From our friends at The Kelzon Group.
Here are a few more observations about the recently released Stage 2 proposed requirements:
Evidently ONC decided there was too much confusion about the definition of an EMR/EHR in Stage 1. So now in Stage 2 they have proposed these definitions:
Base EHR (formerly referred to as a ‘Qualified EHR)
1) includes; patient demographic and clinical health
information, such as medical history and problem lists;
2) has the capacity:
i. to provide clinical decision support;
ii. to support physician order entry;
iii. to capture and query information relevant to healthcare
iv. to exchange electronic health information with, and integrate
such information from other sources.
3) Meets the certification criteria adopted by the Secretary at:
§ 170.314(a)(1) through (8); (b)(1) and (2); (c)(1) and (2);
(d)(1) through (8); and (e)(1). These cover – care coordination,
clinical quality measures, and privacy and security.
Complete EHR – can be setting-specific and must meet all adopted mandatory certification criteria for a setting. While a certified Complete EHR (under the proposed revised definition of CEHRT) will likely have more capabilities than are necessary for any single provider to achieve MU, CMS believes the “Complete EHR” designation still has significant market value. They state: “it provides purchasing clarity and assurance to EPs, EHs, and CAHs that the EHR technology they have meet the regulatory definition of CEHRT(Certified EHR Technology); it can support EPs, EHs, and CAHs if they attempt to achieve all MU objectives and measures; and it ensures all the capabilities the Complete EHR includes have been tested and certified to work properly together”. As mentioned repeatedly, CMS is counting on the competitive marketplace to push vendors deeper into certification.
These definitions make little difference to Best of Breed (BoB) vendors who still have to get certified on all parts of your chosen criteria (such as Vitals requiring growth charts), while the health provider in his/her MU attestation can skip these elements if the task is not part of their normal practice or health delivery program.
But CMS also made this important point in the definition of a Complete EHR:
“…that a stand-alone, separate component of a certified Complete EHR
cannot derive “certified” status based solely on it having been included
as part of the Complete EHR when the Complete EHR was certified. This
same principle applies to certified EHR Modules with multiple
capabilities in that the components of the EHR Modules cannot be
separately sold or purchased as certified EHR technology unless they
have been separately certified.”
This means that a full EMR vendor who gets all their modules certified under one certification test, cannot sell a component of that full product as a ‘certified’ product. For example a lab system, that was certified as part of a full EHR, then sell the lab system as a standalone, would not be considered a certified lab system. However, if the provider previously purchased the full EHR, but did not initially install the lab component, but at a latter date latter did install the lab – that would be considered a certified lab system.