CMIO Summit 2011 | Karen Bell

Overcoming EHR Certification
Hurdles & Gaps

Karen Bell, MD, MMS – Chair, CCHIT

CMIO Summit
June 10, 2011 | 1:00 – 2:00 PM
Omni Parker House Hotel | Boston, MA

Topics

 Why Certification?
 Current Certification Programs
 EHR Alternative Certification for Healthcare Providers or
EACH™
 The EACH Process
 Tips for Providers
 The Future
 Q&A

© 2011 CCHIT | Slide 2 | June 2011

About CCHIT


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

 Meet specific objectives -- i.e., government defined measures
 Stimulate innovation – identify floor on which to innovate


EHR Certification:
Providers Find Value
Measurement
Specialty-Specific
Workflow Support beyond Federal MU
Functionalities
(e.g., ACO)

Functionalities Plug-and-Play Data
Usability Testing
beyond Basic Interchange
and Rating
Federal Capability

Efficient Integration Real-world usage
Stronger Security
of Functionalities verification

Basic Federal Vendor Stability Data Portability
Compliance for and Support (future-proofing)
Meaningful Use


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
 Codified in federal regulation


Two Certification Programs

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

Criteria and Testing Volunteer subject matter experts Federal government
Tool Development

Providers served Many types of providers seeking greater Medicare and Medicaid eligible
assurance when investing in new EHRs; providers and hospitals seeking
specialty options available incentive payments

Technology certified Comprehensive, integrated EHRs + use Broad, flexible array of EHR
verification, usability rating and vendor technologies: complete EHR and
characteristics EHR modules

Accountable to Providers Government

Goals Assurance of functionality, interoperability, Meaningful use (as defined by CMS)
security; meet provider needs for to improve outcomes of care,
transparency of product support health reform


Available CCHIT Certified® programs


CCHIT’s
ONC-ACTB
Certification Program


Three Steps to the Meaningful Use
Incentive Payment Process
Step 1: Step 2: Step 3:
Adopt certified Achieve Apply
EHR technology meaningful use for payment
EHR is certified by an Hospital or Eligible Hospital or Eligible
ONC-authorized Provider achieves Provider submits data
testing and certification Meaningful Use or reports in a manner
body against ONC- goals, objectives, and defined by CMS and
developed criteria and measures published collects payment
standards and NIST by CMS
test procedures

© 2011 CCHIT | Slide 10

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
 Qualified EHR: Either a complete EHR or a collection of
modules that are certified to meet every certification critierion


ONC-ATCB 2011/2012 Hospital Criteria
A provider must
possess “certified
EHR technology”
meeting all criteria
to qualify
for incentives

From CCHIT’s Certification Facts™ product
listings


Finding more information about ONC
criteria and test procedures
ONC’s website with a link to “Standards
and Certification Criteria for Electronic Health Records”

NIST’s website with a link to “Approved Test
Procedures”


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
 A vendor has chosen not to present an updated EHR for ONC-
ATCB 2011/2012 certification


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
 An individual product page includes all of the ONC reporting
requirements


CCHIT’s EHR
Alternative Certification
for Healthcare Providers
or “EACH”


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
 Alternative certification is not needed if a hospital or
eligible provider has adopted an EHR with Complete
certification, or a combination of certified EHR Modules
supporting all Meaningful Use objectives


How do we know if
we need EACH?


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.

Click here


What’s the process?

Determine Certify your Register to
your products and participate in
certification retrieve CMS the EHR
needs Identifier from Incentive
ONC Program


Examples of certification scenarios –
which are you?

A single, uncertified system

A mix of systems, some certified EACH

Many sites with many different systems


A single, uncertified system

CMS
Self-developed Complete EHR EACH ID

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


A mix of systems, some certified

170.302(a)
170.302(b)

Vendor-certified CMS
product ID

170.302(c)
170.302(d) EACH
Self-developed


Many sites with many different systems

170.302(a)
170.302(b)
170.302(c)

170.302(a) CMS ID
170.302(b) EACH CMS ID
170.302(c)

170.302(a) MyEHR
170.302(b) Uncertified Vendor Product
170.302(c) Self-Developed Product
Certified EHR


The EACH Process


Three phases in the EACH Program

Preparation Readiness Certification

Online program Online self-assessment Inspection scheduled
orientation tool with learning program when applicant is prepared

Introduction to the Site inventory and gap Virtual web-based testing
EACH online community analysis of criteria not using ONC criteria and
of hospitals covered by certified EHR NIST test procedures
technology
Team formed and ready Certification results
for self-assessment Certification learning reported and sent to ONC;
program with toolkit listed at cchit.org
including test scripts and
interoperability guide Retests available


SR17

Phase 1: Preparation

Create an account at
each.cchit.org

Take a learning course and
understand what testing and
certification mean to you


SR17 Insert screen shot of orienation learning program
Sue Reber, 11/29/2010

SR18

Phase 1: More Preparation

Explore Resources

Participate in our
- Community
- Weekly Webinar


SR18 Insert screen shot of orienation learning program
Sue Reber, 11/29/2010

SR19
You may certify a
complete EHR to meet
Phase 2: Readiness all criteria

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


SR19 Insert shot of application
Sue Reber, 11/29/2010

SR20

Phase 2: More Readiness

Creating an inventory
to assess your gaps

Build a plan to fill in
your gaps


SR20 Insert shot(s) of assessment tool
Sue Reber, 11/29/2010

Phase 2: More Readiness

Practice
demonstration
& customized
reports Readiness reports
can also be used
as Medicaid
attestation
documentation


Phase 3: Certification

CCHIT
Tester

Healthcare
Web conferencing and providers follow
concurrent audio Test Script to
conferencing demonstrate EHR
technology at their
facility


End Result of Certification

Reported to
ONC-CHPL
and
CMS EHR
Certification ID
rendered


Tips for Providers


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!
 Specialists who want available specialty certification and incentive
payments


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
 Proceed with an EACH certification


The Future ???


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
 An evolutionary process, learn as we go


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
 Continues to match HIT innovation with new, complimentary certification
processes that focus on provider/patient protection and patient care


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
 CCHIT has limited scholarships for CAHs


Questions & Answers

Karen Bell kbell@cchit.org

More information available at
cchit.org and at EACH


CMIO Summit 2011 | Karen Bell

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