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 2011 CCHIT Slide 3 June 2011
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 2011 CCHIT Slide 4 June 2011
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 Real-world usage verification Basic Federal Compliance for Meaningful Use Vendor Stability and Support Data Portability (future-proofing) 2011 CCHIT Slide 5 June 2011
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 2011 CCHIT Slide 6 June 2011
Two Certification Programs Nature of certification Voluntary, robust Mandatory for $$$, to minimum government standards Criteria and Testing Tool Development Providers served Technology certified Volunteer subject matter experts Many types of providers seeking greater assurance when investing in new EHRs; specialty options available Comprehensive, integrated EHRs + use verification, usability rating and vendor characteristics Federal government Medicare and Medicaid eligible providers and hospitals seeking incentive payments 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, support health reform 2011 CCHIT Slide 7 June 2011
Available CCHIT Certified programs 2011 CCHIT Slide 8 June 2011
CCHIT s ONC-ACTB Certification Program 2011 CCHIT Slide 9 June 2011
Three Steps to the Meaningful Use Incentive Payment Process Step 1: Adopt certified EHR technology EHR is certified by an ONC-authorized testing and certification body against ONCdeveloped criteria and standards and NIST test procedures Step 2: Achieve meaningful use Hospital or Eligible Provider achieves Meaningful Use goals, objectives, and measures published by CMS Step 3: Apply for payment Hospital or Eligible Provider submits data or reports in a manner defined by CMS and collects payment 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 2011 CCHIT Slide 11 June 2011
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 2011 CCHIT Slide 12 June 2011
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 2011 CCHIT Slide 13 June 2011
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 2011 CCHIT Slide 14 June 2011
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 2011 CCHIT Slide 15 June 2011
CCHIT s EHR Alternative Certification for Healthcare Providers or EACH 2011 CCHIT Slide 16 June 2011
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 2011 CCHIT Slide 17 June 2011
How do we know if we need EACH? 2011 CCHIT Slide 18 June 2011
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 2011 CCHIT Slide 19 June 2011
What s the process? Determine your certification needs Certify your products and retrieve CMS Identifier from ONC Register to participate in the EHR Incentive Program 2011 CCHIT Slide 20 June 2011
Examples of certification scenarios which are you? A single, uncertified system A mix of systems, some certified EACH Many sites with many different systems 2011 CCHIT Slide 21 June 2011
A single, uncertified system Self-developed Complete EHR EACH CMS 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 2011 CCHIT Slide 22 June 2011
A mix of systems, some certified 170.302(a) 170.302(b) Vendor-certified product CMS ID 170.302(c) 170.302(d) Self-developed EACH 2011 CCHIT Slide 23 June 2011
Many sites with many different systems 170.302(a) 170.302(b) 170.302(c) 170.302(a) 170.302(b) 170.302(c) EACH CMS ID CMS ID 170.302(a) 170.302(b) 170.302(c) MyEHR Uncertified Vendor Product Self-Developed Product Certified EHR 2011 CCHIT Slide 24 June 2011
The EACH Process 2011 CCHIT Slide 25 June 2011
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 Retests available 2011 CCHIT Slide 26 June 2011
SR17 Phase 1: Preparation Create an account at each.cchit.org Take a learning course and understand what testing and certification mean to you 2011 CCHIT Slide 27 June 2011
Slide 27 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 2011 CCHIT Slide 28 June 2011
Slide 28 SR18 Insert screen shot of orienation learning program Sue Reber, 11/29/2010
SR19 Phase 2: Readiness You may certify a complete EHR to meet all criteria You may certify an EHR module to meet just a few criteria 2011 CCHIT Slide 29 June 2011
Slide 29 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 2011 CCHIT Slide 30 June 2011
Slide 30 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 2011 CCHIT Slide 31 June 2011
Phase 3: Certification CCHIT Tester Web conferencing and concurrent audio conferencing Healthcare providers follow Test Script to demonstrate EHR technology at their facility 2011 CCHIT Slide 32 June 2011
End Result of Certification Reported to ONC-CHPL and CMS EHR Certification ID rendered 2011 CCHIT Slide 33 June 2011
Tips for Providers 2011 CCHIT Slide 34 June 2011
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 2011 CCHIT Slide 35 June 2011
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 2011 CCHIT Slide 36 June 2011
The Future??? 2011 CCHIT Slide 37 June 2011
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 2011 CCHIT Slide 38 June 2011
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 2011 CCHIT Slide 39 June 2011
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 2011 CCHIT Slide 40 June 2011
Questions & Answers Karen Bell kbell@cchit.org More information available at cchit.org and at EACH 2011 CCHIT Slide 41 June 2011