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ONC Regulation FAQs

#17 Question [09-10-017-3]

As an eligible provider seeking to demonstrate meaningful use of Certified EHR Technology (CEHRT), what options do I have to meet the Certified EHR Technology definition before and after 2014?

Answer:

The CEHRT definition can be found at 45 CFR 170.102 and applies to the calendar year (CY) for eligible professionals (EPs) and the fiscal year (FY) for eligible hospitals (EHs) and critical access hospitals (CAHs).

Before FY/CY 2014 (i.e., for the EHR reporting periods in 2011, 2012, and 2013)

An eligible provider can satisfy the CEHRT definition in any one of the following three ways:

  1. The eligible provider possesses EHR technology certified to all of the mandatory 2011 Edition EHR certification criteria for the applicable setting.
  2. The eligible provider possesses EHR technology certified to all of the mandatory 2011 Edition EHR certification criteria or equivalent 2014 Edition EHR certification criteria for the applicable setting. This option is similar to the first in that providers must possess EHR technology certified to all of the certification criteria for a setting (inpatient or ambulatory), but it can be a mix of technology certified to the 2011 and 2014 Editions of EHR certification criteria. For example, a provider who already has 2011 Edition EHR technology could purchase an EHR Module with CPOE functionality that is certified to the 2014 Edition CPOE certification criterion. Read a crosswalk of equivalent 2014 Edition EHR certification criteria [PDF - 234.4 KB].
  3. The eligible provider possesses EHR technology that meets the CEHRT definition established for FY/CY 2014 and subsequent years at 45 CFR 170.102. By selecting this option, an eligible provider may be able to satisfy the CEHRT definition without necessarily having to possess EHR technology certified as having all of the capabilities as they would in options 1 and 2. Specifically, this means the provider would, at a minimum, only need to have or possess EHR technology certified to the 2014 Edition EHR certification criteria that meets the Base EHR definition and supports the objectives, measures, and their ability to successfully report the clinical quality measures (CQMs), for the meaningful use (MU) stage that they seek to achieve.

For FY/CY 2014 and Subsequent Years

An eligible provider must possess EHR technology that satisfies the CEHRT definition for FY/CY 2014 and subsequent years at 45 CFR 170.102. Again, this means, at a minimum, possessing EHR technology certified to the 2014 Edition EHR certification criteria that meets the Base EHR definition and supports the objectives, measures, and their ability to successfully report the CQMs, for the MU stage that they seek to achieve.

FY/CY 2014 CEHRT Definition Flexibility as it Pertains to Meaningful Use
 

Menu Objectives and Core/Menu Exclusions

For Stages 1 and 2, in cases where the EP, EH, or CAH could defer a menu objective or (in most cases) meet an exclusion for a core or menu objective, the EP, EH, or CAH would not necessarily need to have EHR technology certified that supports the objective and associated measure in order to have EHR technology that satisfies the CEHRT definition.

Provider Responsibility

EPs, EHs, and CAHs will be responsible for ensuring that they have the necessary EHR technology to meet the FY/CY 2014 CEHRT definition. This means that EPs, EHs, and CAHs could run the risk of not having sufficient CEHRT to support their achievement of MU if, for example, they turn out not to be able to exclude a MU objective and measure as anticipated or they end up needing to satisfy a menu objective and measure that they originally expected to defer.

 

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