What to Do if You Have a Question about Your Certified EHR
Carol Bean and Jacob Reider, M.D. | May 25, 2012
The ONC Certification Program staff receives comments and questions by phone and email that are related to the adoption, use, and implementation of certified EHR, as well as questions related to CMS’ Medicare and Medicaid EHR Incentive Programs. The standards and certification criteria are intended to ensure that certified health information technology (health IT) products perform required functions that support better health and health care for patients. Many of the comments we receive come to us as complaints that a certified EHR product is not performing all of the functions that were required for certification. Other types of complaints, however, call for different response processes. With this blog, we hope to provide a bit more information on how best to share the particular question or concern you have about your certified EHR.
Certification-Related Complaints about Your Certified EHR
The first step in the ONC Certification Program procedure for processing complaints related to certified EHR product functionality is for the public to share details of the complaint with ONC at ONC.Certification@hhs.gov. ONC then forwards these queries for investigation to the ONC-Authorized Testing and Certification Body (ONC-ATCB) that tested and certified the product under the authority granted by ONC. The ONC-ATCB then works with the certified EHR product’s vendor to determine whether the product has the functionality to meet the criteria of concern. If the answer is yes, the person who asked the initial question about a particular function is informed. If the answer is no, the product would need to undergo the EHR technology testing and certification process for that functionality again. This step allows ONC to ensure that the certified EHR products on the Certified Health IT Product List (CHPL) remain in compliance with EHR certification requirements.
What to Do for Other Types of Complaints about Your Certified EHR
We have found that many of the questions we receive about particular health IT certified products, however, are not really related to what these products are required to do in order to meet EHR standards and certification criteria. Examples of these non-certification-related issues include questions related to: pricing, installation, versioning, application use, customer relations, service issues, contracts and agreements, and integration into existing workflows. For these types of concerns about your certified EHR, you should reach out directly to the EHR vendor(s) involved. In addition, we encourage you to get involved by participating in the Federal Advisory Committee Act (FACA) workgroups. The FACA process is also, obviously, the place to share concerns related to EHR standards and certification criteria themselves.
Beyond that, for questions or concerns about Meaningful Use requirements and measures, attestation, or reporting, you should contact the Centers for Medicare & Medicaid Services.
ONC is eager to do everything we can to be responsive to public complaints about EHR certification requirements. Please continue to share with us your certified EHR questions and concerns related to certification requirements at ONC.Certification@hhs.gov. For certified EHR concerns about other issues, we encourage you to participate in the FACA process where public input is invited at every meeting. And, of course, ONC is always interested to hear from you about your experience in making the transition to EHRs, so please feel free to contact us.