CMS Announces "Meaningful Use" Rules

Does that mean it's time to buy an EHR? Maybe not.But what about CCHIT certification?
If you've been thinking about moving to an electronicMany EHRs currently carry a certification from the
health records (EHR) system, in hope of the federalCertification Commission for Health Information
government subsidizing the cost, you might be led toTechnology (CCHIT), a non-profit organization that has
believe the time to act is now. After all, the promise ofdone much to develop standards for EHR software.
$44,000 per physician from Medicare (or up to $63,750The CCHIT certification carried by an EHR is
under Medicaid) is pretty alluring. Getting that money,associated with a specific year to convey which set
however, is not automatic, and not every EHR mayof standards (each year the criteria changes) that the
qualify. In fact, as of right now, no EHR qualifies for theEHR software meets. While useful, that certification is
reimbursement. Not even one.not the "official" certification your EHR needs. Most
Shocked? It's the little secret that vendors aren'tlikely, CCHIT will become a certifying body, and more
touting.organizations are expected. But for now, a CCHIT
To be fair, it's not the vendors' fault. And with all thecertification doesn't get you the $44,000 per physician
news this week about "meaningful use," you might thinkin your practice.
that everything is settled. Well, it isn't, and I'll try toThe bottom line is: If your EHR isn't certified-and none
explain why.are at this time-then you cannot qualify for the federal
In July, the Centers for Medicare & Medicaid Servicesdollars.
(CMS) posted its final rule on "meaningful use"What should you do? If you don't have an EHR in
requirements that physicians must meet with their EHRplace, wait. At least until all the certification hullabaloo is
to participate in the Medicare or Medicaid incentiveresolved. That may take a few months, because after
plans. So far, there are no big surprises, thoughthe certification criteria is completely defined, the EHR
everyone is still digesting the massive 864-pagevendors will most likely need to tweak and enhance
document.their products with the necessary features, and then
Essentially, the document spells out the minimumdebug the software. To commit to an EHR before it is
amount of activities you must perform with your EHRcertified is to place an enormous amount of faith-and
to be considered as having used it in a, well, meaningfulthe success of your practice, not to mention the
way. It includes such things as e-prescribing 40 percent$44,000 per physician-in the company that makes it.
of the time, maintaining vitals, recording smoking status,Sure, each company intends to have its EHR product
providing patients who ask for it with electronic copiescertified, but how long will that take? In the world of
of their health information, and much, much more.software, that's like asking how long is a piece of
While "meaningful use" might seem enough to qualifystring. And you really don't want to use any software
for the federal money, the EHR software itself mustthat was updated under the pressure of short
also be "certified." The problem is that the certifyingdeadlines until it has been adequately tested and
bodies-the organizations that will eventually certify thedebugged. Otherwise, your practice becomes a test
EHR software-have not even been named yet. Evenlab for uncovering those bugs.
worse, the process for certification was issued byIf you can't wait, at least get a written guarantee-with
DHHS only on June 18, 2010. The industry is still waitingcash penalties-from the vendor that it will take
for the Department of Health and Human Serviceswhatever steps are necessary to get its EHR product
(DHHS) to issue the specific criteria that EHRs mustcertified in time for you to qualify for the full $44,000
meet to become certified.per physician Medicare incentive. However, if
Meanwhile, each potential certification body mustcertification doesn't occur until, say, late in 2012, you
become an official "Authorized Testing Andwon't be eligible for the full incentive amount.
Certification Body" (ATCB) as deemed by the OfficeIf you already have an EHR in place, you should also
of the National Coordinator (ONC) for Health andwait, and make no further commitments to upgrades
Information Technology, or an ONC-ATCB. Only anuntil the new version of your EHR has been certified.
ONC-ATCB can deem an EHR software certified forYou might also want to seek a written guarantee from
the CMS incentive programs.the vendor. Just be aware that at some point, you
In other words, no one currently has the authority tocould face the dilemma of either choosing another
certify EHS software and the testing criteria forEHR or keeping what you have and forgoing the
certification does not exist yet.$44,000 per physician.