Not Together With Therefore Meaningful Ehr Certification

Can y'all purchase an ONC Certified EHR, or EHR module, in addition to abide by to your chagrin that no affair how difficult y'all try, Meaningful Use is non inside reach?

While the spotlights were shining brightly on CMS in addition to ONC equally the terminal definitions of Meaningful Use (MU) in addition to EHR certification criteria were beingness released, I expressed misgivings regarding the “lightness” of the draft version of the NIST testing procedures, then naturally I was curious to run across the terminal documents. Although around problematic procedures were but removed from the terminal version, others silent remain.

Thus the answer to the opening query higher upwards is a resounding Yes. In an essay to component ways amongst the heavy handed CCHIT certification model, NIST adopted a simplistic, narrowly defined laid of testing procedures. Vendors, especially pocket-sized ones who never underwent CCHIT certification, volition probable live on happy amongst the latitude afforded past times NIST. However, the lack of specificity may rattling good house unsuspecting physician buyers inwards a bad situation, in addition to hither is how.

• §170.302(h) - Incorporate laboratory essay results: The terminal ONC certification dominion does non require a item criterion to live on used past times the EHR for receiving structured lab results. All comments submitted to ONC requesting criterion specification produce got been rejected inwards the involvement of flexibility. Adhering to the ONC ruling, NIST allows the EHR vendor to pick out whatever format they wishing for certification purposes. Influenza A virus subtype H5N1 comma or pipage delimited text file volition do.
  
  National reference labs, similar Quest in addition to LabCorp, equally good equally smaller regional labs in addition to infirmary labs, are all standardized on around shaver version of the HL7 2.X criterion for transmission of lab results. An EHR, or EHR module, passing ONC certification amongst anything but the manufacture accepted HL7 standards volition live on unable to connect to whatever laboratories. The “older” EHRs, which produce got submitted to CCHIT certification inwards the past, all produce got working HL7 lab interfaces. The occupation concern is amongst gear upwards novel products, certifying for the showtime time.
  
  Assuming the EHR, or EHR module, has HL7 capabilities for lab results, at that topographic point is silent a major hurdle to overcome. National reference labs produce got long implementation queues in addition to stringent testing in addition to certification processes of their own. It may bring vi months or so, for a novel EHR vendor to institute the showtime alive interface amongst a reference lab. Any subsequent interfaces must equally good undergo testing in addition to could equally good bring months to create, depending on both vendor in addition to lab availability of resources.
  
  For a physician contemplating the purchase of a item EHR this translates into a involve to obtain documented proof from both the EHR vendor in addition to the Lab(s) that operational interfaces be for the Laboratories used past times the practice. It equally good requires that y'all component inwards the additional fourth dimension it volition bring to produce your item interface(s).

• §170.304(b) - Electronically central prescription information: NIST has decided that for certification purposes, solely the might to mail out a novel prescription volition live on tested. The entire essay physical care for consists of generating NEWRX messages according to the SCRIPT criterion in addition to sending them to a vendor identified external system. Successful testing is decided based on the correctness of the generated message. An EHR, or EHR module, conforming to this item essay is non guaranteed to live on able to satisfy the MU criterion. Not past times a long shot.
  
  EHRs involve to connect to the Surescripts network inwards social club to mail prescriptions electronically to pharmacies. Surescripts requires the EHR vendor to snuff it through an arduous testing physical care for prior to beingness allowed to utilization the network. The might to mail out novel scripts is solely a pocket-sized component of Surescripts testing. The vendor must produce got the might to equally good have mistake response messages from Surescripts in addition to the pharmacy, have in addition to respond to refill requests from the chemist's shop in addition to mail renewal messages to pharmacies. Surescripts must equally good live on satisfied that the EHR’s user interface conforms to Surescripts standards. Surescripts certification is a lengthy physical care for in addition to it is non odd for it to extend good beyond 8 months.
  
  In a nutshell, a physician aiming to snuff it a meaningful user in addition to collect Government incentives must ensure that the ONC certified EHR nearly to live on purchased is equally good Surescripts certified. ONC certification for this gist MU requirement is meaningless.

• §170.302(d) - Maintain active medication list: The minimalistic NIST essay physical care for for this criterion volition non impact Meaningful Use or stimulus incentives. It may, however, adversely impact patient care. This essay physical care for genuinely presumes that each fourth dimension a prescription is modified, such equally changing dosage or frequency, whatever in addition to all previous history of said prescription is erased. For example, if a few weeks agone y'all prescribed Celexa 20mg in addition to today y'all in addition to the patient determine to increase the dose to 40mg, the medical tape volition present that the patient was started on Celexa today, in addition to the dose is 40mg. There volition live on no visible draw of the 20mg regimen inwards the EHR.
  
  Again, “older” EHRs, having gone through CCHIT certification at around point, volition in all likelihood retain right medication histories. New EHRs in addition to EHR modules, written to the NIST testing specifications, may not. Unlike lab interfaces in addition to electronic prescriptions, at that topographic point is no obvious 3rd political party verification to await for when shopping for an EHR. This type of work volition non live on discovered past times a prospective buyer until the EHR has been purchased, installed in addition to used for around time. At that point, amongst histories lost, the solely recourse would live on to asking the vendor to render an enhancement to certified functionality.

These are precisely the most obvious problems. Generally speaking, the essay procedures are then narrowly defined that recording such things equally who modifies allergies, vital signs, medications or work lists, or when these were modified, or why, are non a requirement for passing the tests. Presumably, these are all recorded inwards the audit logs, but at that topographic point is no specific inspection of the logs in addition to anyway clinicians are non going to consult audit logs on a routine basis. Many other essay procedures are of similarly superficial nature, suggesting that NIST is non attempting to certify a production equally much equally it is trying to certify a applied scientific discipline framework which could live on ultimately used to construct a meaningful product.

Bottom Line: Physicians involve to understand, in addition to ONC needs to clarify, that although required past times CMS, ONC EHR certification does non guarantee availability of all EHR features in addition to functionalities required to attain Meaningful Use.