Jim Tate, Meaningful Use Expert

What if my certified EHR gets data from my non-certified PM?

One very common question I receive about the CMS EHR Incentive Programs for Eligible Providers (EPs) concerns their use of a separate Practice Management System. Many EPs have an EHR that has received Certified Complete EHR status from CMS. They often have a separate Practice Management System that incorporates the functionality to maintain scheduling, billing, patient accounts, and demographics. So, the question often asked is: “If my certified EHR is receiving data from a non-certified Practice Management System, do I have anything to worry about? Are my potential incentives at risk?”

The answer to this question, thankfully, is “No”. In this scenario there is nothing to worry about. CMS has provided clarification with the following FAQ:

Question: “My EHR technology is designed to receive demographic data from a registration system or a practice management system. The data from these other IT systems is then used by my EHR technology to demonstrate compliance with one or more certification criteria. Do these other IT systems that act as data sources to my EHR technology need to be certified?

Answer: “No, other IT systems that act as data sources and are not intended to perform required capabilities in accordance with adopted certification criteria do not need to be certified simply because they supply data to a Complete EHR or EHR Module. Obviously, if the other IT systems have not been developed to, and cannot, perform required capabilities in accordance with adopted certification criteria then certification of those other IT systems would not be available. For the purposes of certification, an EHR technology developer must be able to demonstrate to an ONC-ATCB that its Complete EHR or EHR Module can perform the capabilities specified by all applicable certification criteria. Thus, in circumstances where the Complete EHR or EHR Module is designed to be implemented in multiple ways, including the ability to receive data from a different IT system, the EHR technology developer would need to demonstrate during testing that regardless of the source from which the Complete EHR or EHR Module receives data, it is compliant with all applicable certification criteria for which testing and certification has been sought.”

So there you go. Now find something else to worry about.

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.