ONC provides an EHR certification list you can bank on

Behavioral health providers seeking a duly certified electronic health record (EHR) as the first step to earning federal incentives for using information technology need only check the available inventory accumulating on a new Web site established by the Department of Health and Human Services.

Of course, having definitive EHR certification information in one place may take some getting used to, given the noise from the other EHR certification labels and designations that have come and gone during more than a year of “preliminary” certification activity.

The American Recovery and Reinvestment Act of 2009 (ARRA), in a bid to stimulate adoption of “meaningful use” of EHRs among the nation's hospitals and certain healthcare professionals, authorized billions of dollars in financial incentives and laid out a three-step process to qualify for the dangled dollars: (1) acquire certified EHR technology; (2) employ the technology to hit certain marks for meaningful use over three stages of requirements through 2015; and (3) report the results to the Centers for Medicare and Medicaid Services (CMS).

As the healthcare industry waited throughout 2009 and into 2010 for the HHS Office of the Coordinator for Health Information Technology (ONC) to articulate the final form of the meaningful-use objectives and work with CMS to turn them into regulations, the Certification Commission for Health Information Technology (CCHIT)-the only certifying body at the time-sought to design interim certification testing around the preliminary criteria being discussed by the ONC. CCHIT then planned to make alterations as needed when the final criteria came out.

“Our aim is to ensure that hospitals and doctors have enough time to purchase and implement certified EHRs and achieve meaningful use in time to qualify for HHS financial incentives in 2011 and 2012,” CCHIT executive director Alisa Ray explained in announcing the second of two preliminary adjustments to its ARRA criteria in January 2010, when ONC published an interim final rule on certification criteria. “With eligibility for hospitals opening in October 2010, there is an urgent need for certification programs to be in place.”

But in March 2010, ONC announced it was creating a new and separate program for the purpose of certifying the ability of EHRs to support its Stage 1 meaningful use objectives-actually two consecutive programs. To meet the impending launch of the incentive program in October, the office said it would create a temporary process to get “certifying bodies” accredited and operating for them to test and certify EHR products in time. Meanwhile it would work on a permanent program, operating more formally under the auspices of outside accreditation organizations, which would take effect at an indeterminate future date.

Since July, when ONC published a final rule on the certification process and started taking applicants, a growing number of organizations have been designated an “authorized testing and certification body,” recognized by the acronym ONC-ATCB. As of January 2011, there are six such bodies:

• CCHIT, the Chicago group formed in late 2004 by three health IT-related organizations at the behest of the first national coordinator, Dr. David Brailer, to specify minimum functions, security measures and data exchange abilities for EHRs in hospital and office settings.

• Drummond Group, Inc. (Austin, Tex.)

• ICSA Labs (Mechanicsburg, Pa.)

• InfoGard Laboratories (San Luis Obispo, Calif.)

• SLI Global Solutions (Denver, Colo.)

These five ATCBs have a scope of authorization that includes complete EHRs and EHR modules. The sixth ATCB, Surescripts LLC (Arlington, Va.), has a narrower authorized scope: EHR modules for E-prescribing, Privacy, and Security only.

For providers shopping new EHR systems or planning to upgrade an existing EHR to a version that qualifies for incentives under ARRA's Health Information Technology Economic and Clinical Health (HITECH) Act, “The only certification that counts right now are those criteria that are coming out of ONC and [EHRs that] are being certified as part of the temporary certification process,” said Rik Drummond, chief executive officer of Drummond Group. “Anything previous to that will not get you the meaningful use funds from HITECH … That's very straightforward, that's the only way this happens.”

And because ONC took the reins of certification and engineered both a common process and an oversight function for authorized testing/certification bodies, “We're all exactly the same; we all operate the same level of procedures to do the testing and certification,” said Drummond. “There's no difference in what we're doing there.”

ONC has established a “certified health IT product list” website at https://onc-chpl.force.com/ehrcert. As of yearend 2010, the site already lists more than 200 products (thankfully, in alphabetical order by product name) that have been tested under ONC-ATCB procedures and given a unique certification number. The site specifies whether an EHR is “complete” or “modular,” but thus far does not distinguish between EHRs for the hospital and office settings. An ONC spokesperson said the next version of the website, expected in early 2011, will have increased functionality including the ability to filter and sort by care setting.

A complete EHR is capable of supporting all 15 core objectives for eligible providers (14 for hospitals) plus an additional menu of 10 from which providers must choose five to implement in 2011 and 2012 to attain Stage 1 of meaningful use. Core objectives include the ability to maintain information such as demographics, medication and allergy lists, current diagnoses, vital signs and smoking status, and to accomplish clinical tasks electronically such as ordering, prescribing and detection of dangerous drug interactions. For a complete set of core and menu criteria and a CMS explanation, see this presentation at https://www.cms.gov/EHRIncentivePrograms/Downloads/MU_Stage1_ReqSummary.pdf.

