Does EHR certification by the government mean anything? It does if you want to qualify for a number of incentive programs. Any reputable EHR vendor knows that such incentives can have a huge impact on revenue for eligible hospitals, critical access hospitals, and eligible professionals who want to participate in CMS EHR incentive programs.
Is such participation mandatory? No, but if your EHR system doesn't meet criteria of the Final Rule (which encompass Modified Stage 2 from 2015 through 2017, and Stage 3 in 2018, you won't be eligible for those incentives.
Each category comes with a variety of different objectives and measures. Providers are required by CMS to be able to attest to a specific set of measures and objectives. Eligible hospitals and critical access hospitals have nine objectives, while eligible professionals have 10. For example, guidelines and regulations for eligible professionals must be able to attest:
• Protection of electronic health information.
• Utilization of clinical decision support processes to improve quality of care.
• Use of computerized provider order entries for labs, radiology, and medication orders that meet local, state as well as professional guidelines. This measure also applies to the capabilities of e-prescribing.
• Interoperability in regard to health information exchange.
• Ability to identify education resources for patient-specific needs.
• Medication reconciliation between care settings and providers.
• Patient accessibility to their health information within four business days following availability of their information to an eligible provider.
• Utilization of secure electronic messaging.
• Active participation with public health reporting.
Each of these objectives for eligible providers also comes with specific instructions, guidelines, and objectives. For example, EHR incentive program objectives and measures for 2016 in regard to protecting patient health information provides guidelines in regard to attestation requirements, regulatory references, and criteria for certifications.
Why so important? Due to the transition to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which will determine payment formulas for physicians and healthcare providers, yes, certification of EHR systems by the government can have a huge impact on how Medicare pays health-care providers offering healthcare and medical services to Medicare beneficiaries. The transition will also serve to assess quality of care and utilization of information technology by physicians.
What about MACRA?
Because of the transition from Meaningful Use to MACRA and the need to follow new guidelines, most doctors providing Medicare services will need to show "success" in advancing care information, quality, cost, and clinical practice improvement. For example, under the advancing care information category, physicians should be able to report measures (customizable) that reflect their use of health IT in their daily practices with focus on information exchange and interoperability.
So far, MACRA changes will typically only impact Medicare payments made to physician practices and not Medicaid programs or Medicare hospitals, but that doesn't mean things will not change in the future.
Earlier focuses on EHR incentive programs have been focused on encouraging physicians to transition from paper to EHR systems in order to qualify for incentive programs that take advantage of increasing digital technologies.
EHR software and technologies will be fairly essential for MACRA in its ability to reward providers. This has also encouraged EHR developers to provide flexibility and customization of health IT systems, help physicians (regardless of care scenario) to improve patient outcomes, and increase access to electronic health information through API through the use of plug-ins, apps and analytic tools to provide quality patient care. Focus is on interoperability - a priority achieved by the implementation of government recognized national interoperability standards. MACRA will have an impact on payment incentives that are associated with incentives regarding EHR use, but it will not eliminate those incentives.
With the transition, hospital (Medicaid and Medicare) EHR incentive programs will have a slightly different set of requirements.
ONC Health IT certification process
What exactly is involved in the certification process as defined by the Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program (which as of now is a voluntary certification program designed for health IT standards, implementation specifications and certification criteria)? Today, that includes:
• Regulations - the ONC issues regulations that can include but are not limited to certification and associated standard criteria for health IT modules as well as corresponding certification program requirements.
• Standards for developers in the creation of modules that adhere to standards as well as certification criteria developed by Health and Human Services (HHS) regulations.
• Test laboratories must also be based on the above mentioned standards and certification criteria provided by HHS.
• Certification bodies tested by ATLs (Accredited Testing Laboratories) and product information will be submitted to the ONC and displayed on a certified health IT products listing.
• Providers and hospitals will be certified under Health IT modules in their ability to share information for high-quality delivery of care as well as use of those modules in accordance with the Health and Human Services quality improvement program requirements; those include measures and objectives of Meaningful Use and EHR incentive programs.
Bottom line
The ongoing transition from Meaningful Use to implementation of MACRA will soon be mandating not only use of, but also functionality of certified EHR products and technologies.
MACRA will replace the Sustainable Growth Rate formula methodology with the Merit-based Incentive Payment System (MIPS) for eligible professionals and also provide incentive payments for eligible professionals opting for the Alternative Payment Models (APMs). Such goals will be achieved through use of certified EHR technology (CEHRT) required by MACRA. The use of certified health IT is referenced to meet definitions of CEHRT under MACRA as well as EHR incentive programs.
Improving government strategies to help mitigate burdens on healthcare providers when developing guidelines for EHR incentives should also be taken into consideration when developing, testing, and providing certification guidelines to individual practices as well as hospitals.
So yes, EHR certification by the government does mean something. It's no secret that the government has long been involved in the adoption of, regulation of, and development of new guidelines and regulations as health care technologies have advanced. Nevertheless, greater support from not only private sector, but federal government agencies to provide consistent and ongoing support in regard to implementation both new and comprehensive strategies for the efficient and safe utilization of certified health care IT products is needed.
Author Bio:
Alex Tate is a health IT fanatic who is passionate about technology and its revolutionary impact on the healthcare industry. He adds value to the healthcare community by providing answers to problems faced by the providers. He is always hunting hot topics and opportunities that will open new dimensions in the field of Health IT. He can be contacted at alex.tate@curemd.com.
The views, opinions and positions expressed within these guest posts are those of the author alone and do not represent those of Becker's Hospital Review/Becker's Healthcare. The accuracy, completeness and validity of any statements made within this article are not guaranteed. We accept no liability for any errors, omissions or representations. The copyright of this content belongs to the author and any liability with regards to infringement of intellectual property rights remains with them.