Friday, December 2, 2011

Meditech Connect - A Great Resource!

Dynamic Health IT recently discovered a great, new website called Meditech Connect and is proud to be the first vendor to join the Meditech Connect network. The site, ‘built by meditech users for meditech users’, is a great resource to anyone who works with any version of the Meditech systems. Meditech Connect’s membership has reached over 700 members and is rapidly gaining more support every day.

The Meditech Connect site offers something for everyone. Once you are a member (and membership is free!) you can join groups, read and post blogs, start discussions in the group forums, post job listings, participate in live events, and much more!

Meditech Connect offers Groups such as NPR and RD Report Writers, Old Faithful Magic Users, 6.0 Users, etc. This allows the members to get involved in topics they are interested in and can benefit from versus being included in all discussion. Once you join a group, you can post to the Discussion Forum and see other members in the group. You can also send a message to the group which is delivered to members in an email.

Blogs are also available on Meditech Connect. A hot topic on the Meditech Connect site in recent weeks has been the ‘Meditech 6.0 experience’ due to many articles coming out about 6.0 falling short on software and integration. With different Meditech Connect users weighing in on this topic, it has been interesting to read the differing opinions of the members. This information could be extremely useful information if you were contemplating an upgrade to 6.0.

Another informative service that Meditech Connect offers is Events that the site coordinates and hosts. For instance, on November 11th Meditech hosted Report Writer Friday’s, a social event to allow fellow NPR Report Writer’s to ‘get together and talk shop’. This is a fun way for members to ask questions of other experts or just network with users.

If you are a Meditech consultant, hospital, or vendor, you should definitely check out this site and take advantage of this great resource!

Wednesday, September 7, 2011

The Direct Project – Underlying Technology

As mentioned in our earlier post The Direct Project - Gluing EHR's Together , according to, the goal of the Direct Project is an:

“Easy-to-use, internet-based tool that can replace mail and fax transmissions of patient data with secure and efficient electronic health information exchange”

The title of that post may have been a bit misleading, since it left out the healthcare consumer (formerly called the “patient”). The consumer is a key player in all of this. In any case, how does the Direct Project team propose to attain this goal? One of their disclaimers states that the Direct Project:

“Focuses on the transport of health information”, not the larger issue of interoperability. Interoperability has three prerequisites:
  • Transport: How messages will be sent and received (Direct Project)
  • Semantics: The structure and format of their exchanged content (e.g. CCD document)
  • Vocabulary: What terminology/coding systems will be used (e.g. SNOMED)

The Direct Project only addresses transport – packaging the content of messages, securing it, and transporting it from a sender to a recipient. Also, it leverages technology that is already widely-used. Four criteria are focused on:
  1. Packaging message content
  2. Confidentiality and integrity
  3. Authentication of sender and receiver
  4. Routing
Those criteria are addressed as follows:
1. Packaging: The Direct Project uses MIME with optional XDM. MIME is a widely-used universal standard for email. Cross-Enterprise Document Media Interchange (XMD) is a “push” technology devised by the IHE consortium that complements their existing XDS Integration Profile “pull” technology for cross-enterprise document sharing by providing for transfer of confidential health information via email, CD-R and USB memory devices.

XDM focuses on managing the interchange of documents that healthcare enterprises (from individual physicians up to multi-hospital systems) have decided to share between the patient and the patient’s care providers, or between care providers. This enables better interoperability between Electronic Health Records (EHRs) and Personal Health Records (PHRs).

2. Confidentiality and integrity. Message content is kept confidential through S/MIME encryption and signatures. S/MIME is a standard for public key encryption and signing of MIME data.

3. Authenticity of sender and receiver. X.509 digital signatures are used.

4. Routing. Message routing is handled via SMTP.

None of this stuff is revolutionary technology. It can be obtained through open source libraries and there are commercial products like ZixMail that already meet these criteria. The benefit will be its adoption as a widely-used standard. To learn more about the technical details, the Direct Project's technical specification is available on-line.

