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Town Call:
New Paths to Certification
Accelerating EHR adoption and meaningful use under ARRA


Mark Leavitt, MD, PhD – Chair

Wednesday, Jun 17, 2009, 8:00 AM (PDT) / 11:00 AM (EDT)
Duration: 60 minutes
Live Meeting web conference:
https://www.livemeeting.com/cc/cchit/join?id=N6MZ4C&role=attend
Audio dial-In: (866) 900-5706, Conference ID: 15316708
Questions accepted online via Live Meeting Q&A (not by phone)
Agenda for Town Call


 Leveraging strengths while addressing challenges
 Proposal: new paths to certification
 Estimated timing and process
 Q & A and comments




                                         © 2009 | Slide 2 | June 17, 2009
Leveraging
Strengths while
Addressing
Challenges



                  © 2009 | Slide 3 | June 17, 2009
Strengths of the Current Certification Process
(from NCVHS Testimony by CCHIT, April 29, 2009)

  Transparent, consensus-based development process
     Diversity of volunteers, 3 cycles of public comment, and pilot testing
  Robust, repeatable and efficient inspection process
     100% compliance with criteria required; zero-tolerance for conflict of interest
      among staff and jurors (no relationship with vendors permitted)
  Intensive industry engagement and communication
     >640 volunteers applied to serve this year, double the previous figure
  Broad acceptance by providers
     The 10 largest professional associations have endorsed CCHIT
  Strong compliance by vendors
     >50% apply in first year; >75% of market certified in all current areas
     Substantial numbers upgrade to the latest certification every year
  Confidence of payers / purchasers
     21 States, 25% of private payers offer certified EHR incentives


                                                                      © 2009 | Slide 4 | June 17, 2009
Challenges to Address
(from NCVHS Testimony by CCHIT, April 29, 2009)

 Current program only addresses product features, not usability,
  training, implementation, or ‘field’ success rates

 Current policies are not sufficiently compatible with open source
  licensing models

 Certification fees a possible barrier for nonprofit EHR developers
  serving vulnerable populations

 Cost-effective approach to certifying self-developed and self-
  assembled EHRs that are not for commercial resale




                                                         © 2009 | Slide 5 | June 17, 2009
Proposal:
New Paths to
Certification




                © 2009 | Slide 6 | June 17, 2009
New Paths to Certification
    Certified        Certified   Certified
EHR Comprehensive   EHR Module   EHR Site
     EHR-C            EHR-M       EHR-S




                                    © 2009 | Slide 7 | June 17, 2009
New Paths to Certification: In Brief

       Certified                     Certified                         Certified
 EHR Comprehensive                  EHR Module                         EHR Site
        EHR-C                         EHR-M                             EHR-S

 Rigorous certification of      Flexible certification of Federal   Simplified, low cost
 comprehensive EHR systems      standards compliance for            certification of EHR
 that significantly exceed      EHR, HIE, eRx, PHR, Registry        technologies in use at a
 minimum Federal standards      and other EHR-related               specific site.
 requirements.                  technologies.
 For providers who seek         For providers who prefer to         For providers who self-
 maximal assurance of EHR       integrate technologies from         develop or assemble EHRs
 compliance and capabilities.   multiple certified sources.         from noncertified sources.




                                                                              © 2009 | Slide 8 | June 17, 2009
Certification Program Concepts for
EHR Comprehensive (EHR-C)
Definition               Certified EHR-C vendors provide comprehensive EHR products that
                         comply with all applicable Federal standards and enable providers to
                         meet all Meaningful Use Objectives.

Provider applicability   Physician offices and hospitals that prefer to rely on a single vendor
                         to provide their EHR and want maximal assurance that it will fulfill
                         their needs as well as qualify for ARRA incentives.

Certification            Functionality enabling providers to comply with all applicable Federal
                         standards, implement adequate security practices, meet all of the
requirements
                         Meaningful Use Objectives, and fulfill other requirements deemed
                         essential through CCHIT’s consensus-based development process.
                         Also required: evidence of success in meaningful use at multiple
                         user sites.

Other data published     Usability will be evaluated and rated.

Inspection methods       Juried demonstration, documentation inspection, technical
                         interoperability testing, usability evaluation, live site use verifications.

