There is an Open Secret: CMS knows it. ONC knows it. Certainly the ONC-ATCBs know it. The Certified Health IT Product List should be approached with extreme trepidation. Let the provider beware. The site clearly states that the list is composed of Certified Complete EHRs and Modules that have met the “certification criteria as identified in the Standards and Certification Rule.”
During the extreme compression of the timeline in preparation for Stage 1 meaningful use it became necessary to create a Temporary Certification program so that certified technology could quickly be made available for providers and hospitals as they prepared for EHR adoption and the CMS Medicare and Medicaid incentive programs. EHRs and Modules are tested and certified based upon the NIST test procedures by the various ONC-ATCBs. As someone who has worked with over 130 EHR vendors on their certification projects I can say I have been impressed with the professionalism and consistency of every ONC-ATCB I have seen. My warning is about the mistaken belief that because an EHR or Module has been listed on the CHPL site it must be good or even serve an intended purpose with any degree of usability. That is simply not the case and everyone knows it.
Stage 1 Certification is not a seal of approval. No one should think the list of Certified Products is a list of equals. Quite a few of the applications are excellent and demonstrate elegant approaches to the electronic documentation of health information. Others are poorly designed, cumbersome, and no provider will ever be satisfied using them. The purpose of certification was not to separate the good from the bad. So tread very carefully and know the list of these applications contains quite a few diamonds, as well as a few snakes.
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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]
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