Thursday, July 28, 2011

EPs - Steps to MU Incentive Payments

I've been reading article after article about Meaningful Use and the difference between the Medicaid and Medicare incentive programs.  Much of this data is scattered and not always easy to understand.  The purpose of this blog is to highlight the important details of the Medicare and Medicaid incentive programs available to Eligible Professionals through the HITECH Act and American Recovery and Reinvestment Act of 2009.   The process to receive incentive payments can be broken down into seven distinct steps.  These steps are examined below:

Step 1. Determining Eligibility: The first step for an EP is to determine which program, Medicare or Medicaid, they are eligible for, if any.  The program requirements and definitions are very different among the two programs.  For example, to qualify for the Medicaid program, an EP must have 30% or more Medicaid patients (20% - 30% for Pediatricians).  CMS's Eligibility Wizard can be found here.  This will run through a number of questions to determine in which program an EP is eligible to participate.

Also very different among the two programs are the incentive payment amounts and the schedule of payments. 
  • Medicaid program:
    • Higher total incentive payment = $63,750
    • No late start penalty
    • Payments are distributed over six years 
    • Prior to 2015, if an EP fails to meet meaningful use measures, they can skip that year and not lose a layer of payments
    • Can take advantage of A/I/U
    • Medicaid incentive payments are made by the States
    • NOTE: This program is administered individually by each State - find out information about your State's program here.
  • Medicare program:
    • Lower total incentive payment = $44,000
    • Medicare payments are based on 75% of the total Medicare allowed charges submitted no later than two months after the end of the calendar year
    • Late start penalty by 2013
    • Payments are distributed over five years
    • If an EP fails to meet meaningful use measures, they lose the incentive payment for that year.
    • Extra 10% available for EPs practicing predominantly in a Health Professional Shortage Area (HPSA) 
Step 2. Register: EPs that would like to participate in either Incentive program should register with CMS.  CMS encourages possible participants in the incentive programs to register as early as possible.  EPs can register for the program without a certified EHR system but cannot attest.  As part of the registration process, the EP must designate who will receive the incentive payments.

EPs will need the following information during registration:
  • National Provider Identifier (NPI)
  • National Plan and Provider Enumeration System (NPPES) User ID and Password
  • Payee Tax Identification Number (only if you choose to reassign your benefits)
  • Payee National Provider Identifier ( only if you choose to reassign your benefits)
  • Third Party Registration - A user registering on behalf of an EP will need an Identity Access Management System (I&A) User ID and Password.  To obtain an account, visit the I&A Security Check.
When you have all of your required information, visit the CMS registration website.  CMS has provided a Medicaid Program User Guide and Medicare Program User Guide to assist individuals through registration.

In order to participate in the Medicare Incentive program, EPs must also be enrolled in the Provider Enrollment, Chain and Ownership System (PECOS).   EPs can access PECOS by using the User ID and password assigned to them when they applied to the NPPES for their National Provider Identifier (NPI).

Step 3: Select an Incentive Program: EPs are eligible to participate in either the Medicare or Medicaid incentive programs but they cannot participate in both program simultaneously like Eligible Hospitals.  As mentioned earlier, there are many differences between the programs eligibility requirements as well as the incentive payments so EPs should thoroughly examine their patient population to decide which program would be more beneficial.  Incentives for EPs are based on the individual EPs numbers, not the numbers of the entire practice collectively.  Also, all the doctors in a practice do not need to participate in the same incentive program.  

If an EP is participating in the Medicaid program, the requirement for Year 1 is only to adopt, implement, and/or upgrade (A/I/U) to certified EHR technology. Therefore, there is no reporting period for the Year 1.

It is important to note that EPs can switch between the Medicare and Medicaid programs one time after the initial incentive payment has been made before 2015 .

Step 4: Obtaining Certified EHR Software: In order to eligible to apply for incentive programs, EPs must be using certified EHR software.  ONC has created a certification process to certify vendor software and allow EPs to self-certify homegrown systems. EPs can obtain certified EHR software in one of three ways: purchasing a Complete EHR, purchasing Modular EHRs to meet all HITECH requirements, or self-certifying their own software.

A complete EHR has been tested and certified by an Authorized Testing and Certification Body (ACTB) and meets all of the government’s requirements as a whole. This means that if an EP implements a complete EHR, they can register for an Incentive Program and begin attesting to Meaningful Use criteria once they have met meaningful use measures for a consecutive 90-day reporting period.

