CMIO Summit 2011 | Karen Bell

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CMIO Summit 2011 | Karen Bell

  1. 1. Overcoming EHR CertificationHurdles & GapsKaren Bell, MD, MMS – Chair, CCHITCMIO SummitJune 10, 2011 | 1:00 – 2:00 PMOmni Parker House Hotel | Boston, MA
  2. 2. Topics Why Certification? Current Certification Programs EHR Alternative Certification for Healthcare Providers or EACH™ The EACH Process Tips for Providers The Future Q&A © 2011 CCHIT | Slide 2 | June 2011
  3. 3. About CCHIT © 2011 CCHIT | Slide 3 | June 2011
  4. 4. Why EHR Certification? Purchaser (provider and patient) protection -- system has desired features and functions as advertised Security – at least to a minimum set of testable criteria Interoperability – includes standards for  Nomenclature  Messaging  Implementation guidance  Transport Meet specific objectives -- i.e., government defined measures Stimulate innovation – identify floor on which to innovate © 2011 CCHIT | Slide 4 | June 2011
  5. 5. EHR Certification:Providers Find Value Measurement Specialty-Specific Workflow Support beyond Federal MU Functionalities (e.g., ACO) Functionalities Plug-and-Play Data Usability Testing beyond Basic Interchange and Rating Federal Capability Efficient Integration Real-world usage Stronger Security of Functionalities verification Basic Federal Vendor Stability Data Portability Compliance for and Support (future-proofing) Meaningful Use © 2011 CCHIT | Slide 5 | June 2011
  6. 6. Current Certification Programs Provider and patient accountable Multiple settings and specialties, each with its separate program Multi-stakeholder engagement, piloting, and updatingONC-ATCB certified Developer focused (vendor or provider) Eligible provider (ambulatory) and Inpatient settings only Essentially one size fits all Codified in federal regulation © 2011 CCHIT | Slide 6 | June 2011
  7. 7. Two Certification ProgramsNature of certification Voluntary, robust Mandatory for $$$, to minimum government standardsCriteria and Testing Volunteer subject matter experts Federal governmentTool DevelopmentProviders served Many types of providers seeking greater Medicare and Medicaid eligible assurance when investing in new EHRs; providers and hospitals seeking specialty options available incentive paymentsTechnology certified Comprehensive, integrated EHRs + use Broad, flexible array of EHR verification, usability rating and vendor technologies: complete EHR and characteristics EHR modulesAccountable to Providers GovernmentGoals Assurance of functionality, interoperability, Meaningful use (as defined by CMS) security; meet provider needs for to improve outcomes of care, transparency of product support health reform © 2011 CCHIT | Slide 7 | June 2011
  8. 8. Available CCHIT Certified® programs © 2011 CCHIT | Slide 8 | June 2011
  9. 9. CCHIT’sONC-ACTBCertification Program © 2011 CCHIT | Slide 9 | June 2011
  10. 10. Three Steps to the Meaningful UseIncentive Payment Process Step 1: Step 2: Step 3: Adopt certified Achieve Apply EHR technology meaningful use for paymentEHR is certified by an Hospital or Eligible Hospital or EligibleONC-authorized Provider achieves Provider submits datatesting and certification Meaningful Use or reports in a mannerbody against ONC- goals, objectives, and defined by CMS anddeveloped criteria and measures published collects paymentstandards and NIST by CMStest procedures © 2011 CCHIT | Slide 10
  11. 11. Federal definitions ofcertified EHR technology Complete EHR: able to perform, at a minimum, all of the applicable capabilities required by certification criteria adopted by the Secretary, and thereby, as providing eligible professionals or eligible hospitals with the technical capabilities they need to support their achievement of meaningful use of certified EHR technology EHR Module: any service, component, or combination thereof that can meet the requirements of at least one certification criterion adopted by the Secretary Qualified EHR: Either a complete EHR or a collection of modules that are certified to meet every certification critierion © 2011 CCHIT | Slide 11 | June 2011
  12. 12. ONC-ATCB 2011/2012 Hospital Criteria A provider must possess “certified EHR technology” meeting all criteria to qualify for incentives From CCHIT’s Certification Facts™ product listings © 2011 CCHIT | Slide 12 | June 2011
  13. 13. Finding more information about ONCcriteria and test procedures ONC’s website with a link to “Standards and Certification Criteria for Electronic Health Records” NIST’s website with a link to “Approved Test Procedures” © 2011 CCHIT | Slide 13 | June 2011
