Overcoming EHR Certification Hurdles & Gaps

Karen Bell, MD, MMS – Chair, CCHIT

CMIO Summit

June 10, 2011 | 1:00 – 2:00 PM

Topics

 Why Certification?

 Current Certification Programs

 EHR Alternative Certification for Healthcare Providers or

EACH™

 The EACH Process

 Tips for Providers

 The Future

Why EHR Certification?

 Purchaser (provider and patient) protection -- system has

desired features and functions as advertised

 Security – at least to a minimum set of testable criteria

 Interoperability – includes standards for

 Nomenclature  Messaging

 Implementation guidance  Transport

EHR Certification:

Providers Find Value

Workflow Support Measurement beyond Federal MU (e.g., ACO) Specialty-Specific Functionalities Functionalities beyond Basic Federal Plug-and-Play Data Interchange Capability Usability Testing and Rating Efficient Integration

of Functionalities Stronger Security

Current Certification Programs

 Provider and patient accountable

 Multiple settings and specialties, each with its separate program  Multi-stakeholder engagement, piloting, and updating

ONC-ATCB certified

 Developer focused (vendor or provider)

 Eligible provider (ambulatory) and Inpatient settings only  Essentially one size fits all

Two Certification Programs

Nature of certification Voluntary, robust Mandatory for $$$, to minimum government standards

Criteria and Testing Tool Development

Volunteer subject matter experts Federal government Providers served Many types of providers seeking greater

assurance when investing in new EHRs;

specialty options available

Medicare and Medicaid eligible

providers and hospitals seeking

incentive payments Technology certified Comprehensive, integrated EHRs + use

verification, usability rating and vendor characteristics

Broad, flexible array of EHR technologies: complete EHR and EHR modules

Accountable to Providers Government Goals Assurance of functionality, interoperability,

security; meet provider needs for transparency of product

Meaningful use (as defined by CMS) to improve outcomes of care,

CCHIT’s

ONC-ACTB

Three Steps to the Meaningful Use

Incentive Payment Process

Step 1:

Adopt certified

EHR technology

Step 2:

Achieve

meaningful use

Step 3:

Apply

for payment

testing and certification body against

ONC-developed criteria and standards and NIST test procedures

Hospital or Eligible Provider achieves

Meaningful Use

goals, objectives, and measures published by CMS

Hospital or Eligible Provider submits data

Federal definitions of

certified EHR technology

 Complete EHR: able to perform, at a minimum, all of the

applicable capabilities required by certification criteria adopted

by the Secretary, and thereby, as providing eligible

professionals or eligible hospitals with the technical

capabilities they need to support their achievement of

meaningful use of certified EHR technology

 EHR Module: any service, component, or combination thereof

that can meet the requirements of at least one certification

criterion adopted by the Secretary

ONC-ATCB 2011/2012 Hospital Criteria

From CCHIT’s Certification Facts™ product listings

A provider must possess “certified

EHR technology” meeting all criteria

Finding more information about ONC

criteria and test procedures

ONC’s website with a link to “Standards

and Certification Criteriafor Electronic Health Records”

NIST’s website with a link to “Approved Test

Lesson Learned: IT’S COMPLICATED!!

 Provider developers and vendor developers have different missions, business strategies, and objectives for their EHRs

 Many hospitals (and some physicians) use combinations of the above (best of breed approach) to meet their strategic objectives

 ONC criteria (modules) may not match clinical workflows

 A model of obtaining “certified EHR technology” from a vendor fails when:

 Health IT is partly or fully self-developed  A product has been significantly customized

 A commercial product version is too old to be upgraded  A hospital is in a multi-year product upgrade or conversion

Where providers can find ONC-ATBC

certification results

 ONC’s Certified HIT Products List (CHPL) Web Page

 All certified Complete EHRs and EHR Modules that meet the definition of Certified EHR Technology (from all ONC-ATCBs)  Providers electing to combine Modules use the CHPL to validate

whether the Modules they have selected satisfy all of the applicable certification criteria

 Generates ID number required for CMS application

 CCHIT’s “Find Products”

Web Page (inspected by us)

 An aggregate, cross-indexed product listing with a faceted search capability to help providers find products that meet their needs

CCHIT’s EHR

EHR Certification Alternative for

Healthcare Providers (EACH™)

 A certification alternative for hospitals and eligible

providers who are

 Self-developing or significantly customizing EHR technology

 Using older, uncertified EHR technology

 Needing gap closure due to a mix of certified and uncertified

EHR technologies

First – check your eligibility

Review the CMS requirements for eligibility at their EHR Incentive Program web site. If you are an eligible professional, you can use their Eligibility Wizard.

