Drummond Group EHR Certification FAQ

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.

About the author

John Lynn

John Lynn

John Lynn is the Founder of the HealthcareScene.com, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference, EXPO.health, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.

1 Comment

  • Interesting that Drummond’s client EHR developer used dental as an example of the specialized applications they author. With such limited coverage by Medicare of dental procedures CMS tells the public:

    “… you need to remember that Medicare will only cover such procedures if it is performed by a dentist who is on the hospital staff in Part A coverage or performed by a physician under Part B coverage.”

    For that developer unless its other EHR offerings support specialties and subspecialties with a high proportion of Medicare and/or Medicaid reimbursement … I wonder if it is cost effective to seek ARRA certification from CCHIT or Drummond … when that certification is meaningless to the provider?

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