  14. 14. Lesson Learned: IT’S COMPLICATED!! Provider developers and vendor developers have different missions, business strategies, and objectives for their EHRs Many hospitals (and some physicians) use combinations of the above (best of breed approach) to meet their strategic objectives ONC criteria (modules) may not match clinical workflows A model of obtaining “certified EHR technology” from a vendor fails when:  Health IT is partly or fully self-developed  A product has been significantly customized  A commercial product version is too old to be upgraded  A hospital is in a multi-year product upgrade or conversion  A vendor has chosen not to present an updated EHR for ONC- ATCB 2011/2012 certification © 2011 CCHIT | Slide 14 | June 2011
  15. 15. Where providers can find ONC-ATBCcertification results ONC’s Certified HIT Products List (CHPL) Web Page  All certified Complete EHRs and EHR Modules that meet the definition of Certified EHR Technology (from all ONC-ATCBs)  Providers electing to combine Modules use the CHPL to validate whether the Modules they have selected satisfy all of the applicable certification criteria  Generates ID number required for CMS application CCHIT’s “Find Products” Web Page (inspected by us)  An aggregate, cross-indexed product listing with a faceted search capability to help providers find products that meet their needs  An individual product page includes all of the ONC reporting requirements © 2011 CCHIT | Slide 15 | June 2011
  16. 16. CCHIT’s EHRAlternative Certificationfor Healthcare Providersor “EACH” © 2011 CCHIT | Slide 16 | June 2011
  17. 17. EHR Certification Alternative forHealthcare Providers (EACH™) A certification alternative for hospitals and eligible providers who are  Self-developing or significantly customizing EHR technology  Using older, uncertified EHR technology  Needing gap closure due to a mix of certified and uncertified EHR technologies Alternative certification is not needed if a hospital or eligible provider has adopted an EHR with Complete certification, or a combination of certified EHR Modules supporting all Meaningful Use objectives © 2011 CCHIT | Slide 17 | June 2011
  18. 18. How do we know ifwe need EACH? © 2011 CCHIT | Slide 18 | June 2011
  19. 19. First – check your eligibilityReview the CMS requirements foreligibility at their EHR IncentiveProgram web site. If you are aneligible professional, you can usetheir Eligibility Wizard. Click here © 2011 CCHIT | Slide 19 | June 2011
  20. 20. What’s the process? Determine Certify your Register to your products and participate in certification retrieve CMS the EHR needs Identifier from Incentive ONC Program © 2011 CCHIT | Slide 20 | June 2011
  21. 21. Examples of certification scenarios –which are you? A single, uncertified system A mix of systems, some certified EACH Many sites with many different systems © 2011 CCHIT | Slide 21 | June 2011
  22. 22. A single, uncertified system CMS Self-developed Complete EHR EACH ID All criteria are applied for with one system in use at one location or multiple, identical locations, a Complete EHR certification is granted with one CMS ID © 2011 CCHIT | Slide 22 | June 2011
  23. 23. A mix of systems, some certified170.302(a)170.302(b) Vendor-certified CMS product ID170.302(c)170.302(d) EACH Self-developed © 2011 CCHIT | Slide 23 | June 2011
  24. 24. Many sites with many different systems170.302(a)170.302(b)170.302(c)170.302(a) CMS ID170.302(b) EACH CMS ID170.302(c)170.302(a) MyEHR170.302(b) Uncertified Vendor Product170.302(c) Self-Developed Product Certified EHR © 2011 CCHIT | Slide 24 | June 2011
  25. 25. The EACH Process © 2011 CCHIT | Slide 25 | June 2011
  26. 26. Three phases in the EACH Program Preparation Readiness CertificationOnline program Online self-assessment Inspection scheduledorientation tool with learning program when applicant is preparedIntroduction to the Site inventory and gap Virtual web-based testingEACH online community analysis of criteria not using ONC criteria andof hospitals covered by certified EHR NIST test procedures technologyTeam formed and ready Certification resultsfor self-assessment Certification learning reported and sent to ONC; program with toolkit listed at cchit.org including test scripts and interoperability guide Retests available © 2011 CCHIT | Slide 26 | June 2011
  27. 27. SR17 Phase 1: Preparation Create an account at each.cchit.org Take a learning course and understand what testing and certification mean to you © 2011 CCHIT | Slide 27 | June 2011
  28. 28. Slide 27SR17 Insert screen shot of orienation learning program Sue Reber, 11/29/2010
  29. 29. SR18 Phase 1: More Preparation Explore Resources Participate in our - Community - Weekly Webinar © 2011 CCHIT | Slide 28 | June 2011
