On Feb. 24, 2012, the Office of National Coordinator (ONC) released its proposed rule for the certification of electronic health record systems, which complements the CMS proposed rule for Meaningful Use Stage 2. In the proposed certification criteria, the ONC introduces the concept of editions—the new set of certification criteria is referred to as the 2014 Edition, while the current criteria are referred to as the 2011 Edition. This is important to note, as both editions may be available concurrently.
The proposed 2014 Edition certification criteria radically redefine the term "certified EHR technology" (referred to by ONC as "CEHRT") in an attempt to address industry concerns and provide more flexibility. The proposed definition of CEHRT would require EPs to have what the ONC characterizes as a Base EHR, which would include capabilities considered mandatory under the federal statute to meet Meaningful Use. In contrast to the current requirements, EPs would no longer have to purchase or assemble a Complete EHR in order to qualify for incentives. Instead, they could use only a Base EHR plus whatever CEHRT technologies are necessary to satisfy all core measures the EP cannot exclude and satisfy the particular menu measures of that EP's choosing.
This shift would relieve a portion of regulatory burden for certain EPs, particularly hospitals and specialists, in that they do not have to adopt technology with functions they do not use or need in order to satisfy Meaningful Use. For instance, a psychiatrist would not have to purchase CEHRT for vitals capture since he/she would exercise an exclusion clause eliminating the need to meet this measure because it is irrelevant to the practice of psychiatry. Whereas, under the 2011 Edition, a psychiatrist would have to purchase comprehensive CEHRT for all 25 Stage 1 measures, even though he/she would never use the technology.
Under the 2014 Edition, there would be three ways for EPs to meet the new CEHRT definition:
- Purchase a Complete EHR that has tested and certified on ALL measures
- Purchase a combination of EHR modules that do all the functions needed
- Purchase a single Base EHR module that performs the required functions
Another shift proposed in the 2014 Edition is the use of single standards for communicating information in certain transactions, as opposed to the options vendors have for communicating information under current certification criteria. Health Level 7 (HL7) is the proposed standard for lab results, syndromic surveillance and immunizations, and the Consolidated Clinical Document Architecture (CDA) is the proposed document standard. The proposed rule also includes requirements that EHRs be able to use the SMTP and SMIME secure messaging standards, the SOAP-based secure transport standard and the Direct transport standard for health information exchange (HIE). The use of these standards supports progress towards a common means of transporting health information, including leveraging the Internet that is so pervasive in the country.
The proposed rule also includes changing the name of the permanent certification program to the "ONC HIT Certification Program."
For more information, read the ONC's proposed rule at http://www.ofr.gov/OFRUpload/OFRData/2012-04430_PI.pdf.