Clarifying Certification

by John Halamka, Life as a Healthcare CIO


On Friday, CCHIT announced certification of 33 complete and modular EHRs.  Drummond Group announced 3 certifications.

Many folks are asking about the difference between complete EHR certification and modular EHR certification.

A complete EHR must perform the functions necessary to support all 25 meaningful use criteria - 15 from the core set and all 10 from the menu set.   A complete EHR must support the 3 core quality measures, the 3 alternate quality measures and at least 3 of the menu set quality measures.

Modular EHR components are certified for the functions they perform.  The user then mixes and matches components as needed to meet the core set and the 5 menu set items they have chosen.   Each function included in meaningful use attestation must be certified.   Thus, in 2011, you only need to acquire the modular EHR components for the 20 criteria you are planning to include in your meaningful use attestation.

If your existing vendor-based hospital information does not provide all the functions you need for meaningful use, then acquire the modules needed to fill the gaps.   Alternatively, you can do what I am doing and seek a site certification of the hospital rather than assemble certifications for the products you are using.

It's likely that many existing EHRs will achieve modular certification - having most but not all needed functionality.   It's perfectly reasonable to use your existing EHR for the majority of the functionality you need, then supplement it with a data warehouse or health information exchange to achieve all the certifications necessary.

I hope this clarifies the certification process.

There will be many interesting lessons learned in this first round of certification.

1.  As I've reported previously, the Syndromic Surveillance implementation guide in the Standards Final rule is incorrect.   However, until it is fixed, vendors must implement the wrong data exchange in order to be certified because that is what the NIST testing site specifies.

2.  Some vendors may opt to be modular EHRs now and evolve to become complete EHRs as data exchange issues are clarified.   

3.  Testing procedures are going to evolve in these early days of certification and that is going to be challenging for vendors to support.   For example, NIST currently offers an e-prescribing validation procedure for NCPDP e-Prescribing formats using EDI but not XML implementations.  The HIT Standards Committee and the Standards Final Rule did not limit the transaction to just the EDI type.   Thus, it's likely NIST will change their testing criteria to support both EDI and XML.

  In the end, it will fall to the purchaser to ensure their goals are aligned with vendor plans.     If purchasers are seeking modules to expand the capabilities of an existing EHR, that should be clear.   If purchasers want a complete EHR and their preferred vendor is currently a module,  purchasers should request an agreement that the vendor will offer a complete EHR in a set period of time.