  30. 30. Slide 28SR18 Insert screen shot of orienation learning program Sue Reber, 11/29/2010
  31. 31. SR19 You may certify a complete EHR to meet Phase 2: Readiness all criteria You may certify an EHR module to meet just a few criteria © 2011 CCHIT | Slide 29 | June 2011
  32. 32. Slide 29SR19 Insert shot of application Sue Reber, 11/29/2010
  33. 33. SR20 Phase 2: More Readiness Creating an inventory to assess your gaps Build a plan to fill in your gaps © 2011 CCHIT | Slide 30 | June 2011
  34. 34. Slide 30SR20 Insert shot(s) of assessment tool Sue Reber, 11/29/2010
  35. 35. Phase 2: More ReadinessPracticedemonstration& customizedreports Readiness reports can also be used as Medicaid attestation documentation © 2011 CCHIT | Slide 31 | June 2011
  36. 36. Phase 3: Certification CCHIT Tester Healthcare Web conferencing and providers follow concurrent audio Test Script to conferencing demonstrate EHR technology at their facility © 2011 CCHIT | Slide 32 | June 2011
  37. 37. End Result of CertificationReported toONC-CHPLandCMS EHRCertification IDrendered © 2011 CCHIT | Slide 33 | June 2011
  38. 38. Tips for Providers © 2011 CCHIT | Slide 34 | June 2011
  39. 39. Which ambulatory certified product(s)might work best for you?ONC ATCB 2011/2012 only  Experienced in health IT or have your own self developed system  Desirous of a “niche” product or other technology for which there is not a CCHIT Certified® program at presentCCHIT Certified® only - providers for whom there are noincentive paymentsDual Certification: CCHIT Certified® and ONC-ATCB cert  Just about everyone else in the ambulatory environment!  Specialists who want available specialty certification and incentive payments © 2011 CCHIT | Slide 35 | June 2011
  40. 40. Approaching Hospital EHR Certification Check with your vendors as to their intent to certify… and to which criteria If vendor has an ONC-ATCB certified complete EHR, go no further (must use it) If using an older version of a vendor product, ask for Privacy and Security upgrade, and modular certification of whatever is compliant with ONC criteria Conduct your own gap analysis on older (or self developed) products and services (using the NIST test procedures for each ONC criteria) to determine extent of upgrades and additional modules necessary to achieve compliance (CCHIT’s readiness program can help) Consider cost of investment, ROI and fit with timing of current business plan Buy, build or update as needed Proceed with an EACH certification © 2011 CCHIT | Slide 36 | June 2011
  41. 41. The Future ??? © 2011 CCHIT | Slide 37 | June 2011
  42. 42. More Lessons Learned Need to pilot NIST developed test procedures before “go live” Need to assure that all criteria can be objectively tested Time intensive interoperability testing, but no testing of actual ability to exchange data in the native environment No guarantee that “receivers” can accept data Note that not all CQM measures need to be tested and certified as part of EP “calculate and report quality measures” criterion Some criteria need greater specificity, some need less Hospitals who use “best of breed” may need multiple, duplicative modules An evolutionary process, learn as we go © 2011 CCHIT | Slide 38 | June 2011
  43. 43. Near FutureONC Certification  Stage Two Meaningful Use, Standards, and Certification Criteria (2013?)  Transition from 6 ONC Authorized Testing and Certifying bodies to a limited set of Testing labs overseen by NIST and ONC authorized Certification bodies – can be the same entity – but certifications to remain active until new criteria are released  Permanent Certification rule calls out certification for HIT other than EHRs: PHRs, remote monitoring devices, HIE entities  Always tied to MU objectives and measuresCCHIT Certified®  Only ONC certification organization to go beyond federal minimum  Continues to match HIT innovation with new, complimentary certification processes that focus on provider/patient protection and patient care © 2011 CCHIT | Slide 39 | June 2011
  44. 44. In Summary CCHIT is an ONC-ATCB for ONC-ATCB 2011/2012 certification for both vendors and providers CCHIT also offers a number of CCHIT Certified® vendor programs (since 2006) We have immediate capacity for EHR testing in all programs We offer an EHR alternative certification for both hospitals and eligible providers called “EACH” to help providers qualify for ARRA funds CCHIT has limited scholarships for CAHs © 2011 CCHIT | Slide 40 | June 2011
  45. 45. Questions & Answers Karen Bell kbell@cchit.orgMore information available at cchit.org and at EACH © 2011 CCHIT | Slide 41 | June 2011

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