The Office of the National Coordinator has until December 31 to release a final set of EHR standards and certification criteria on which vendors can base their products and claim compliance with requirements outlined in the American Recovery and Reinvestment Act.
The timeline means there could potentially be several more months of unknowns related to what incentive prerequisites will entail. What will the certification of a qualified EHR look like? What will the parameters of meaningful use include? What will be required of vendors and providers to adapt to those changes?
If we all had a crystal ball, perhaps we could forecast the future. But there is no crystal ball. And right now, the industry must simply wait for additional guidance.
Even the Certification Commission for Healthcare Information Technology (CCHIT)—the organization that has been certifying EHR vendors since 2006—isn't privy to what the ONC will decide, says Sue Reber, marketing director for CCHIT. Though the commission will publish its final 2009-2010 certification criteria on Friday, Reber acknowledges there may be more changes to come.
"We are trying to remain as flexible as possible so we can react quickly to those decisions," she says. "Hopefully with the work of the HIT standards committee, we'll see some guidance later this summer, and then we’ll be able to adjust the criteria."
CCHIT will delay the launch of its 2009-2010 certification program until it has at least reviewed the draft standards and certification criteria that are due to HHS by August 26, according to ONC operating plan released May 18. CCHIT has not established a final implementation date for its new criteria and testing though Reber speculates it will be “later this year.” CCHIT typically launches its new certification programs on July 1.
But that shouldn't stop physicians from considering a certified EHR product, Reber says. That's because most current CCHIT certification criteria already include many of the "qualified electronic health record" capabilities required by ARRA, such as physician order entry, clinical decision support, and the ability to capture quality information and exchange electronic health information, Reber says. However, once HHS publishes specific standards and certification criteria—as well as the parameters for meaningful use—CCHIT will adjust the criteria to reflect those requirements, she adds.
One important change for 2009-2010 is that CCHIT's Certification Handbook, which includes the policies of the commission’s certification programs, is undergoing significant revisions to take into account the expanded applicability of EHR certification under ARRA, Reber says. As a result, the commission will not publish it until later this summer.
For example, the commission is researching a process for a more extensive verification of successful implementation and usability of commercial products.
It has also formed a subcommittee to research usability measurement, though many of the details have not yet been established, Reber says.
The commission will also pilot a program to inspect and certify EHR technologies-in-use that will accommodate a greater variety of development and deployment models. This includes looking at lower cost ways to certify open source, best-of-breed, or a variety of other self-developed or modular approaches to EHR implementation, Reber says. "We may not certify these as commercial products, but for the purposes of ARRA qualification, we may certify them as products used onsite in single environments," she adds.
CCHIT’s 2009-2010 criteria pertain to EHRs used in the following settings:
There are also newly developed stand-alone criteria for e-prescribing and updated criteria for ambulatory add-on options in child health and cardiovascular medicine. Each set of criteria will include a simplified user’s guide to help providers and others understand how the current criteria map to requirements already outlined in ARRA, Reber says.