CCHIT Certification Update for Electronic Health Records:  Is Your Agency Up to the Gamble?

By Kaye Eisele

Should behavioral health specialists follow Certification Commission for Healthcare Information Technology’s (CCHIT’s) suggestions to gain certification even before ONC has officially defined what constitutes meaningful use in all electronic health records (EHRs), including mental health and substance abuse records? 

For now, the answer may be yes. After all, CCHIT has been at it for a fair amount of time, and they take their accreditation and certification very seriously. Not only that, CCHIT currently stands alone as an EHR certifying body.

But behavioral healthcare providers also take having certified technology seriously. Most simply aren’t sure if they’re the gambling kind. In other words, they may have to rely on the CCHIT’s certification process while awaiting the maturation of electronic health records’ official certification and meaningful use EHR definitions. Will behavioral healthcare providers assist in the definition?  Should they go ahead already and contract CCHIT-approved vendors? Or are they better off taking a wait-and-see approach? Heads are spinning, and certification processes are pending, but the actual deadlines for certification haven’t budged – leaving many behavioral healthcare providers uncertain which way to turn next. 

CCHIT:  Exclusive or Not?

Will the CCHIT continue to be exclusive to the EHR qualifying process for federal stimulus funding? The CCHIT reports on its website: "[Organizations other than CCHIT] may also seek and obtain recognition once an accreditation process has been defined, but the timing and details of that have not been disclosed by the ONCHIT (Office of the National Coordinator for Health Information Technology)."

CCHIT also reports, "Waiting until the HHS rulemaking process is completed in mid-2010 raises a high risk that providers will not be able to implement EHR technology in a timely way to obtain 2011 and even 2012 incentives. We believe changes in the HHS requirements between now and then will have much less impact than would a delay in EHR implementation."

By all accounts, behavioral healthcare technology providers seem earnest in their efforts to obtain certification, as they understand the importance of CCHIT’s seal of approval. In fact, most seem compelled to obtain certification. To revisit the certification process, CCHIT is suggesting that providers may not want to wait for the final rule-making processes to evolve, leaving many providers -- and not just those within the behavioral sciences -- in a quandary. 

CCHIT Conflicts of Interest

On top of that, the issue of business ties between some EHR vendors and CCHIT board members has yet to be addressed. Some see this as a conflict of interest, but this could also be the least of anyone’s worries right now. Although, as time goes on, this pink-elephant issue may prove messy and should make providers take pause. (Note to self:  Does my CCHIT-endorsed vendor have any ties to CCHIT board members that may result in a conflict of interest within the certification process, current or past?  Does it have the potential to bring forth eventual reimbursement issues?)

Savvy Certification Process

So what exactly should a savvy behavioral healthcare provider look for if it has not yet chosen a vendor (or wants to switch) in order to ensure proper EHR certification? And can a vendor that is certified by CCHIT certify all providers within an office or facility?

Let’s answer the last question first: Yes. Additionally, if your CCHIT-accredited vendor has provided and completed all mandated accreditation processes, you and your colleagues may very well be good to go. That’s good news, right? Well, for the most part. While CCHIT is currently the only agency deemed to be capable of achieving EHR certification, additional EHR accreditation and certification organizations may be revealed for your mental health/substance abuse treatment private practice or organization.  So, to answer the first question, if you are not quite on board with CCHIT, or are not the gambling kind for that matter, it may be smart to wait and see how the process of inclusivity for certifying bodies evolves.

Vendors Also Uncertain

It's not just healthcare providers who experience challenges surrounding CCHIT certification; EHR vendors also face pressures from CCHIT. For instance, CCHIT Chairman Mark Leavitt, who will retire from his position in October 2010, recently challenged vendors. He said, "Choose the risk you want to take. Go ahead now [with a CCHIT review] and have an extra year to implement, with a small risk that there will be some gap in which EHR systems would have to be updated to receive final certification."

CCHIT Addresses Concerns

With the impending deadlines for EHR certification ever nearing, behavioral healthcare providers may feel compelled to heed this warning suggested by Leavitt.  The public was invited to comment on any and all issues surrounding EHR certification and that deadline was December 17, 2009.  The outcomes of this public comment period are largely unpublished at press time, but CCHIT addressed some specific questions that the public had regarding many EHR issues -- most notably testing dates for certification, costs surrounding the process, and whether those who received certification in prior years will continue to have certification.  On its website, the CCHIT said:
           Testing dates are assigned on a first come, first serve basis. While you can choose a   
           date, we expect all applicants to complete certification within 90 days. Testing will begin
           as soon as applicants are received in October 2009. Full payment is required with the 
           application. While a vendor may tell individual customers that they have applied for
           certification, they may not use terms such as "Certification Pending" in marketing 
           materials. The application period will be continuous as of October 7 through September
           30, 2012.

Other important information from CCHIT’s website includes:

• The application window will remain open continuously for the 2011-2012 cycle of certification, until September 30, 2012
• It is in a vendor’s interest to apply for and attain certification in time for its customers to implement an EHR and demonstrate meaningful use objectives that will qualify them for ARRA incentives available during that period.
• For CCHIT Certified® certification, compliance with 100 percent of 2011 criteria will be required.
• For Preliminary ARRA certification, the Foundational Security and Privacy criteria must be met, plus criteria for any other modules for which certification is sought. The Certification Facts label will note which meaningful use objectives are supported.

CCHIT Certified programs are still under development for various areas, including behavioral health, clinical research, dermatology, and long term and post acute care. Vendor applications will open in summer 2010 for these. What’s more, a behavioral health certification program is under development and projected for launch in mid-2010, according to CCHIT’s website.

Full Meaningful Use Definition Tied to ER Certification
 
ONCHIT Certification staffers are feeling the pressure as they steadfastly want to help develop a definition of meaningful use of EHRs by 2010. According to Government Health IT, the national coordinator, Dr. David Blumenthal, said recently, "We are beginning to think about what follows and the implementation of programs under way and some of the thorny issues we will be dealing with in the implementation process."

In January, ONCHIT will hear what states have to say about perceived barriers to health information exchange. Following that, a group of experts will involve patients and families and listen to their views on health data exchange. This information will be utilized for Meaningful Use standards, for which physicians and hospitals must comply in order to receive Medicare and Medicaid subsidies for 2011 EHRs. Meaningful Use definitions will coincide with EHR certifications.

Other hearings in early 2010 will be conducted by Dr. Paul Tang, co-chair of ONCHIT’s Health IT Policy Committee, which will give providers and other organizations a voice in the development of 2013 and 2015 criteria for Meaningful Use.

Certification Gamble Continues

So the gamble continues when considering the Medical Group Management Association’s Denver conference earlier this year when vendors doubted another certifying body other than CCHIT would enter the picture. As executive vice president of NextGen Healthcare Information Systems Scott Decker said, "We're anticipating not much competition.” He added that it would cost too much to develop a program that could compete with CCHIT, even though the Health Information Technology (HIT) Policy Committee has urged additional EHR certifying bodies.

Beyond who will ultimately certify EHR solutions, the fact remains that behavioral health products do not have a current certification program. While CCHIT anticipates June 2010 certification programs, only one will be addressing the unique behavioral health systems and that will be for standalone systems. Also on the horizon are public comment results in response to the Behavioral Health Workgroup's comprehensive Behavioral Health CCHIT Certification criteria, which will be available in February 2010. Many behavioral healthcare providers will be ready to hear those results, especially providers who are not the gambling kind and wish to learn more before making certification choices that will result in huge future impacts in effective and quality patient care, as well as ample financial reimbursement based on certification.