Certified EHR Technology Stage 2

One of the truly “listened and learned” enhancements of the stage 2 criteria is defining certified EHR technology. The new criteria is now called the 2014 Edition while the current final rule we are under will be known as the 2011 Edition. In the 2011 Edition an eligible professional, eligible hospital, and critical access hospitals have to purchase complete EHR systems to successfully attest to meaningful use. It does not matter if you don’t use or need the functions of parts of the EHR, if it is included to make a “complete EHR” you must purchase it.

The new criteria takes a more practical and flexible approach to the issue. The proposal for the 2014 Edition is to consider a Base EHR. EPs, eligible hospitals, and CAHs must have EHR technology with capabilities certified to meet the definition of a Base EHR. Here is the criteria for a Base EHR:

• Includes patient demographic and clinical health information, such as medical history and problem lists
• Capacity to provide clinical decision support
• Capacity to support physician order entry
• Capacity to capture and query information relevant to health care quality
• Capacity to exchange electronic health information with, and integrate such information from other sources
• Capacity to protect the confidentiality, integrity, and availability of health information stored and exchanged

From there, as the ONC is describing it, you build outward. The EP, eligible hospital, and CAH would need to have EHR technology with capabilities certified for meaningful use core objectives and measures for the meaningful use stage they are reporting and attesting to unless they can meet an exclusion. Likewise, for menu objectives, their EHR technology would only need the capabilities certified for the MU stage they are reporting and attesting to.

There would now be three ways to meet the new certified EHR technology (CEHRT) definition. You can purchase a Complete EHR, a combination of EHR modules that do all the functions needed, or a single EHR module. The proposed compliance will be acceptable in both stage 1 and 2. If you are reporting in stage 1 in calendar years 2012 or 2013, EPs, eligible hospitals, and CAHs must have EHR technology that is 2011 Edition certified or equivalent 2014 Edition EHR certification criteria adopted. If you are reporting in Stage 1 or 2 in calendar year 2014 the participants must have EHR technology which includes a Base EHR that has been certified to the 2014 Edition criteria and would support objectives and measures to successfully attest to meaningful use.

Current Notice of Proposed Rulemaking  for Stage 2 Meaningful Use in comment periods.

1. Health Information Technology: Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology, 2014 Edition; Revisions to the Permanent Certification Program for Health Information Technology
2. Medicare and Medicaid Programs; Electronic Health Record Incentive Program-Stage 2