Status of Meaningful Use and the HiTECH Certification Program

Summary

As most of you know, the money authorized by the stimulus plan (ARRA) for funding of physicians for using an approved Electronic Healthcare Record (EHR) has been pending for over a year awaiting a definition of Meaningful Use and determination of the rules for certification of approved EHRs. Those definitions are now finalized and CodoniX will be certified by one of the industry leaders in testing and certification. This organization expects to be one of the first groups to become an authorized testing and certification body.

The whole process of Meaningful Use and Certification has been lengthy and complicated. To full understand what has occurred in the past and what will happen in the coming months, you need to know a few important acronyms (remember this is the government)

ARRA = American Recovery and Reinvestment Act-official name of the stimulus plan
HHS = Department of Health and Human Services
ONC = Office of the National Coordinator for Health Information Technology
ONC-ATCB = (ONC-Authorized Testing and Certification Body) these are the only groups that can certify an EHR
HITECH = Health Information Technology for Economic and Clinical Health.
CCHIT = Certification Commission for Health Information Technology-an industry certification group that has no standing for certifying EHRs for ARRA funding.

CodoniX has been following the new HITECH meaningful use guidelines very closely and feel that it is important that everyone in the CodoniX community becomes aware of the latest rules and regulations. Very briefly the following facts currently shape the certification landscape:
• As of Aug 9, 2010 no group has become an ONC-ATCB (ONC-Authorized Testing and Certification Body) – it is estimated that by the end of the summer there will probably be 2 groups (Drummond and CCHIT) that will have become authorized testers.
• As of Aug 9, 2010 since there are no ONC-ATCBs, no vendor has a HITECH certified product and none have been tested.
• Prior certification by CCHIT in any form, for any date range, does nothing towards HITECH certification – every EHR must get certified by the new criteria
For those that don’t like to get bogged down in the further details, I want to assure all of our clients that we intend to get certified as soon as ONC-ATCBs accept applications. If you would like to have more information please continue reading.

 

Detailed overview of Certification Process and Meaningful Use:

The last 6 months have been very interesting to follow as the certification guidelines became defined. On January 13, 2010 the ONC released preliminary rules for EHR certification that went on for 206 pages. We at CodoniX actually were very excited, because they were quite complex, and required a very sophisticated solution to meet a number of the proposed criteria. Many of our competitors have relatively weak documentation modules that rely on free text, voice recognition and other modalities that make clinical reporting of discrete data virtually impossible.

From January to June the rules were subject to public comment and lobbying efforts. The one group that fared most poorly was CCHIT which prior to this had a monopoly on certification and testing of EHRs. Dr. Blumenthal the head of ONC made it very clear that they expected to have multiple certifying bodies and that the certifying scenarios and testing procedures would not be determined by the testing bodies. The actual testing scenarios and protocols were assigned to NIST (National Institute of Standards and Technology) which was another blow to CCHIT since in the past they had been both the tester and test creator. In the first Quarter of 2010 CCHIT was touting “pre-certification” and implying that this would lead to HITECH fast tracking if not out right certification. At the end of April CCHIT abruptly stopped this and explicitly stated that the HITECH rules were likely to be different.

On June 13, 2010 the head of HHS released the rules that governed who could become an ONC-ATCB. At the moment it appears that The Drummond Group and CCHIT are very likely to get concurrent approvals and ONC predicts at least one or two more participants, however at this time it is unclear who they might be. Because CCHIT has given a lot of prior certifications which are now of marginal value, we believe that it is probable that these CCHIT certified providers (who paid a minimum of $40K but almost always significantly more) will probably be jockeying for special treatment if nothing else to be at the head of the line. It is also important to note that although it is ‘semi-independent’ – CCHIT was established by HIMSS (am industry sponsored group) and has had very significant funding from many of the major HIS vendors (GE, Cerner, EPIC, Next Gen, etc.) In addition, a number of these vendors either sit on the board or participate in key committees.

Because of this we have identified the Drummond Group as our preferred tester. They have a long history of industry wide testing and certification. At the moment they are not taking applications from vendors for certification until they become an ONC-ATCB (see http://www.drummondgroup.com/blog/ehr-temporary-certification-faq/ for more information.)

As of June of this year the final meaningful use rules were undefined and the rules for becoming a certifying body were just released. On July 13, 2010 the final rules for meaningful use were finally released and initially published in the influential New England Journal of Medicine.

It is important to understand fully what these rules mean and what type of re-imbursement can be expected. First the rules themselves have actually been simplified from the original proposal in January of this year. To qualify for reimbursement through the HITECH act, users must use an ONC-ATCB certified EHR. However, it is critical to note that this is just the first step. The most important step is to prove that the physician user makes “MEANINGFUL USE” of their EHR. In other words they must prove that they are using the application for most of their patients and that they are using multiple parts of the application. I have attached the rules below, but it is important to note that all current CodoniX users are already using more than is required.

The second important issue to consider is that to be reimbursed a user must have used the HER for at least 90 days in the calendar year of payment. Although $44K is widely quoted that is a cumulative number over several years. The current maximum payment for 2011 is $18K/physician and our goal is to make sure that all of our users qualify. This raises the interesting question of how many users at a site will qualify. Obviously part timers that work only occasionally will not count, but we have been unable to find out the definition of a physician user. We will pass along this information when it becomes available.

Below is a listing of the meaningful use guidelines; it consists of a Core set of Requirements and then a menu of options and each EHR must pick 5 options from this later menu.


 

 

CodoniX is now certified by Surescripts, which means that we now have the ability to offer full e-Prescribing through the only recognized certification body.  With this important function finalized we believe that we currently already meet all of these criteria.