tag:blogger.com,1999:blog-4384692836709903146.post5648683615099526169..comments2024-03-27T09:55:23.143-07:00Comments on Dispatch from the Digital Health Frontier: Clarifying CertificationJohn Halamkahttp://www.blogger.com/profile/04550236129132159307noreply@blogger.comBlogger8125tag:blogger.com,1999:blog-4384692836709903146.post-35602740363079550152010-10-11T11:03:22.689-07:002010-10-11T11:03:22.689-07:00John,
After reviewing the initial entries on the ...John,<br /><br />After reviewing the initial entries on the CHPL and participating in numerous discussions over the last week on certification and the impact, I appreciate the concise summary. In particular, the clarification on core and menu items is particularly helpful as this seems to be an area of confusion.<br /><br />Thanks,<br /><br />BrentBrent Antonyhttps://www.blogger.com/profile/01013914028002671225noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-53761487417489574152010-10-07T11:52:31.446-07:002010-10-07T11:52:31.446-07:00Specialist EPs with clinical workflows and HIT nee...Specialist EPs with clinical workflows and HIT needs that do not resemble preventive medicine/primary care really need to satisfy the definition of "certified EHR technology" via the EHR Module combination pathway. What I mean is that many EPs do not have a clinical or business use case for Complete EHR products. Instead, they will rely on their specialty IS vendors to get products such as LIS, AIMS, RIS/PACS, etc, certified for as many criteria in 45 CFR 170.302 and 304 as feasible, then must plug in the gaps with "filler" modules certified against any missing criteria.<br /><br />A better way to define "certified EHR technology" via the modular pathway in the Stage 2 regulations would be to state that combinations of EHR Modules should only need to encompass the certification criteria that directly correspond with CMS meaningful use measures the individual EP needs to satisfy. This removes the requirement that EPs must have access to EHR Modules certified against ONC criteria that correspond with CMS measures for which the EP meets the exclusion criteria (e.g., implementing an eRx module and a CPOE/medications module even though you write <100 prescriptions in an EHR reporting period, and are thus excluded from the CPOE and eRx measures).Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-52064146942590458662010-10-07T09:55:17.568-07:002010-10-07T09:55:17.568-07:00You are correct. All eligible professionals need...You are correct. All eligible professionals need to acquire modules with 25 capabilities to achieve the designated "Certified EHR technology". They can then choose which 20 meaningful use criteria to adopt and attest.John Halamkahttps://www.blogger.com/profile/04550236129132159307noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-74432896892940845232010-10-07T06:49:38.162-07:002010-10-07T06:49:38.162-07:00Thanks for your response. In the eRx example then,...Thanks for your response. In the eRx example then, would the physician have to "collect" all 25 certified modules from multiple vendors first, then adopt only 20 and qualify for the incentive? Or would they have to only gather the 20 certified modules that they wish to adopt and report on those. What confuses me is if a physician who is integrating certified EHR modules from multiple vendors should not be required to purchase all 25 modules but only adopt 20. Your thoughts on this would be highly appreciated.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-56932726390544987752010-10-07T04:15:53.575-07:002010-10-07T04:15:53.575-07:00You've identified the issue precisely. Such ...You've identified the issue precisely. Such a product would NOT quality a clinician for meaningful use. All 25 functions need to be available from modules, even though a clinician only has to attest to using 20 of the them. Stand alone eRx vendors will only achieve modular certification and clinicians will have to use multiple products to achieve "Certified EHR technology" and thus qualify for meaningful use.John Halamkahttps://www.blogger.com/profile/04550236129132159307noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-27884702130851341512010-10-07T03:46:01.486-07:002010-10-07T03:46:01.486-07:00One related comment to this is the modular certifi...One related comment to this is the modular certification. Let me explain with an example - A vendor has, say, 22 of 25 objectives required for certification, which would include the 15 core objectives and 7 of the 10 menu set objectives including the 2 Public Health ones. If a Eligible Provider adopts this solution, will they qualify for MU incentives? In this case, the vendor has modular certification for these 22 modules. The ONC FAQ seems to indicate on page 17 that the vendor should be fully certified on all applicable criteria adopted by the Secretary. If the EP is clear on which 5 menu set objectives they are going to defer and only wants to adopt the 20 modules that make sense to them, why would it be necessary for the vendor to certified on all 25 objectives? Otherwise, standalone solutions, like ePrescribing vendors, will be forced to partner with other modular solutions to offer a complete EHR to customers which is not going to feasible. Can you elaborate your thoughts on this?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-65257149259598325822010-10-04T14:28:22.749-07:002010-10-04T14:28:22.749-07:00Yes, a hospital must have software certified for t...Yes, a hospital must have software certified for the items it choses not to achieve in Stage 1. I've just added an FAQ from ONC/HHS stating this to my post.John Halamkahttps://www.blogger.com/profile/04550236129132159307noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-42502963037434110552010-10-04T13:49:49.942-07:002010-10-04T13:49:49.942-07:00"Regardless of whether one uses a Complete EH..."Regardless of whether one uses a Complete EHR, a combination of EHR Modules or a Site certification, all certification criteria need to be met in all settings."<br /><br />Can you please clarify, "all criteria... need to be met"? Does a hospital have to certify for menu items it chooses not to achieve in Stage 1?Anonymousnoreply@blogger.com