Cost range               ~$30,000 - $50,000 range (for new applicants; pricing for retesting of
                         08 certified products TBD)

                                                                                 © 2009 | Slide 9 | June 17, 2009
Certification Program Concepts for
EHR Modules (EHR-M)
Definition               Certified EHR-M modules are applications that comply with
                         applicable Federal standards and enable providers to meet one or
                         more Meaningful Use Objectives (labeling will specify which
                         Objectives and standards are met).

Provider applicability   Physician offices and hospitals that choose to combine technologies
                         from multiple certified sources to qualify for ARRA incentives.

Certification            Basic functionality that enables providers to comply with applicable
                         Federal standards, implement adequate security practices, and meet
requirements
                         one or more of the Meaningful Use Objectives.

Other data published     N/A

Inspection methods       Demonstration, documentation inspection, technical interoperability
                         testing.

Cost range               ~$5,000 - $35,000 range (depending on scope of module)
                         Scholarships for eligible nonprofit suppliers if grants can be obtained.




                                                                             © 2009 | Slide 10 | June 17, 2009
Certification Program Concepts for
EHR Sites (EHR-S)
Definition               Certified EHR-S sites have developed or assembled EHR
                         technologies that comply with Federal standards and enable them to
                         meet all Meaningful Use Objectives.

Provider applicability   Any physician office, clinic, hospital, other facility or network that has
                         self-developed or assembled an EHR from various sources and
                         wishes to apply to ARRA incentives.

Certification            Functionality available (regardless of deployment model) that
                         enables providers to comply with applicable Federal standards,
requirements
                         implement adequate security practices, and meet Meaningful Use
                         Objectives.

Other data published     N/A

Inspection methods       Virtual Site Visit technology with offline inspector review and follow-
                         up correspondence.

Cost range               ~$150 - 300 per licensed provider (ambulatory); hospital pricing
                         model TBD. Scholarships for eligible providers (FQHC, underserved
                         population, critical access, etc) if grants can be obtained.


                                                                               © 2009 | Slide 11 | June 17, 2009
Mapping Current CCHIT Programs to
the New Paths
                                                    EHR-C EHR-M EHR-S
Ambulatory and Inpatient EHRs                        X
Child Health, Cardiovascular, Enterprise add-on      X
Emergency Department, other specialties and
                                                               X
settings under development
Stand-alone ePrescribing                                       X
PHRs                                                           X
Health Information Exchanges                                   X
Ambulatory or Inpatient internally developed EHRs                               X




                                                         © 2009 | Slide 12 | June 17, 2009
Options for Vendors/Developers of EHR and
Related Technology
                                                           EHR-C EHR-M EHR-S
Comprehensive EHRs with multiple successful
                                                            X         X                X
installations
Specialty, small office, ‘light’ and open source EHRs                 X                X
ePrescribing applications                                             X                X
PHRs, patient-physician communication applications                    X                X
Health Information Exchanges (could certify EHR
                                                                      X                X
and PHR functions, not just HIE transactions)
Registries, other applications capable of fulfilling one
                                                                      X                X
or more meaningful use objectives
Self-developed EHRs and other technologies                                             X


                                                                © 2009 | Slide 13 | June 17, 2009
Conceptual Application Process
for ARRA Incentive Payments
          EHR-C                        EHR-M                          EHR-S
 Provider deploys certified    Provider deploys a             Provider develops or
 EHR-C                         combination of certified       assembles noncertified
                               EHR-M modules                  EHR technologies.

 EHR-C vendor gives            EHR-M suppliers each give      Provider site applies, is
 provider the certification    provider the certification     inspected, and receives
 code (issued by CCHIT) for    code (issued by CCHIT) for     EHR-S certification. Code
 that product                  their products/services        issued to site by CCHIT.
                               Provider includes EHR-M
                               certification codes in their   Provider includes EHR-S
 Provider includes EHR-C
                               ARRA incentive application.    certification code in their
 certification code in their
                               (Combined modules must         ARRA incentive application.
 ARRA incentive application
                               cover all meaningful use
                               objectives.)
 Provider submits measure      Provider submits measure       Provider submits measure
 data required for ARRA        data required for ARRA         data required for ARRA
 meaningful use                meaningful use                 meaningful use



                                                                     © 2009 | Slide 14 | June 17, 2009
Estimated Timing
and Process
Crosswalk from Currently Recognized
Certification Criteria to Meaningful Use
                          ARRA 2011-2012 Meaningful Use
                          Objectives, Measures, Standards,
                         Implementation Specifications, and
                                 Certification Criteria

