Certified EHR/Health IT Products List Now Available

Health care providers who are eligible to participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs now have a new tool to help them on their road to meaningful use. As of November, ONC’s official Certified Health IT Product List (CHPL) identifies EHR technologies that have been tested and certified as being technically capable of supporting those providers’ achievement of meaningful use based on Stage 1 criteria outlined in HHS rules published on July 28 of this year.

The CHPL now includes more than 90 certified EHR technologies, and the list continues to grow.

A couple of important points about the CHPL:

  1. ONC maintains the CHPL, which is the authoritative, comprehensive, aggregate list of all the EHR technologies certified by an ONC-Authorized Testing and Certification Body (ONC-ATCB). EHR technologies that have been certified by ONC-ATCBs and appear on CHPL are eligible to be used for the Medicare and Medicaid EHR Incentive Programs, and will be given a reporting number for that purpose. At the time of registration or attestation with the Centers for Medicare & Medicaid Services (CMS), eligible providers can use those reporting numbers as part of qualifying for EHR incentive payments. (This part of the process is shown on the CMS timeline for the Medicare and Medicaid EHR Incentive Programs milestones.)
  2. The Certified Health IT Product List is a snapshot of currently certified EHR technologies. Each Complete EHR and EHR Module on the CHPL has been certified by an ONC-ATCB and reported to ONC. This list is regularly updated as newly certified EHR technologies are reported to ONC.

HHS Resources for Successful Adoption of Certified EHR Technology

With certified EHR technologies now available, eligible health care providers can tap into the other resources HHS has developed to help them adopt and meaningfully use certified EHR technology.

Those resources include:

  1. Regional Extension Centers to provide on-the-ground technical assistance across the country
  2. The Health IT Workforce Development Program to prepare skilled workers for new jobs in health IT
  3. The Beacon Communities Program to highlight best practices
  4. The Medicare and Medicaid EHR Incentive Programs website. This CMS website contains educational resources and fact sheets with complete program information to help eligible providers adopt and demonstrate meaningful use and receive incentive payments.

These programs support certification policies and processes, all with the ultimate goal of improving the nation’s health through the use of EHR technology and other health information technology.

Re-Cap of ONC EHR Certification Policies and Programs

June to August

ONC established the Temporary Certification Program to authorize organizations to test and certify EHR technology and to establish the processes used for that purpose.

ONC published the Standards and Certification Criteria Final Rule. This rule outlined the capabilities EHR technologies must include to support achievement of meaningful use Stage 1 under the Medicare and Medicaid EHR Incentive Programs.

September

The first ONC Authorized Testing and Certification Bodies were named under the Temporary Certification Program and began testing and certifying EHR technologies based on criteria outlined in the Standards and Certification Criteria Final Rule.

October

ONC published the current Version 1.0 of the Certified Health IT Product List, which lists the EHR products that have been tested and certified under the Temporary Certification Program to the certification criteria adopted by the Secretary and that have been reported to and validated by ONC. In some cases EHR products will have been tested and certified to all applicable adopted certification criteria necessary to meet the definition of certified EHR technology (i.e., those designated Complete EHRs); in other cases they will have been tested and certified to a subset of all of the applicable adopted certification criteria (i.e., those designated EHR Modules), which do not on their own meet the regulatory definition of certified EHR technology.

Version 2.0 of the Certified Health IT Product List is under development and will be available in early 2011. It will provide both additional information, such as a list of the Clinical Quality Measures to which a given product was tested; as well as additional functionality, such as different ways to query and sort the data for viewing. It is also Version 2.0 of the CHPL that will be able to provide the number for reporting to CMS as described above.

As we move forward, we welcome your comments about our efforts and your experiences with implementing health IT.

10 Comments

  1. Dear Carol and Staff: I am writing on behalf of myself and the Clinical Groupware Collaborative, and industry group that is pro-competition and supportive of modular, plug-and-play solutions for EHR technology. I am also writing on behalf of the AAFP, whose members practice in small and medium size medical practices for the most part.

    We would like to recommend that the CHPL table and database record additional information that makes explicit the difference between EHR technology products that are modular, and pass their components, and those that are complete, and fail one of more of the component tests. In other words, it would be helpful for the market to know the intention of the vendor that approaches testing and certification.

    We would also like to recommend that the CHPL note the date of attempted but failed certification for any component of the testing, and when re-testing is done and passed.

    You’re doing great work, and I know this is a work-in-progress.

    Kind regards, DCK

  2. Brian Ahier says:

    I’m not so sure that taking a modular approach to achieving meaningful use is going to work with the latest guidance from ONC. It seems that they are taking a back door approach towards reinstating the all or nothing requirements that were scaled back from the proposed rule to the final rule.

