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CHIME: EHR certification criteria could change with time - July 5, 2010

Orlando Florida
The government’s certification program for health IT will continue to evolve over time, according to a review of the recently released final rule for the temporary certification program, released last week by the College of Health Information Management Executives (CHIME).

The temporary program to certify EHR technology went into effect on June 24, and it will be replaced by the permanent certification program as soon as Dec. 31, 2011. However, CHIME found that the recently released final rule suggests that EHR will need to be certified on an ongoing basis, and that meaningful use criteria are likely to evolve over time.

“Regardless of the year and meaningful use stage at which an eligible professional or eligible hospital enters the Medicare or Medicaid EHR Incentive Program, the certified EHR technology that they would need to use would have to include the capabilities necessary to meet the most current certification criteria,” according to the temporary certification rule.

While the industry is uncertain about the final shape of the meaningful use objectives that Centers for Medicare & Medicaid Services (CMS) will choose, the temporary certification final rule suggests that Stage 1 criteria could become tougher over time, the Ann Arbor, Mich.-based CHIME stated.

CHIME’s interpretation of the rule suggests that, although Stage 1 criteria will be finalized soon, it is possible future rule-making could include updates to the Stage 1 criteria, said Pamela McNutt, senior vice president and CIO at Dallas-based Methodist Health System and chair of CHIME’s Policy Steering Committee.

The final rules for temporary certification don’t require recertification for HIT product updates and “fixes” that don’t adversely affect meaningful use criteria. However, a product may be certified if there are any concerns about changes in an application that could affect its ability to achieve meaningful use objectives.

In addition, the authorized testing and certification bodies (ATCBs) recognized by the Office of the National Coordinator for Health IT (ONC) cannot require that integrated bundled EHRs or EHR modules be certified to a higher set of standards than the certification criteria set by the ONC. CHIME viewed this clarification as a positive result of the commenting process that caused ONC to re-evaluate the proposed rule.

CHIME also positively viewed provisions in the final regulation that call for ATCBs to provide remote testing of applications. The regulations state that an application need not be live at a customer’s site before it is tested, opening the way for testing of applications at vendors’ facilities.

The organization still is concerned that a product’s certification can be revoked for some “Type 1” violations by an ATCB that would prompt questions about the integrity of the certification of those products. If a product loses certification, a healthcare organization would have 120 days to secure a certified product, either by the vendor having its product re-certified by a different ATCB or installing another certified product.

While the loss of a product’s certification is unlikely, any such occurrence will probably affect hundreds of provider organizations and could place them under extreme stress to resolve the issue quickly, CHIME said.




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