2014 Edition EHR Certification Includes New Transparency Requirements

ONC’s 2014 Edition EHR Certification Criteria define the requirements that EHR technology must meet in order to be used by eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) participating in the Medicare and Medicaid EHR Incentive Programs.  In addition to these criteria, ONC made some policy changes to the HIT Certification Program.

Starting with the 2011 Edition certification, EHR technology developers were required to disclose certain information about their certified products.  This information included: the date the product was certified; the product version certified; the unique certification number or other specific product identification; the clinical quality measures to which the product was certified; any additional software the product relied upon to demonstrate its compliance with certification criteria; and the certification criterion or criteria to which an EHR Module had been certified.

See the grids for 2014 Edition Certification criteria mapped to meaningful use Stage 2 objectives [DOCX - 124 KB] and mapped to meaningful use Stage 1 objectives [DOCX - 107 KB].

In the 2014 Edition Final Rule, we added two new transparency requirements in response to stakeholder feedback.

Publicly Accessible Certification Test Results

The first new provision requires that the test results on which an ONC-Authorized Certification Body (ONC-ACB) based its 2014 Edition certification decision be publicly accessible.  These test reports can be accessed by clicking on any specific 2014 Edition product on the Certified HIT Product List (CHPL) to view its detailed product page. Once there, you’ll find a hyperlink to the test results report.

The test reports provide detailed information on the certification criteria to which the product was certified, the test procedures used during testing, and many other specific details, including the “usability” or, to be more specific, the “user-centered design” processes followed by the EHR technology developer in creating its product.  As part of 2014 Edition certification, EHR technology must be presented to an ONC-ACB with documentation proving that user-centered design processes were applied to each of eight medication-related certification criteria (named in the “safety-enhanced design” certification criterion 45 CFR 170.314(g)(3)) for which certification is requested.

Price Transparency

The second new provision requires ONC-ACBs to ensure that EHR technology developers disclose “[a]ny additional types of costs that an EP, EH, or CAH would pay to implement the Complete EHR’s or EHR Module’s capabilities in order to attempt to meet meaningful use objectives and measures.”  This policy focuses on an EHR technology developer’s responsibility to notify EPs, EHs, and CAHs about additional types of costs (i.e., one-time, ongoing, or both) that may affect an EHR technology’s cost for the purposes of achieving MU.  We clarified, however, that this provision focused on the type(s) of cost(s) that needed to be disclosed, not the actual dollar amount.

6 Comments

  1. I admire this step I think this is very important for EHR technology vendors to disclose certain information about their certified products. Just Labeling Award Winning EHR is not enough.

  2. Cathy Huddle says:

    Price transparency is a great idea. However, from my review of certified vendor websites it appears that some vendors are not doing it at all – or it is next to impossible to find on their site (such as only being available on their Stage 2/2014 press release that is buried in a list of other press releases). Still others include the pricing statement but with extremely vague pricing.

    I am hoping CMS will actually enforce this rule and also develop more specificity around how the pricing should be disclosed.

  3. Janvi Patel says:

    I am agree with cathy huddle. These steps are important to improve the business.

  4. I think this is a significant step in bringing transparency. What I found however, was that most of the stuff was something that providers and healthcare professionals would just not understand. Only people intimately involved in the MU certification process can understand the nuances.

    It is a great step nonetheless.

  5. MahiTricks says:

    I am full agree with cathy huddle. Your Guide is very useful

  6. What makes me so happy to see is that transparency is being addressed regardless of the current administration. Frankly, I don’t see much movement except lip service in terms of real transparency from the current admin. But it’s very nice to see each organization take it upon themselves to address the issue and start working on it independently. Thank you for talking about a topic when most want to avoid it and just hope the public forgets about it. It’s much appreciated.

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