An EHR product granted modular certification can support some but not all the objectives-either because the vendor purposely chose to concentrate on a subset of criteria or its product did not yet pass all the testing requirements for a complete EHR. Providers electing to pick and choose among two or more modular systems must gather and integrate on their own a complete set of capabilities to qualify for incentives, and report the multiple certification numbers.

According to the final rule on the certification programs, the temporary program is scheduled to run through 2011, or until the permanent program is fully constituted following a new round of federal rulemaking. The ONC spokesperson was not permitted to discuss the time horizon for the permanent program outside that rulemaking.

Conventional wisdom holds that the permanent program is gearing up to take over when ONC begins requiring the more advanced EHR capabilities in HITECH's Stage 2. “Everyone anticipates that once a product is certified, it will last you through Stage 1,” said Dr. Karen Bell, CCHIT's chair. “When Stage 2 comes around, it's going to be a whole new certification process.” The certification rule indicates that EHR technology must be re-certified every two years.

“Any vendor who's certified by the temporary process before Dec. 31, 2011, has a product that will remain certified with a high degree of probability until the new criteria are out and effective for Stage 2,” Bell added. “I can't guarantee this, but that's what makes sense, and so we're hoping that because it makes sense, that's what will happen.”

CCHIT offers “additional” behavioral health certification

Remember that CCHIT workgroup that was developing certification criteria tailored to behavioral health EHR users?

That group, CCHIT's Behavioral Health workgroup, completed its efforts-very much behind the scenes-and produced criteria that support new “additional” and “standalone” certifications that are specific to behavioral health EHRs. These two certificates were launched in July 2010:

• CCHIT's “Additional Certification” for Behavioral Health certifies that a set of behavioral health criteria have been added to an ambulatory EHR package. The certificate is termed “additional” because it can be added to EHRs that qualify, or will be qualified, for the separate ONC-ATCB certification-the one that's needed to get HITECH EHR incentive funds.

• CCHIT's “Standalone Certification” for Behavioral Health is relevant only to EHRs that are specifically built for behavioral health and for which ONC-CHPL certification is not a consideration.

By yearend, two ambulatory EHR products earned CCHIT's Additional Certification for behavioral health. One of the EHRs, from NextGen Healthcare, has also earned the ONC-CHPL certificate. The other EHR, from UNI/CARE Systems, is listed with a “pre-market” status for the Additional Certification, pending verification of use at physician offices, and has yet to earn its ONC-CHPL certification.

No products are yet listed as having earned CCHIT's Standalone Certification for behavioral health. For the latest status about products that have earned CCHIT's behavioral health certifications, visit www.cchit.org, click on the “Find Products” tab, and sort for the certifications you're looking for.

CCHIT's behavioral health-specific certification criteria include things that automate the information-gathering and work flow of that environment, such as:

• Creating initial assessments and documenting results.

• Capturing results of standardized assessment tools and additional data that augment those tools.

• Enabling assessment data to populate the treatment plan.

• Prompting for additional assessments based on practice standards.

• Association of clinical notes with treatment plan issues/elements.

• Entering guardian or conservator information as structured data.

• Capturing a signature of someone not authorized to access the system (guardian, probation officer, etc.).

• Assigning one or more providers to specific interventions within a treatment plan.

• Supporting DSM codes.

Depending on the willingness of other EHR vendors to submit their products for both HITECH certification and CCHIT's Additional Certification for behavioral health, providers eligible for EHR incentives won't have to choose between a system that gets them federal money and one that's attuned to their work.

The broader picture of what EHRs can and should do for health professionals is a frequent refrain for Dr. Karen Bell, CCHIT chair, when she talks about certification against the backdrop of HITECH.

Providers should ask themselves what their purchase goals are, said Bell. “Are they doing it to basically just get the meaningful-use incentive payments? Or are they doing this because it's part of a longer-term investment and a commitment that the whole practice has made-and when I say the whole practice, I mean everyone down to the front-desk receptionist-to really modify their practice and deliver better care to their patients?”

The HITECH [ONC-ATCB] certification is “tied to whatever it takes to meet Stage 1 meaningful use,” she added. “So if it's not in Stage 1 meaningful use, it's not going to be in ONC's certification process … [It is] therefore very much focused on getting structured data into an EHR, and it's not necessarily focused at this point on what it takes to care for patients.”

Behavioral Healthcare 2011 January-February;31(1):22-24