                                                                   New criteria as
                                                                  needed to fill gaps

                                             Certification
                                               Criteria
                         Meaningful
  Health       Care                          supporting
                            Use                                      Currently
 Outcomes     Process                        Meaningful
                         Objectives                                 Recognized
 Priorities    Goals                             Use
                        and Measures                                Certification
                                             Objectives
                                            and Measures              Criteria



                                                                     Criteria not
                            Interoperability Standards            required for ARRA
                        and Implementation Specifications            2011-2012



                                                              © 2009 | Slide 16 | June 17, 2009
Certification Timing under ARRA
(Subject to timing of HHS/ONC decisions and actions)
 ARRA 2011-2012 Certification
    Launch Preliminary ARRA 2011-2012 Certification in Sept 09
    Launch Final ARRA 2011-2012 Certification in Jan 10
    Accelerate development and launch of expansion areas
    Certification is valid through Dec 31, 2012
 ARRA 2013-2014 Certification
    Begin preliminary development from 2013-2014 Meaningful Use
     Objectives and Measures
    Goal: launch Final Certification programs 15-18 months before beginning
     of incentive window (i.e., mid to late 2011)
    Certification would extend to 12/31/2014

 ARRA 2015-2016 Certification
    Similar timing model to 2013-1014

                                                            © 2009 | Slide 17 | June 17, 2009
Certification Timeline Sync-up
(Tentative, based on statutory provisions + stated or estimated HHS/ONC plans)
  May         June        July      Aug         Sept         Oct       Nov         Dec          Jan             Feb-July
  2009        2009        2009      2009        2009        2009       2009        2009        2010              2010
           5/29-CCHIT 09 Criteria published & submitted to HITSC

                             7/14-7/16-CCHIT meetings (Commission, Work Group kickoff)
         informed by
                        analyze,                    9/??-Launch ARRA 2011-2012 Preliminary Certification
                       close gaps                   Pilot Test New Paths                      1/??-Launch ARRA
                                                                                                   2011-2012 Final
                                            analyze,                                               Certification including
                                           close gaps                                              New Paths
                                                                                           analyze,
                                                                                          close gaps     Other expansion
                                                                                                         launches
                  6/16-HITSC releases draft Meaningful Use definitions and measures
                                           8/26-HITSC/HITPC finalize recommended meaningful use measures,
                                           standards, implementation specs, certification criteria; HHS begins rule-
                                           making and OMB review processes
                                                                                             12/31 HHS publishes
                                                                                             Interim Final Rule




                                                                                              © 2009 | Slide 18 | June 17, 2009
Thank You!
Q&A


 During the meeting, questions will be taken online (not via phone)
 Submit comments and questions via Live Meeting Q&A (see above)
 We will answer as many questions as possible ‘live’ and post
  additional responses on our website.

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CCHIT Town Call: New Paths To Certification for Open Source

