In setting up its just-announced plan for certifying electronic health records, the Office of the National Coordinator set up a two-pronged approach: "˜temporary' certification will be offered to prepare providers for fast-approaching deadlines for first-stage incentive payments in 2011.
"Permanent" certification will subsequently be offered for EHR systems that providers must use in order to qualify for the more sophisticated requirements of meaningful use expected in the second and third stages of the program " in 2012 and beyond.
In either case, ONC must set up a way to sanction organizations to do both EHR testing and certification. For temporary certification, a single organization will both test and certify. For permanent certification, testing and certification will be performed by separate organizations.
In the new scheme, however, not all certifiers will be created equal.
Organizations that want to become authorized to do permanent certification will have to meet tougher " and more expensive " requirements to prove their mettle, according to ONC's proposed rule.
It will also be pricey to become authorized under the permanent certification program. The average initial costs for an applicant to become accredited and apply to be a certifier will be about $20,047.
The permanent certification program will take up to 16 months to put into place and must be operating by the beginning of 2012 so vendor products can be approved and providers can fulfill requirements for second stage meaningful use, according to the proposed rule.
While ONC is still developing the components of permanent certification, it is fast tracking the process for accrediting organizations to perform 2011 testing and certification. That's because certified products must be available in a matter of months -- this fall -- according to the rule.
That's cutting it thin, as temporary certifiers will likely not be in place until this May or June, ONC according to ONC's description of the rule.
Yet ONC expects no more than three applicants for the temporary program based on what it has observed in the marketplace. For this group, cost is not likely to be a factor, however. ONC has estimated it will cost $2,300 to apply to become a temporary certifier and tester for 2011.
ONC anticipates about 93 commercially developed and open source EHRs (and 50 EHR functional modules) will be tested and certified under the temporary program.
That program will end when ONC has authorized at least one certification organization under the permanent program.
Amidst all the unknowns, one thing is certain: The Certification Commission for Health IT (CCHIT) which since 2006 has been the only organization authorized to certify EHRs, will submit an application to be a certifier, "as soon as they are ready to accept them," said Alisa Ray, its executive director.
The release of the proposed rule will "reduce the uncertainty that the health care community has experienced white awaiting this additional information," she said.
