More answers for certified EHR devotees

I was recently asked a few more questions about certification, and I’ll share my answers with the HIT community.

1.  Per your first blog about certification, I understand that all hospitals and eligible providers need to have certified EHR technology, which means that they must acquire software (complete or modular) that supports all 25 Meaningful Use functions (15 core and 10 menu set). Since  Meaningful Use only requires attestation for 5 of the 10 menu set items, does the unused technology need to be installed and used?

The answer is yes. In the Certification final rule, the term is  “utilize” – so it has to be installed and used. Providers just report on those functions they select from the menu set.

Here the relevant sentence from the Meaningful Use Final Rule  —  “Under all three EHR incentive programs, EPs, eligible hospitals, and CAHs must utilize ‘certified EHR technology’ if they are to be considered eligible for the incentive payments.”

Here are additional specifics from the three regulations:

• ARRA – must use a qualified system to get incentive
• Meaningful Use final rule – We are adopting the ONC definition of Qualified Electronic Health Record in 45 CFR 170.102 [has to meet all criteria adopted by the secretary]
• Standards and Certification final rule – Certified EHR Technology…. Qualified meets all certification criteria adopted by the secretary

The flexibility in the menu set is reporting on Meaningful Use measures in Stage 1, not the flexibility to use an incomplete EHR.

2.  NIST testing procedure for Section 170.302 (a) Drug-drug, drug-allergy interaction checks includes the language ‘Provide certain users with the ability to adjust notifications provided for drug-drug and drug-allergy interaction checks.” What do you think about that?

I agree that drug-drug interaction notification requires tuning to avoid alert fatigue. Sometimes even minor interactions with trivial clinical consequences pop up, interrupting workflow. There should be tuning allowed to adjust such alerts to the level of severity optimized for a given practice. However, I cannot think of a use case in which an allergy alert should be altered/suppressed.

The test procedure developed by NIST is faithful to the certification criterion adopted in the Standards and Certification final rule. ONC has received comments on this issue from several stakeholders and is reviewing them.

3.  In many ambulatory settings, clinicians use a hospital information system to route medication prescriptions to in hospital pharmacies. Hospital-based systems are more likely to use HL7 for in hospital message routing instead of NCPDP, the standard used for e-prescribing. Is this acceptable?

The Standards and Certification final rule does not specify the standards to be used for in hospital medication workflows, so HL7 routing from ambulatory care clinics to an internal outpatient pharmacy is fine. However, in order to be designated as “Certified EHR technology,” the hospital information system must also have the capability (used or unused) of routing prescriptions to external retail or mail order pharmacies using NCPDP Script.

I hope this is helpful.

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