    ONC posted on its website an FAQ stating that hospitals must have EHRs that have been certified against all 24 objectives of meaningful use, not just the 19 they plan to use to demonstrate meaningful use. This means that hospitals will need to purchase and implement technology beyond that required to comply with the meaningful use requirements, delaying many hospitals’ efforts to become meaningful users.

    The ONC FAQ takes away the flexibility to defer objectives and requires hospitals and physicians to have in place EHRs certified against all 24 objectives of meaningful use. http://healthit.hhs.gov/portal/server.pt/community/onc_regulations_faqs/3163/faq_17/20779
    It reads:

    Question [9-10-017-1]:

    Under the Medicare and Medicaid EHR Incentive Programs Final Rule, eligible health care providers are permitted to defer certain meaningful use objectives and measures and still receive an EHR incentive payment. However, it is our understanding that in order for us to have our EHR technology certified, we must implement all of the applicable capabilities specified in the adopted certification criteria regardless of whether we intend to use all of those capabilities to qualify for our EHR incentive payment. Is our understanding correct?

    ONC Answer:

    Yes, this understanding is correct. The flexibility offered as part of the Medicare and Medicaid EHR Incentive Programs Final Rule is not mirrored in the Initial Set of Standards, Implementation Specifications, and Certification Criteria Final Rule because we believe that it is important to accommodate eligible health care.
    ___________________________

    So, to qualify for the incentive payments, hospitals must have an EHR certified against all 24 objectives of meaningful use, while demonstrating meaningful use against only 19 objectives. Thus, they will need to buy now technology that CMS does not require them to use until later, and which may need to be replaced or upgraded when new certification criteria are adopted for later stages of meaningful use. As an example we will need to purchase or upgrade to the technology to support reporting of biosurveillance and immunization data to public health departments directly from the EHR, even if the public health departments in our state are not capable of receiving the data in the standardized electronic formats required by ONC and CMS. This guidance has seriously muddied the water towards using modular EHR solutions…

  3. Brian Ahier says:

    My comment inadvertently seems to be cut short on the full ONC answer from the FAQ. The answer in its entirety reads:

    “Yes, this understanding is correct. The flexibility offered as part of the Medicare and Medicaid EHR Incentive Programs Final Rule is not mirrored in the Initial Set of Standards, Implementation Specifications, and Certification Criteria Final Rule because we believe that it is important to accommodate eligible health care providers’ ability to achieve meaningful use. We recognize that in some circumstances an eligible health care provider may not know which meaningful use measures they will seek to defer until they begin implementation and in others an individual provider (even within a specialty) will want to choose different measures to defer based on their local situation and implementation experience. Thus, in order to possess EHR technology that meets the definition of Certified EHR Technology, it must be tested and certified by an ONC-ATCB to all applicable certification criteria adopted by the Secretary.”

  4. Can anyone comment on these (to me, confusing) statements, from another site?

    “In a recent discussion about certification by the HITECH Policy Committee, it was explained that if you have a ONCHIT-certified clinical data warehouse and use it to generate quality and MU performance measures, if a non-certified system accesses the warehouse and/or places data into the warehouse, the warehouse could be deemed non-certified. I call it ‘contamination through association’….

    “For example, if a device such as an IV pump, drug dispensing cabinet, or digital imaging equipment is considered ‘smart’ (that is, receiving and communicating patient information and communicating the data over the core hospital infrastructure), then if the device is not ONCHIT-certified, it could be deemed as a potential ‘contaminator’, thereby rendering the entire EMR as non-compliant and not eligible for MU. “

  5. Mike Regan says:

    One very important part of the the “Meaningful Use” process that gets overlooked is the requirement for a Risk Assessment. Many folks focus on having a certified EMR system thinking that is all that they need to receive the incentive payments. The Risk Assessment is a critical part of the process and many EMR vendors have not explianed to their clients the need for performing a Risk Assessment. The is a great deal of confusion on whether the EMR vendor will provide the necessary tools for conducting the Risk Assessment. Most will not. Many, in their marketing literature, indicate that their product is/will be certified for meaningful use while ignoring this key component. Buyer beware.

  6. Carol and all,

    I see ONC as inadvertantly sending mixed messages to the marketplace.

    On the one hand, in the Standards IFR released 12/09, ONC clearly understood and expressed the value and need of moving toward modular, plug-and-play EHR platforms and apps.

    On the other hand, as Brian and others have pointed out, some of the regs work against this evolution. Another example is the pressure put on RECs to get up and running; RECs are encouraged to develop preferred vendor relationships, which has the result of locking in existing technologies and locking out more innovative challengers.

