A Reader Asks: Can current EMR systems produce the kinds of reports that will be required to demonstrate Meaningful Use? If not, where does that leave providers?
HIS Pros Says: The temporary EHR certification rule released by ONC requires certified systems to be capable of reporting the numerator, denominator and percentage for each measure detailed by CMS in the final meaningful use rule. (See §170.302(n) in the certification rule). This requirement was not in the proposed rule and was added as a response to numerous comments urging ONC to include requirements that reduce the burden on provider organizations to evaluate and demonstrate compliance with the percentage measures, as well as increase the accuracy and reliability of provider reporting.
The not so happy news is certified EHRs must produce the reporting that the rule requires and if this has not already been included in product development it must be added. A few forward-thinking vendors we talked to have anticipated the ONC reporting requirement (or perhaps simply thought about their customers’ needs) and say that their software provides this functionality now. CCHIT, which has been doing “Preliminary ARRA Certifications” has 14 products listed that have passed certification testing under the proposed rule.
Providers who plan on using currently installed systems to achieve Meaningful Use must face the reality that these systems will need to be certified to meet ONC requirements and that they will need to budget time and money to install upgrades. (We can only hope that the testing process required for certification will flesh out the bugs in hastily developed software, thereby mitigating the need for exhaustive testing of new functionality by provider organizations).
Those with “best of breed” system environments may grapple with “EHR module” certification and upgrade/replacement of multiple systems — compounding the work needed for compliance. Aggregating data from multiple systems to provide the required MU measurements may be the biggest reporting hurdle, since the rule specifically states that there is no requirement that individual EHR modules be tested for interoperability. An example is a facility with a standalone Emergency Department module that is used for CPOE and is not well integrated with the inpatient CPOE system — each system will report its own statistics.
Providers currently evaluating EHR systems and modules should ask about prospective vendor’s plans to comply with the ONC certification rule. I would view any suggestion that you can report on the measures yourself using system tools (reporting software or data warehousing functions) with extreme skepticism. Those that are purchasing systems now should ensure there is language in the contract that requires the vendor to obtain (and maintain) certification with a firm remedy if it is not forthcoming in time for the CMS defined reporting periods.
Beware the software vendor that will want to charge for the functionality to achieve Meaningful Use. Ask vendors what their plans are — and get it in writing.
- Will your EHR system be certified?
- When will the certified version be available?
- Will there be any charges associated with acquiring and installing the certified version?
- What will the charges be?
- Will the vendor provide you a contractual warranty (with a penalty for non-compliance) that use of the software will allow you to achieve Meaningful Use?
The bottom line — reporting on the CMS Meaningful Use measures is now a requirement for certified EHR technology. That is great news. The only downside is that if a software vendor has not anticipated this requirement, the functionality will have to be developed prior to the product being certified, which in a worst case could delay release and implementation of a certified product. But don’t fear — test procedures for the final temporary certification requirements must still be finalized by NIST (expected July 22), and the ONC Certification and Testing Bodies also need to be selected and announced, so there may be some time to work on the software development end of things.