  • 1. Town Call: New Paths to Certification Accelerating EHR adoption and meaningful use under ARRA Mark Leavitt, MD, PhD – Chair Wednesday, Jun 17, 2009, 8:00 AM (PDT) / 11:00 AM (EDT) Duration: 60 minutes Live Meeting web conference: https://www.livemeeting.com/cc/cchit/join?id=N6MZ4C&role=attend Audio dial-In: (866) 900-5706, Conference ID: 15316708 Questions accepted online via Live Meeting Q&A (not by phone)
  • 2. Agenda for Town Call  Leveraging strengths while addressing challenges  Proposal: new paths to certification  Estimated timing and process  Q & A and comments © 2009 | Slide 2 | June 17, 2009
  • 3. Leveraging Strengths while Addressing Challenges © 2009 | Slide 3 | June 17, 2009
  • 4. Strengths of the Current Certification Process (from NCVHS Testimony by CCHIT, April 29, 2009)  Transparent, consensus-based development process  Diversity of volunteers, 3 cycles of public comment, and pilot testing  Robust, repeatable and efficient inspection process  100% compliance with criteria required; zero-tolerance for conflict of interest among staff and jurors (no relationship with vendors permitted)  Intensive industry engagement and communication  >640 volunteers applied to serve this year, double the previous figure  Broad acceptance by providers  The 10 largest professional associations have endorsed CCHIT  Strong compliance by vendors  >50% apply in first year; >75% of market certified in all current areas  Substantial numbers upgrade to the latest certification every year  Confidence of payers / purchasers  21 States, 25% of private payers offer certified EHR incentives © 2009 | Slide 4 | June 17, 2009
  • 5. Challenges to Address (from NCVHS Testimony by CCHIT, April 29, 2009)  Current program only addresses product features, not usability, training, implementation, or ‘field’ success rates  Current policies are not sufficiently compatible with open source licensing models  Certification fees a possible barrier for nonprofit EHR developers serving vulnerable populations  Cost-effective approach to certifying self-developed and self- assembled EHRs that are not for commercial resale © 2009 | Slide 5 | June 17, 2009
  • 6. Proposal: New Paths to Certification © 2009 | Slide 6 | June 17, 2009
  • 7. New Paths to Certification Certified Certified Certified EHR Comprehensive EHR Module EHR Site EHR-C EHR-M EHR-S © 2009 | Slide 7 | June 17, 2009
  • 8. New Paths to Certification: In Brief Certified Certified Certified EHR Comprehensive EHR Module EHR Site EHR-C EHR-M EHR-S Rigorous certification of Flexible certification of Federal Simplified, low cost comprehensive EHR systems standards compliance for certification of EHR that significantly exceed EHR, HIE, eRx, PHR, Registry technologies in use at a minimum Federal standards and other EHR-related specific site. requirements. technologies. For providers who seek For providers who prefer to For providers who self- maximal assurance of EHR integrate technologies from develop or assemble EHRs compliance and capabilities. multiple certified sources. from noncertified sources. © 2009 | Slide 8 | June 17, 2009
  • 9. Certification Program Concepts for EHR Comprehensive (EHR-C) Definition Certified EHR-C vendors provide comprehensive EHR products that comply with all applicable Federal standards and enable providers to meet all Meaningful Use Objectives. Provider applicability Physician offices and hospitals that prefer to rely on a single vendor to provide their EHR and want maximal assurance that it will fulfill their needs as well as qualify for ARRA incentives. Certification Functionality enabling providers to comply with all applicable Federal standards, implement adequate security practices, meet all of the requirements Meaningful Use Objectives, and fulfill other requirements deemed essential through CCHIT’s consensus-based development process. Also required: evidence of success in meaningful use at multiple user sites. Other data published Usability will be evaluated and rated. Inspection methods Juried demonstration, documentation inspection, technical interoperability testing, usability evaluation, live site use verifications. Cost range ~$30,000 - $50,000 range (for new applicants; pricing for retesting of 08 certified products TBD) © 2009 | Slide 9 | June 17, 2009
  • 10. Certification Program Concepts for EHR Modules (EHR-M) Definition Certified EHR-M modules are applications that comply with applicable Federal standards and enable providers to meet one or more Meaningful Use Objectives (labeling will specify which Objectives and standards are met). Provider applicability Physician offices and hospitals that choose to combine technologies from multiple certified sources to qualify for ARRA incentives. Certification Basic functionality that enables providers to comply with applicable Federal standards, implement adequate security practices, and meet requirements one or more of the Meaningful Use Objectives. Other data published N/A Inspection methods Demonstration, documentation inspection, technical interoperability testing. Cost range ~$5,000 - $35,000 range (depending on scope of module) Scholarships for eligible nonprofit suppliers if grants can be obtained. © 2009 | Slide 10 | June 17, 2009
