Seeking Your Feedback: Voluntary EHR Certification for Behavioral Health and Long-Term and Post-Acute Care Settings

Larry Wolf | May 14, 2014

The Health Information Technology Policy Committee (HITPC) has been asked by the Office of the National Coordinator for Health Information Technology (ONC) to explore the health information technology (health IT) needs of the long-term and post-acute care (LTPAC) and behavioral health (BH) settings.  In most cases, providers in these settings are not eligible to receive funding from the Medicare & Medicaid EHR Incentive (Meaningful Use) Programs.

The Certification and Adoption Workgroup is leading this charge on behalf of the HITPC and has developed a draft set of voluntary certification criteria focused on interoperability, privacy and security, and modularity that will improve providers’ access to the functionality they need from their electronic health records (EHRs).

Your Feedback is Requested!

The Workgroup is seeking public comment on the proposed voluntary certification criteria in two ways:

  1. For this listening session, we are asking that participants interested in testifying on Thursday, May 22nd sign up in advance to share their feedback. As always, the public can listen and participate in this session online.
  2. Respond to this blog by 11:59pm on May 22nd using this public comment template to be emailed to  Note: The proposed recommendations are included in the public comment template.

Many of the voluntary certification criteria align with the ONC 2014 Edition Standards and Certification Criteria Final Rule. A detailed reference document to the ONC 2014 Edition Standards and Certification Criteria is also provided.


Through a series of meetings— including two hearings featuring more than 40 testifiers, and presentations by a myriad of experts— we have immersed ourselves in understanding the health IT challenges and needs of LTPAC and BH.  For example, experts noted in 2007, 43 percent of home health agencies and hospices adopted uncertified EHRs. External Links Disclaimer  In 2004, the same percentage (43 percent) of nursing homes reported they adopted EHRs External Links Disclaimer and systems varied wildly and were generally not interoperable.  A more recent report from 2012 found that community mental health centers had an EHR adoption rate of 21 percent External Links Disclaimer.

Though these settings have different needs, there are many characteristics that are shared by LTPAC and BH providers.  For both settings, stakeholders have shared their frustration regarding the lack of reliable, interoperable systems.  Stakeholders also shared their thoughts on how to ensure that a voluntary certification initiative does not stifle innovation, is useful to both the patient and the provider, and is right-sized to provide needed functionality while keeping costs down.

How the Voluntary EHR Certification Criteria are Grouped

The certification criteria are divided into three categories— All Providers, LTPAC/BH Setting Specific, and Some Providers.  The All Providers category refers to certification criteria the workgroup has identified as being applicable to all provider types (e.g., hospitals, primary care, specialists, LTPAC and BH), the LTPAC /BH Setting Specific category refers to criteria relevant to named care settings, and the Some Providers category references criteria that may be relevant to LTPAC or BH providers depending on the scope and needs of the practice.

Organizing Principles for Recommendations
 For ALL Providers

  • Transition of Care
  • Privacy and Security
  • Data Segmentation/Consent Management
 LTPAC Setting-Specific

  • Patient Assessment
  • Survey and Certification

BH Setting-Specific

  • Patient Assessments
  • Data Segmentation/Consent Management
 For some LTPAC and BH Providers

  • Clinical Reconciliation
  • Clinical Health Information
  • Labs/Imaging
  • Medication-related
  • CPOE
  • Clinical Decision Support
  • Quality Measures
  • Patient Engagement
  • Advanced Care Planning
  • Data Portability
  • Public Health – Transmission to Immunization Registries


We offer the following questions to encourage discussion, but we invite comment on any issue related to this topic.

Overall Approach

  • Do the proposed certification criteria appropriately address the needs of LTPAC/BH settings?  Is there additional EHR functionality missing from our proposals that should be considered?
  • The Workgroup is considering whether to recommend that any LTPAC/BH voluntary certification program be organized as modules (e.g., transitions of care module, labs module, etc).  Would the modular format be helpful in addressing the specific needs of LTPAC/BH providers?
    • Are the standards associated with the proposed certification criteria mature enough for adoption?

Level of Effort

  • What level of effort would be needed for providers to implement and maintain the proposed certification criteria?
  • What level of effort would be needed for vendors to develop the proposed certification criteria?

We look forward to your insight, input and feedback. And remember, if you can’t make the listening session, provide your comments using the public comment template.