    My read here is that this is a left hand/right coordination problem. IMHO ONC has defined it’s mission primarily through the lenses of technology development. This isn’t a criticism…just an observation about a process that has been pressured to get moving rapidly…and overall ONC has done a great job to-date.

    Encouraging the development of modular, plug-and-play platform/apps technologies will require another lens — the lens of MARKET development and business model enablement.

    I suggest that ONC consider creating a committee with this end in mind: Enablement of a Market for Modular, Plug-and-Play EHR Platforms and Applications. fyi, I’m also writing as a Board Member of the Clinical Groupware Collaborative http://www.clinicalgroupwarecollaborative.com, and we’d be pleased to assist in any way possible.

  7. Craig Law says:

    My comment is very similar to the above but I see it from a slightly different perspective. Our medical groups as potential meaningful users have several platforms in use that are now certified, but wait…there is more. The vendors certifed the platform while using web portals as supportive technologies during the certification process. Now, the vendors perspective is that groups MUST use (according to what ONC told them) ALL technologies they used in certification or they are not using certified technologies and not eligible for meaningful use. Not surprisingly the vendors are placing an extremely high price on these add-on technologies for which in our particular evironment (FQHC as an example) have very little applicable use.

    We conceivably could spend $10,000 a month or more on a portal that will not get used (<10% of our surveyed patients even have regular internet access, let alone understand portal technology for secure communications) and the functionality could easily be exchanged by a secure email system costing a tiny fraction of this (but of course may not be certified) or use of any number of other technologies.

    Please guide us that this is not the vendors guarenteed profit margin act but is focused on improving care in ways that make sense for our individual patient populations needs and is supportive of using different approaches to achieve the same end.

    • Brian Ahier says:

      Craig, you bring up an excellent point. I am wondering how we will be able to use non-certified Direct Project standards to attest to the exchange requirements for meaningful use and avoid being held hostage to the vendors for these expensive add on technologies…

  8. I share Craig Law’s perspective below. It is one thing to regulate what physicians use in their practice and quite another to demand that physicians enforce these regulations on their patients. The assumption that most patients out there are computer savvy and have the same health literacy levels as the highly visible e-patients is a fallacy. The populations served by FQHCs, RHCs, CAH and providers in other underserved settings were not represented by those who had input in defining the current regulations and neither were the physicians who serve them. There should be exemptions available for doctors in rural areas and other underserved settings. Which brings us to Brian’s point.

    Perhaps ONC did not anticipate that EHR vendors will be charging additional fees for modules and functionality outside the bare bones core product. Some are not. Most do and always did. Patient Portals are a perfect example, but CQM reporting, e-Prescribing and every single interface whether required to be functional or just “tested for capability” is an additional, and significant, cost to providers. Testing an interface for capability should be a vendor certification requirement, but not a provider’s Meaningful Use criterion. That way vendors are forced to develop capabilities and providers are not mandated to pay for something that will not be used in Stage 1.

    A good solution would be to exempt providers from paying for services included in the Complete EHR certification package, but charged separately by the vendor, if the provider purchases an alternative certified service. For example, a provider who signs up for the new Surescripts services should not be forced to also pay the EHR vendor for the CCR/CCD interface certified by the vendor. If a secure email module certifies, and the provider purchases and uses this secure email product in lieu of a Patient Portal, the provider should not be forced to pay for the Portal.

    I don’t know about the wisdom of ONC encouraging one software paradigm over another and I have to admit that the most recent outstanding innovations I’ve seen came from extremely large and “old” vendors (if you haven’t seen Cerner’s M-Pages and cloud based Google-like search, you should take a look (I have no affiliation with Cerner)). I’m sure there are equally innovative modular applications out there, such as Surescripts’ new connectivity platform. In any case, in a free market if you have a compelling product, you will be successful without government intervention. The RECs are operating within the market. Some pick “older” vendors, others pick newer vendors and a significant number pick nothing at all, and ultimately all RECs must support whatever the physicians choose to purchase.

    Regarding RECs, since it is probably to late for ONC to change the requirements for Stage 1, if you are reading this and are working with a REC, try to negotiate with your selected vendors that there will be no extra charges for any additional Meaningful Use modules, particularly those “capability” interfaces that require only one test.

  9. We would like to recommend that the CHPL table and database record additional information that makes explicit the difference between EHR technology products that are modular, and pass their components, and those that are complete, and fail one of more of the component tests. In other words, it would be helpful for the market to know the intention of the vendor that approaches testing and certification.

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