Drummond Group has recently published an FAQ about EHR certification. I’m guessing that the FAQ will continue to grow over time. They do cover some important topics. Here’s one of the FAQ that I found particularly interesting (and pretty sad too).
Q: My software is developed for a specialty practice (e.g. dental, etc.) and some criteria are not relevant for my customers. To be a Complete EHR, do I still need to certify over all the criteria?
A: There is not a specialized criteria set beyond the general categories of ambulatory or inpatient, and thus specialized software are required to satisfy the same criteria as general EHRs. The concept is that even if a user will not utilize all the features of a certified EHR that the certified EHR must still have this functionality present within it. Regarding criteria that do not fit a specialty’s typical use, ONC address this type of situation in their Standards and Certification Criteria Final Rule. They talk more of the situation with ED/inpatient settings and comments that growth charts are not needed. Here are the relevant sections that show the aggregated comments they received and their response.
Comments. A few commenters noted this certification criterion applies more
directly to specialties that predominantly treat children. For other specialties, this criterion would add unnecessary cost and complexity to many HIT products that they would use. Many commenters suggested that a growth chart component should not be required for EHR technology designed for an inpatient setting, as it is not feasible to track this data in a meaningful way over a long enough period of time in an inpatient setting (which is typically of a short and infrequent duration). A couple of commenters suggested that non-traditional forms of growth charts should be accepted. One commenter suggested that the certification criterion establish a baseline, but should not limit the expansion of this capability to other ages. Other commenters made specific suggestions for different age ranges, such as including children under the age of two and lowering the upper age to ages less than 20 years old (e.g., 18).
Response. As we stated above with respect to the calculation of BMI, we believe
that Certified EHR Technology should be capable of performing this capability
regardless of the setting for which it is designed. Moreover, with respect to whether growth charts should be applicable to Complete EHRs and EHR Modules designed for an inpatient setting, we remind commenters that children’s hospitals qualify as eligible hospitals under the Medicaid EHR incentive program and will also need to demonstrate meaningful use of Certified EHR Technology. We do not preclude Complete EHR and EHR Module developers from designing novel approaches to displaying growth charts. Finally, we concur with the commenter that suggested this certification criterion should be a baseline. We reiterate that this certification criterion establishes a floor, not a ceiling, and we encourage Complete EHR and EHR Module developers to include additional functionality where it will enhance the quality of care that eligible professionals and eligible hospitals can provide.