EHR Incentive Q&A: Do modular certified EMR’s qualify for meaningful use and also qualify for full incentive payouts?

Chris asked the following question:
Do modular certified EMR’s qualify for meaningful use and also qualify for full incentive payouts?

Modular certified EHR software can qualify for meaningful use and the EHR incentive payouts. Although, they can’t do it on their own. Although, if you combine the modular certified EHR with other modular or full certified EHR software, then you can qualify. Clear as mud huh?

The good thing is that you can go to the ONC CHPL website and select the certified EHR software which you use and it will tell you if combined it meets the criteria.

So, for example, maybe you have a modularly certified EHR that is certified for everything but ePrescribing. You could then also purchase a certified ePrescribing software and together they would be considered a complete certified EHR that would qualify you for the EHR incentive money.

At least this is my understanding of the intent. I’m sure there are going to be lots of little intricacies without clear answers.

UPDATE: There was some discussion in the comments about whether you had to have a complete EHR or only one that had the modules you use to show meaningful use. Thanks to Jim Tate for finding the HHS reference that says you do have to have a complete EHR even for the modules which you’ve excluded or menu set objectives which you didn’t select.

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John Lynn

John Lynn

John Lynn is the Founder of, 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.

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  • So as a follow on say an EMR is modularly certified, only has sufficient optional modules to allow the physician to technically qualify for MU, but is not fully certified (recall there are a number optional criteria that need to be met from a larger menu) Will this allow the physician to gain the stimulus funding, we at Mitochon believe this is not correct but know that some other vendors in the industry are planning to modular certify but claim the physician will achiev full MU with their system. They are also a Free EMR vendor and we hope they service the smaller physician practice market with integrity as we will when we are Free and fully certified in a few short weeks.

  • My understanding is that the EHR or combination of EHR components need to become a complete certified EHR. Although, it won’t surprise me if some EHR vendors try to get away with the modular certification. Especially during the self attestation phase.

  • The modular thing makes complete sense. Forcing an EHR vendor to be a jack-of-all-trades is not smart.

    Centricity is a perfect example of a modular EHR. There is no eprecribe built in, yet when you purchase an EHR that can “tap” into the Centricity database and function as one, then you meet that MU requirement.

  • Passing MU is an all-or-nothing deal*. Consequently, all of your required in-use ONC certified modules must aggregate to passing all the requisite Core and Menu Set criteria (including the core, alternate core, and 3 chosen optional CQM).

    Moreover, you must pass all 20 measures (15 core, 5 menu). Passing 19 of 20 doesn’t get you 95% of the money, it gets you $0.
    * It should be noted that there are some “exemptions” that constitute “passing.”

  • Hi John,
    Your answer is not exactly right.

    For eligible professionals to qualify they must meet all CORE meaningful use requirements and at least 5 MENU meaningful use requirements. The EHRs’ modules certified have a relationship with each of these measures.

    So, if the professional’s EHR modules use is certified in all the related CORE meaningful use measures and at least 5 Menu, it is possible for them to use one system and get incentives.

    Otherwise, you are correct about them combining systems to meet their CORE and 5 MENU.

    Hope that helps.

  • Have you seen this in writing anywhere? On the ONC-CHPL it says the following:
    To obtain a CMS EHR Certification ID, follow the steps outlined below:
    1. Select your practice type by selecting the Ambulatory or Inpatient buttons below
    2. Search for EHR Products by browsing all products, searching by product name or searching by criteria met
    3. Add product(s) to your cart to determine if your product(s) meet 100% of the required criteria
    4. Request a CMS EHR Certification ID for CMS registration or attestation from your cart page

    The 3rd part at least to me implies that the EHR products that you’ve added to your cart (which are the ones you use) have to meet 100% of the required criteria. Certainly there could be a debate on whether the required criteria is just the CORE and 5 MENU items, but I believe that the required criteria for an EHR vendor or combination of vendors is to meet all CORE and MENU items. Otherwise, I don’t think ONC would have required EHR vendors that are “Complete EHR” certified vendors to satisfy all CORE and MENU items.


  • The 100% is for “complete certification” rather than modular.
    So if you use an EHR that was certified as “complete” they met all criteria (which happened to map all meaningful use measures…the CORE and MENU). So no worries unless you do not meet the letter of the meaningful use item in the attestation process. If you add to your cart 3 hodge podge modular they may or may not cover all CORE and at least 5 MENU.

    For example: Just using a certified product is not enough. Each measure the eligible professional must meet must be met. So if the CORE or MENU item requires 50% of their patients have smoking status recorded as structured data, They cannot report 49% and expect the $ because they have a certified EHR.

    What makes it confusing is defining what eligible professionals must do VS what the EHR product they are using must do.

    Eligible professionals (not hospitals) must use certified technology for all CORE meaningful use objectives and MEASURES and at least 5 MENU objectives and MEASURES. CMS knows if your fudging on attestation because they have the list of technologies that map to each measures.

    All EHR’s test and seek certification have modules. These modules map to meaningful use and some are bundled like security.

    There is going to be some surprises when denials begin to hit because we have done a poor job of educating the eligible professionals. They are so confused.

    What professionals need to do:

    Get a list of CORE and MENU items and ask me to map each module certified to them (we can produce this as a table for your readers). The gov. should have done this.

    In the table, they will see:

    Meaningful use Objective/Meaningful Use Measure Required to meet /Technology Module Mapped Certified?/Menu or Core Item.

    You can total all CORE and 5 Menu and see if you are on target with the technology. Again, if you use a completely certified product, your only worries are meeting your specific measures.

  • “The gov. should have done this.”
    True, but why would the gov make it easy to get money from them?

    All one ever has to do is look at the tax system and you’ll understand why this is so screwed up.

    Taking it to a more basic level: when the TSA dropped my laptop, it took me 6 months to get half that laptop value paid to me.

    They were just hoping I’d go away for $500.

    This is the same with this reimbursement…make it complex enough that many/most just give up or don’t “pass” and less money gets paid out.

  • To receive the incentives EPs must meet 15 Core and 5 of 10 Menu MU objectives. However, there is the potential for exclusions so some EPs might only have to meet much fewer of the objectives to qualify for Stage 1. Even if EPs exclude or defer any MU objectives, they still must have ‘Complete EHT technology” which is a “Complete EHR” or a total collection of Certified Modules or a combination of the two. I hope this helps.

  • That’s my understanding as well Jim. The key is that they have to have a complete EHR. Doesn’t matter how they get to complete (by pieces or all in one), but it has to be complete.

    Although, it seems some are arguing that they don’t have to have a complete EHR, but only an EHR with the modules they use to show meaningful use.

  • Hopefully this CMS guidance will clarify the issue that EPs must have compete certified technology even if they are able to exclude or defer some MU objectives. “Please note that EPs must have complete certified EHR technology (or a complete set of certified EHR modules) capable of supporting all of the core and menu set objectives, including any objectives for which the EP can claim an exclusion and menu set objectives the EP does not select.”

  • Jim,
    Thanks for finding an official reference. Glad to see that my description in the post above was correct. I’ll add a link to the reference in the post.

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