tag:blogger.com,1999:blog-4384692836709903146.post3983516144784767568..comments2024-03-18T04:38:01.678-07:00Comments on Dispatch from the Digital Health Frontier: Clarifying Certification Part IIJohn Halamkahttp://www.blogger.com/profile/04550236129132159307noreply@blogger.comBlogger10125tag:blogger.com,1999:blog-4384692836709903146.post-49053790834101092632010-11-23T13:16:05.269-08:002010-11-23T13:16:05.269-08:00Ferdinand, the link to the ONC FAQ page is http://...Ferdinand, the link to the ONC FAQ page is http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163 Click the link on question #17.Davidhttps://www.blogger.com/profile/13251393010554964308noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-30333275518180670042010-11-15T20:31:24.758-08:002010-11-15T20:31:24.758-08:00I just read an AHA bulletin referring to an ONC Q&...I just read an AHA bulletin referring to an ONC Q&A that appears to settle this question. However, I couldn't find the Q&A on the ONC and CMS FAQ pages. Here's the text from the AHA note:<br /><br />Question [9-10-017-1]:<br />Under the Medicare and Medicaid EHR Incentive Programs Final Rule, eligible health care providers are permitted to defer certain meaningful use objectives and measures and still receive an EHR incentive payment. However, it is our understanding that in order for us to have our EHR technology certified, we must implement all of the applicable capabilities specified in the adopted certification criteria regardless of whether we intend to use all of those capabilities to qualify for our EHR incentive payment. Is our understanding correct?<br />ONC Answer:<br />Yes, this understanding is correct. The flexibility offered as part of the Medicare and Medicaid EHR Incentive Programs Final Rule is not mirrored in the Initial Set of Standards, Implementation Specifications, and Certification Criteria Final Rule because we believe that it is important to accommodate eligible health care providers’ ability to achieve meaningful use. We recognize that in some circumstances an eligible health care provider may not know which meaningful use measures they will seek to defer until they begin implementation and in others an individual provider (even within a specialty) will want to choose different measures to defer based on their local situation and implementation experience. Thus, in order to possess EHR technology that meets the definition of Certified EHR Technology, it must be tested and certified by an [ONC-Approved Testing and Certification Body] to all applicable certification criteria adopted by the Secretary.Ferdinand Velascohttps://www.blogger.com/profile/13611583335814047506noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-18244082929903890222010-10-19T16:13:39.292-07:002010-10-19T16:13:39.292-07:00Thank you for clarifying the first issue as the ON...Thank you for clarifying the first issue as the ONC and CMS had a very confused response to this question in their developer's conference call in July. We had emailed you earlier and really appreciate your effort to verify this with the government officials.Bristowhttps://www.blogger.com/profile/13572556348429564723noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-9172176373287953762010-10-15T12:11:12.423-07:002010-10-15T12:11:12.423-07:00In response to Mary Dee: It looks like the boxes ...In response to Mary Dee: It looks like the boxes that are not checked are either 170.304xxx or 170.306xxx depending on if the system is ambulatory or inpatient. 304 contains criteria for ambulatory systems. So, if you are an inpatient system, you would not be required to have any of those boxes checked.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-79615569316816952042010-10-15T10:43:59.219-07:002010-10-15T10:43:59.219-07:00John and Mary Dee:
If I may interject, I think th...John and Mary Dee:<br /><br />If I may interject, I think the confusion is stemming from the fact that Complete EHRs for EPs are certified for all criteria in 45 CFR 170.302 (general) and 304 (ambulatory), whereas Complete EHRs for eligible hospitals are certified for all criteria in 45 CFR 170.302 (general) and 306 (inpatient). <br /><br />So, if you look at the ONC's CHPL website for a Complete EHR product certified for the EP version of the program, it can still be a Complete EHR but not certified for any of the Part 170.306 criteria. Likewise, a Complete EHR for the eligible hospital version of the program does not need to be certified against the Part 170.304 criteria. <br /><br />This is why the CHPL lists several Complete EHRs which may seem to the naked eye to not be certified for all criteria. Consumers need to pay attention to the regulatory citations in the checklist.<br /><br />As an additional note, 170.302(w) is an optional criterion, so you could also have a Complete EHR not certified for that one.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-68622088495845196862010-10-14T18:24:24.887-07:002010-10-14T18:24:24.887-07:00I've spoken to numerous policymakers about it ...I've spoken to numerous policymakers about it and I've tried to convey a consensus of their words which is "acquire ALL Core and Menu Set Stage 1 functionality, install it, and report on your use of 20 functions. You cannot just acquire software for the 20 functions." I've edited the blog post a bit to make this clearer.John Halamkahttps://www.blogger.com/profile/04550236129132159307noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-38701048000824556942010-10-14T14:55:56.183-07:002010-10-14T14:55:56.183-07:00I am with Mary Dee. I disagree with this interpret...I am with Mary Dee. I disagree with this interpretation. One has to use a certified EHR in a meaningful way. One does not have to utilize every certified aspect of that EHR.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-88301020665777397702010-10-13T14:20:16.053-07:002010-10-13T14:20:16.053-07:00I agree with your interpretations, but I am intere...I agree with your interpretations, but I am interested in your personal views on the real-world rationale behind requiring EPs who meet the exclusion criteria for certain measures (for example CPOE and eRx) to access modules certified against the corresponding criteria before they have a combination considered to be "Certified EHR Technology."<br /><br />I work as a regulatory compliance specialist for a medical association that serves physicians in a non-primary care medical specialty, and our members will meet the exclusion criteria for almost all of the MU measures that offer exclusion criteria. It is impossible to explain to my members why ONC has this comprehensiveness requirement for modular combinations -- certainly, my members will always have a need for, and meet, the exclusion criteria for several of these PCP-oriented measures. Any thoughts?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-58832249604888701842010-10-13T13:58:45.606-07:002010-10-13T13:58:45.606-07:00I do not represent any government organization, so...I do not represent any government organization, so my comments are only my opinion. However, after speaking with numerous vendors and government staffers, my opinion is that functionality needed to support all 2011 Meaningful Use measures must be installed in the offices of Eligible Professionals and in Hospitals. This means that a Complete EHR or modules from multiple vendors must be installed such that all boxes are checked.John Halamkahttps://www.blogger.com/profile/04550236129132159307noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-55047286950896497492010-10-13T11:51:59.316-07:002010-10-13T11:51:59.316-07:00John, I'm not sure I agree with your interpret...John, I'm not sure I agree with your interpretation of the first issue you brought up regarding the first question here. I have seen this interpretation elsewhere, that an EMR is required to implement all 25 functions and only the provider gets to select which 5 menu items they want to use. <br /><br />If you look at View Criteria for any of the EMRs identified as "Complete EHR" on the HHS "Chapel" list (http://onc-chpl.force.com/ehrcert/productperformanceoverview), you will see most of them do not have all criteria checked. In fact, I have yet to see any that have all of them checked. <br /><br />Am I missing something here?Mary Dee Harrishttps://www.blogger.com/profile/10613708606166830931noreply@blogger.com