  • 11. Certification Program Concepts for EHR Sites (EHR-S) Definition Certified EHR-S sites have developed or assembled EHR technologies that comply with Federal standards and enable them to meet all Meaningful Use Objectives. Provider applicability Any physician office, clinic, hospital, other facility or network that has self-developed or assembled an EHR from various sources and wishes to apply to ARRA incentives. Certification Functionality available (regardless of deployment model) that enables providers to comply with applicable Federal standards, requirements implement adequate security practices, and meet Meaningful Use Objectives. Other data published N/A Inspection methods Virtual Site Visit technology with offline inspector review and follow- up correspondence. Cost range ~$150 - 300 per licensed provider (ambulatory); hospital pricing model TBD. Scholarships for eligible providers (FQHC, underserved population, critical access, etc) if grants can be obtained. © 2009 | Slide 11 | June 17, 2009
  • 12. Mapping Current CCHIT Programs to the New Paths EHR-C EHR-M EHR-S Ambulatory and Inpatient EHRs X Child Health, Cardiovascular, Enterprise add-on X Emergency Department, other specialties and X settings under development Stand-alone ePrescribing X PHRs X Health Information Exchanges X Ambulatory or Inpatient internally developed EHRs X © 2009 | Slide 12 | June 17, 2009
  • 13. Options for Vendors/Developers of EHR and Related Technology EHR-C EHR-M EHR-S Comprehensive EHRs with multiple successful X X X installations Specialty, small office, ‘light’ and open source EHRs X X ePrescribing applications X X PHRs, patient-physician communication applications X X Health Information Exchanges (could certify EHR X X and PHR functions, not just HIE transactions) Registries, other applications capable of fulfilling one X X or more meaningful use objectives Self-developed EHRs and other technologies X © 2009 | Slide 13 | June 17, 2009
  • 14. Conceptual Application Process for ARRA Incentive Payments EHR-C EHR-M EHR-S Provider deploys certified Provider deploys a Provider develops or EHR-C combination of certified assembles noncertified EHR-M modules EHR technologies. EHR-C vendor gives EHR-M suppliers each give Provider site applies, is provider the certification provider the certification inspected, and receives code (issued by CCHIT) for code (issued by CCHIT) for EHR-S certification. Code that product their products/services issued to site by CCHIT. Provider includes EHR-M certification codes in their Provider includes EHR-S Provider includes EHR-C ARRA incentive application. certification code in their certification code in their (Combined modules must ARRA incentive application. ARRA incentive application cover all meaningful use objectives.) Provider submits measure Provider submits measure Provider submits measure data required for ARRA data required for ARRA data required for ARRA meaningful use meaningful use meaningful use © 2009 | Slide 14 | June 17, 2009
  • 16. Crosswalk from Currently Recognized Certification Criteria to Meaningful Use ARRA 2011-2012 Meaningful Use Objectives, Measures, Standards, Implementation Specifications, and Certification Criteria New criteria as needed to fill gaps Certification Criteria Meaningful Health Care supporting Use Currently Outcomes Process Meaningful Objectives Recognized Priorities Goals Use and Measures Certification Objectives and Measures Criteria Criteria not Interoperability Standards required for ARRA and Implementation Specifications 2011-2012 © 2009 | Slide 16 | June 17, 2009
  • 17. Certification Timing under ARRA (Subject to timing of HHS/ONC decisions and actions)  ARRA 2011-2012 Certification  Launch Preliminary ARRA 2011-2012 Certification in Sept 09  Launch Final ARRA 2011-2012 Certification in Jan 10  Accelerate development and launch of expansion areas  Certification is valid through Dec 31, 2012  ARRA 2013-2014 Certification  Begin preliminary development from 2013-2014 Meaningful Use Objectives and Measures  Goal: launch Final Certification programs 15-18 months before beginning of incentive window (i.e., mid to late 2011)  Certification would extend to 12/31/2014  ARRA 2015-2016 Certification  Similar timing model to 2013-1014 © 2009 | Slide 17 | June 17, 2009
  • 18. Certification Timeline Sync-up (Tentative, based on statutory provisions + stated or estimated HHS/ONC plans) May June July Aug Sept Oct Nov Dec Jan Feb-July 2009 2009 2009 2009 2009 2009 2009 2009 2010 2010 5/29-CCHIT 09 Criteria published & submitted to HITSC 7/14-7/16-CCHIT meetings (Commission, Work Group kickoff) informed by analyze, 9/??-Launch ARRA 2011-2012 Preliminary Certification close gaps Pilot Test New Paths 1/??-Launch ARRA 2011-2012 Final analyze, Certification including close gaps New Paths analyze, close gaps Other expansion launches 6/16-HITSC releases draft Meaningful Use definitions and measures 8/26-HITSC/HITPC finalize recommended meaningful use measures, standards, implementation specs, certification criteria; HHS begins rule- making and OMB review processes 12/31 HHS publishes Interim Final Rule © 2009 | Slide 18 | June 17, 2009
  • 19. Thank You! Q&A  During the meeting, questions will be taken online (not via phone)  Submit comments and questions via Live Meeting Q&A (see above)  We will answer as many questions as possible ‘live’ and post additional responses on our website.