2014 Edition EHR Certification Includes New Transparency Requirements

Steven Posnack, M.S., M.H.S. | February 11, 2014

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.