Certified EHR getting data from non-certified PM system

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 EHR 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
Jim Tate

Jim Tate

Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected] More posts by Author

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