2014 Edition EHR Testing and Certification

Here we go, again. This week hopefully launches the Permanent Certification Program for EHR Technology and kicks off the testing and certification process for 2014 Edition software. We have been through this before and hopefully this time we will see a more measured approach for the sake of us all. The launch of Stage 1 (now referred to as 2011 Edition) certification was the equivalent of the Oklahoma land rush. The urgency to receive certification as soon as possible was a business decision that often relegated functionality and usability to a secondary position. There will be no excuses this time for inferior development that forces providers into convoluted work flows that are required to document meaningful use. The only deadlines are self-imposed from the vendor perspective. Let’s review why a more civil approach to certification may be on the horizon.

• The Testing and Certification Bodies have been down this road before. They know how to support vendors and provide clarification and guidance on the process and functional requirements. They have deep experience in testing and have developed procedures that work, and work well. I guess there may still be a few vendors out there who have not gone through certification, but the vast majority of developers have also been down this road. Familiarity works to reduce anxiety.

• The introduction of gap testing should take a load off vendors. They will not need to retest any unchanged modules that had received 2011 Edition certification. Being able to focus on a subset of modules for development and testing is a plus.

• EHRs for specialists were forced by the “Complete EHR Technology” concept to incorporate functionality that their users would never use and would be excluded during the incentive attestation process. That is now gone with the concept of “Base EHR” and only those addition additional modules that would be used to achieve meaningful use will be required to become certified. This is very big for vendors that support chiropractors, diagnostic radiologists, dentists, and other specialists.

• The “2014 Rule” is a gift from Above. We were all laboring under the apprehension that eligible hospitals had to be using 2014 Edition software by October 1, 2013 and eligible providers by January 1, 2014. Not a lot of time for vendors to get certified, roll out their applications, and then train all users. Sounds a bit stressful.  Now providers, no matter what stage of meaningful use, only need to be meaningful users of 2014 Edition software for 90 days in 2014 to be eligible for incentives. CMS put it out there in black and white: “For 2014 only…..All providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month EHR reporting period.”

The  Accredited Testing Laboratories are anxious for the launch of 2014 Edition testing. One strange certification quirk does seem to complicate their lives. 2011 Edition testing and certification will not end with the onset of the 2014 Edition program. The Office of the National Coordinator for Health Information Technology informs us, “All EHR technology in the pipeline to be completed under the Temporary Certification Program must be completed within six months after the sunset of the program.” So well into 2013 there will be testing for both the 2011 and 2014 Edition certifications.

Jim Tate is founder of EMR Advocate and a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use.