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Due Diligence on Meaningful Use of EHR

As you do due diligence on what it means to achieve meaningful use of health IT, these additional resources may be helpful.

Official Info on EHR Certification and Meaningful Use

Final Rule for Permanent EHR Certification Program

In June of last year the Office of the National Coordinator for Health Information Technology in the Department of Health and Human Services established a temporary health IT certification standard (see below) in order to get the certification process rolling. In January of this year ONCHIT issued a final rule for a permanent health IT certification program.

According to Joe Goedert at Health Data Management, "Under the final rule, ONC will select one organization, called the ONC-Approved Accreditor or ONC-AA, which will accredit entities wishing to become a health I.T. certification body. The final rule details ONC's competitive process for selecting the ANC-AA. The chosen organization will serve a three-year term and can be reselected following another competitive selection process."

• Click on Certification Program to access the ONCHIT certification Web page.
  
• Click on Fact Sheet to read the ONCHIT's overview document on the final rule.
• Click on Final Rule to access the document in its entirety (pdf).
  

'Final' Meaningful Use Requirements

On July 13, 2010, the US Department of Health and Human Service's Office of the National Coordinator for Health IT released the final "meaningful use" requirements that "eligible professionals (EPs), eligible hospitals and critical access hospitals (CAHs)" participating in Medicare and Medicaid must meet to quality for federal stimulus funding. After reviewing some 2000 responses to the preliminary rules released last spring, the ONC opted for flexibility and inclusion, softening the initial standards to enable more hospitals to reasonably qualify for ARRA incentives and reap the benefits of comprehensive health IT.

Click on Final Meaningful Use Rules to access the full ONC document. For the "Cliff's Notes" versions, try these:

• Click on Healthcare IT News/Meaningful use objectives for a media summary.
• Click on "'Meaningful Use' Regulation for Electronic Health Records" for an official summary by National Coordinator for Health IT David Blumenthal, MD, in the July 13, 2010, New England Journal of Medicine. (Marilyn Tavenner, RN, principal deputy administrator of the Centers for Medicare and Medicaid Services, co-authored.)

The ONC and Temporary Health IT Certification

In lieu of permanent standards and definitions, the federal government has created temporary certification criteria to determine which health IT systems meet the standards necessary to bring hospitals and physician offices into compliance with ARRA's "meaningful use" requirements:

• Click on Certification Standards to access extensive information on the federal governments initial certification criteria.
• Click on Certification FAQs to access federal "Standards and Certifications Criteria Final Rule: Frequently Asked Questions."
  

Certification of Open-source Health IT

Click on Open Source Certification for proposed HHS/ONC rules pertinent to certification of open-source health IT products—excerpted from "Proposed Establishment of Certification Programs for Health Information Technology; Proposed Rule," Federal Register, March 10, 2010.

ARRA

Click on Title IV of the American Recovery and Reinvestment Act for information on health IT incentives available under ARRA.

Proposed Establishment of Certification Programs for Health Information Technology: Facts-At-A-Glance

(As of March 2, 2010)

• Section 3001(c)(5) of the Public Health Service Act (PHSA) as added by the Health Information Technology for Economic and Clinical Health (HITECH) Act, requires the National Coordinator, in consultation with the Director of the National Institute of Standards and Technology, to keep or recognize a program or programs for the voluntary certification of health information technology (health IT)as being in compliance with applicable certification criteria.
• Certification of EHR Technology will provide assurance to purchasers and other users of health IT that an EHR system offers the necessary technological capability, functionality, and security to meet meaningful use criteria.
• Under this authority the Office of the National Coordinator for Health Information Technology (ONC) has issued a Notice of Proposed Rulemaking (NPRM) proposing the establishment of two certification programs for the purposes of testing and certifying health IT, one temporary and one permanent.
• As required by statute, ONC has consulted with NIST on all aspects of developing the proposed certification programs, and will continue to consult and collaborate with NIST during the implementation and operational phases of both temporary and certification programs. NIST is developing a test method and infrastructure that will be used by testing laboratories in the testing component of both certification programs.
• Certified EHR technology is a requirement for providers to receive incentive payments for the adoption and meaningful use of EHRs under the Medicare & Medicaid Incentives Program. The development of these programs is also authorized by the HITECH Act and a separate proposed regulation has been published that outlines provisions governing the program.
• An initial set of standards, implementation specifications, and certification criteria for Complete EHRs and EHR Modules was also published in a related Interim Final Rule.
  
• The first proposal within the NPRM would establish a temporary certification program whereby the National Coordinator would authorize organizations to test and certify Complete EHRs and/or EHR Modules, thereby assuring the availability of Certified EHR Technology prior to the reporting period in which health care providers may seek the incentive payments available under the Medicare and Medicaid EHR Incentives Program demonstrating meaningful use of Certified EHR Technology.
• The second proposal within the Certification Programs NPRM would establish a permanent certification program to replace the temporary certification program.  The permanent certification program would separate the responsibilities for performing testing and certification, introduce accreditation requirements, establish requirements for certification bodies authorized by the National Coordinator to related to the surveillance of Certified EHR Technology, and would include the potential for certification bodies authorized by the National Coordinator to certify other types of health besides Complete EHRs and EHR Modules.
• The temporary program would end once the permanent certification program is established and at least one certification body has been authorized by the National Coordinator.The public comment period for the temporary certification program will be open for 30 days after publication. The public comment period for the permanent certification program will be open for 60 days after publication.
• While two certification programs are described in this proposed rule, ONC anticipates issuing separate final rules for each of the programs.
• To inform the rulemaking processes, ONC received recommendations from the HIT Policy Committee (a Federal Advisory Committee), and input from technical subject matter experts, health care providers, and other stakeholders.

Other info on Meaningful Use

AMDIS: Meaningfuluse.org

Click on Meaningfuluse.org to access the Association of Medical Directors of Information Systems' collaborative "Meaningful Use" site, designed to promote national dialogue, and offer access to resources and education related to HITECH stimulus funds.