Examples of certification scenarios –

which are you?

A single, uncertified system

A mix of systems, some certified

Many sites with many different systems

A single, uncertified system

CMS ID

Self-developed Complete EHR

All criteria are applied for with one system in

use at one location or multiple, identical

locations, a Complete EHR certification is

granted with one CMS ID

Many sites with many different systems

Uncertified Vendor Product Self-Developed Product Certified EHR

CMS ID

Three phases in the EACH Program

Preparation

Readiness

Certification

Online program orientation

Introduction to the

EACH online community of hospitals

Team formed and ready for self-assessment

Online self-assessment tool with learning program Site inventory and gap analysis of criteria not covered by certified EHR technology

Certification learning program with toolkit

including test scripts and interoperability guide

Inspection scheduled when applicant is prepared Virtual web-based testing using ONC criteria and NIST test procedures Certification results

reported and sent to ONC; listed at cchit.org

Phase 1: Preparation

Create an account at each.cchit.org

Slide 27

SR17 Insert screen shot of orienation learning program

Slide 28

SR18 Insert screen shot of orienation learning program

Phase 2: Readiness

You may certify an EHR module to meet just a few criteria

You may certify a

complete EHR to meet

all criteria

Slide 29

SR19 Insert shot of application

Phase 2: More Readiness

Creating an inventory to assess your gaps

Build a plan to fill in your gaps

Slide 30

SR20 Insert shot(s) of assessment tool

Phase 2: More Readiness

Practice

demonstration & customized

reports _{Readiness reports} can also be used as Medicaid

Phase 3: Certification

Which ambulatory certified product(s)

might work best for you?

ONC ATCB 2011/2012 only

 Experienced in health IT or have your own self developed system  Desirous of a “niche” product or other technology for which there is

not a CCHIT Certified® program at present

CCHIT Certified® only - providers for whom there are no

incentive payments

Dual Certification: CCHIT Certified® and ONC-ATCB cert

 Just about everyone else in the ambulatory environment!

Approaching Hospital EHR Certification

 Check with your vendors as to their intent to certify… and to which criteria

 If vendor has an ONC-ATCB certified complete EHR, go no further (must use it)

 If using an older version of a vendor product, ask for Privacy and Security upgrade, and modular certification of whatever is compliant with ONC criteria  Conduct your own gap analysis on older (or self developed) products and

services (using the NIST test procedures for each ONC criteria) to determine extent of upgrades and additional modules necessary to achieve compliance (CCHIT’s readiness program can help)

 Consider cost of investment, ROI and fit with timing of current business plan  Buy, build or update as needed

More Lessons Learned

 Need to pilot NIST developed test procedures before “go live”  Need to assure that all criteria can be objectively tested

 Time intensive interoperability testing, but no testing of actual ability to exchange data in the native environment

 No guarantee that “receivers” can accept data

 Note that not all CQM measures need to be tested and certified as part of EP “calculate and report quality measures” criterion

 Some criteria need greater specificity, some need less

 Hospitals who use “best of breed” may need multiple, duplicative modules

Near Future

ONC Certification

 Stage Two Meaningful Use, Standards, and Certification Criteria (2013?)  Transition from 6 ONC Authorized Testing and Certifying bodies to a

limited set of Testing labs overseen by NIST and ONC authorized

Certification bodies – can be the same entity – but certifications to remain active until new criteria are released

 Permanent Certification rule calls out certification for HIT other than EHRs: PHRs, remote monitoring devices, HIE entities

 Always tied to MU objectives and measures

CCHIT Certified®

 Only ONC certification organization to go beyond federal minimum

In Summary

 CCHIT is an ONC-ATCB for ONC-ATCB 2011/2012

certification for both vendors and providers

 CCHIT also offers a number of CCHIT Certified®

vendor programs (since 2006)

 We have immediate capacity for EHR testing in all

programs

 We offer an EHR alternative certification for both

hospitals and eligible providers called “EACH” to help

providers qualify for ARRA funds

Questions & Answers

Karen Bell

[email protected]

More information available at