HITECH requires the use of certified EHR technology for certain providers (e.g., physicians and short-term acute care hospitals) to qualify for incentive payments under the Medicare and Medicaid EHR Incentive Programs ("Meaningful Use Programs"). For purposes of the Meaningful Use Programs, two types of certifications can be issued to EHR technology that meets certification criteria adopted by the Secretary of HHS: (1) Complete EHR, or (2) EHR Module. To be eligible for meaningful use incentive payments, eligible hospitals (EHs) and eligible professionals (EPs) must use EHR technology that has been certified by an entity authorized by ONC. To date, six ONC-Authorized Testing and Certification Bodies (ONC-ATCBs) have been authorized to test and certify EHR technology that can be used by eligible professionals and hospitals in the Meaningful Use Programs.19 For example, EHR certification criteria include (but are not limited to) vocabulary standards (e.g., Systematized Nomenclature of Medicine (SNOMED), International Classification of Diseases (ICD), Logical Observation Identifiers Names and Codes (LOINC)) and content exchange standards (e.g., Clinical Document Architecture (CDA) and Continuity of Care Document (CCD)).
While some EHR technology certification criteria used for the Meaningful Use Program for EPs and EHs would be applicable to the workflow in LTPAC setting, there is growing concern and awareness that not all of the certification criteria are applicable to EHR technology used by LTPAC providers. For example, the capability to plot growth charts or submit to immunization registries would not be a typical feature of a LTPAC EHR technology. Additionally, the adopted EHR technology certification criteria do not reflect the requirements that are uniquely needed by LTPAC providers.
For several years, the LTPAC provider and vendor community worked with Health Level 7 (HL7) (a Standards Development Organization) to produce an EHR Functional Profile for LTPAC. This Profile was used by LTPAC stakeholders and the Certification Commission for Health Information Technology (CCHIT) to identify LTPAC EHR certification criteria.20 It should be noted that the CCHIT LTPAC EHR Certification Program has not been recognized by ONC. While there is significant overlap in the EHR criteria that have been adopted for the Meaningful Use Program and the LTPAC EHR Certification Criteria, there are also differences in the criteria that have been identified in these two programs. This misalignment has created confusion and uncertainty among LTPAC providers regarding whether they should purchase certified EHRs and if so, what type of certified EHR product would support the workflow of the LTPAC provider. ONC is aware of the uncertainties and questions regarding EHR certification confronting LTPAC and other providers that are ineligible under the Meaningful Use Programs and is working with stakeholders to better understand their EHR technology needs.
During the discussion at the 2011 LTPAC HIT Summit at the session on "Moving LTPAC Providers in the Nationwide Health IT Infrastructure," providers and vendors concluded that there is likely a core set of EHR criteria that will be common across all EHR products (e.g., requirements related to privacy/security, medication reconciliation, problem list, etc.).21 During this discussion, providers and vendors suggested that ONC consider: (1) meeting with LTPAC providers and vendors to identify what EHR certification criteria are needed to support the workflow in LTPAC; and (2) working with the Meaningful Use Workgroup of the Health IT Policy Committee to identify the types of HIE activities that are needed in and from LTPAC. The Longitudinal Coordination of Care Workgroup (LCCWG) created through the ONC-sponsored S&I Framework (described in more detail below) is beginning to examine the HIT standards needed to support HIE on behalf of persons receiving LTPAC. The HIE activities targeted in this S&I effort are expected to advance the meaningful use of EHRs and shed some light on some of the EHR certification criteria needed by LTPAC providers.
As discussed in the section further in this report "Leverage and Standardize Assessment Content to Engage LTPAC Providers in HIE," experts interviewed noted that there is growing discussion about the need to integrate LTPAC providers in HIE activities to support quality, continuity, and collaborative care (Appendix A: Stakeholder Interview Summary). To support efficient and interoperable HIE, some LTPAC providers and EHR vendors believe that it is important to use EHR products that support at least some of the standards incorporated in certification criteria for the Meaningful Use Incentive Program. As reported at the 2011 LTPAC HIT Summit, some vendors expressed an interest in obtaining certification for their EHR products as either: (1) meeting the meaningful use requirements; and/or (2) complying with the LTPAC CCHIT comprehensive EHR criteria.22 At least one LTPAC vendor has obtained hospital modular EHR certification (through an ONC-ATCB) for their product to support the interoperable and secure exchange of health information such as demographics, problem lists, physician order entry, medication lists, medication reconciliation, and advance directives. This LTPAC HIT vendor and one other have also obtained LTPAC CCHIT EHR certification.23
To support widespread adoption of appropriate and interoperable EHRs for LTPAC, the LTPAC HIT Collaborative recommended in the LTPAC 2010-2012 Health IT Roadmap24 that policy guidance be provided for the EHR certification criteria needed to enable the exchange of health information between hospitals, physicians and LTPAC providers. The members of the Collaborative believe that such criteria would facilitate HIE with and by LTPAC providers, support the meaningful use of EHRs by a wide array of health care providers, and support the emerging nationwide HIT infrastructure.
At this time the ONC has not established a specialty EHR certification program (e.g., a certification and testing program for EHR products for LTPAC providers (or other specialty providers)) or identified EHR certification criteria that are unique to the workflow requirements in LTPAC or other specialty providers. Establishing such a program or identifying EHR certification criteria is complex, could be costly, and requires careful consideration of the advantages and disadvantages. An objective in the draft roadmap of the recently established LCCWG under the ONC-sponsored S&I Framework is to "develop certification requirements for EHR and LTPAC vendors in anticipation of LTPAC pilots."25
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