A modular EHR allows an EP to combine certified modules from different systems in order to meet the government requirements for a certified EHR. For modular certification, the ONC Certification Numbers for each of the certified products must be collected and submitted to ONC as a ‘package’ solution. ONC reviews the package solution and if it meets all requirements for a certified system, they issue a new certification number which is used to attest Meaningful Use (MU).

EPs can also self-certify a homegrown system or an outdated version of a vendor system.  Modular products also allow an EP to buy some certified modules in addition to self-certifying their system to meet the requirements on the remaining modules. 

ONC lists all products that are certified as Complete or Modular on the Certified Health IT Product List (CHPL).

Step 5: Meeting Meaningful Use Measures: To be a 'meaningful user' of certified technology means to use the EHR in a meaningful manner to improve the quality of health care.  Once an EP has certified technology in place, they should review the incentive program Meaningful Use Measures to ensure that all necessary work flow procedures are in place to capture all required data.   

EPs must meet 15 core meaningful use measures, 5 of 10 menu meaningful use measures, and 6 clinical quality measures (3 core or alternate core, and 3 of 38 from menu set).  All objectives have a specific measure; some measures are percentage based and some are a yes/no attestation.  Some measures have exclusions because they are not relevant to a certain provider's practice or patient population.  An example of an exclusion is an EP who sees no patients that are 13 years or older will be excluded from the measure to 'record smoking status for patients 13 years old or older.'

Step 6: Attest to Meaningful Use Measures:   An EP must complete a continuous 90-day reporting period within the calendar year of the incentive program in order to attest. So, if an EP wishes to begin their incentive program in 2011, they must complete their 90-day reporting period before December 31, 2011. Once an EP has completed their 90-day reporting period, they are ready to attest to meeting the meaningful use measures.  An EP has sixty days after the close of a calendar year to submit their attestation data to CMS. 

Visit the Attestation page on the CMS website for more information.  CMS has also provided an Attestation User Guide, Attestation Worksheets and a Meaningful Use Attestation Calculator.

After reporting on all meaningful use measures in the CMS registration and attestation system, data will immediately be submitted and the user will be notified if the submission was successful.  Upon notification that the submission is complete and successful, the EP is qualified to receive their incentive payment.

Payments for the Medicare incentive program can be expected approximately 4 - 8 weeks after attestation.  EPs should note that if they have not met the $24,000 threshold for allowed charges at the time of attestation, CMS will hold the incentive payment until the threshold is met.  Incentive payments are based on the charges from the entire calendar year, not just charges from the 90-day reporting period.  If an EP has still not met the threshold by the end of the calendar year, the payment is held 60 days after the end of the calendar year to allow all pending claims to be processed.

SUCCESS!....but don't forget Step 7......

Step 7: Prepare for potential audits: Any EP that attests to meaningful use to receive incentive payments for either the Medicare or Medicaid program is subject to auditing from CMS. In order to prepare yourself for a potential audit, retain all supporting paper and electronic documentation used during attestation.  EPs should also keep documentation supporting their Clinical Quality Measures (CQM).  This documentation should be saved six years after attestation.  If, during an audit, an EP is found to be ineligible for the incentive payment, the payment will be recouped by CMS.  CMS plans to create an appeals process and will post more information on this process to their website soon.

Tuesday, July 26, 2011

The Direct Project - Gluing EHR's Together

Most of us believe that the push towards Electronic Health Records (EHR’s) is a good thing and a necessary step along the road toward making each person’s EHR available for any healthcare provider who might need to treat that patient, whether the patient is in Los Angeles or Prairieville, LA. This goal of universal EHR availability is called the Nationwide Health Information Network (NHIN). Providers are certainly making progress towards the NHIN, prodded along by the governments “carrot and stick” approach under the HITECH Act (Meaningful Use) Stage 1 and the availability of better technology and more tech-savvy healthcare providers.  
Another step toward NHIN is enabling EHR’s to talk to one another. Until recently, communication between EHR’s from different vendors was a bit like people located in different countries and speaking different languages, not fluent in each other’s language, trying to converse by telephone. There is a standard called HL7 but it was designed to exchange transactional data, not an entire health record. HITECH Stage 1 provided for the use of either the CCD or CCR a standard, which is, effectively, a universal language. One other piece seems to have been neglected until this year, however – and was omitted from HITECH Stage 1 – a secure standard for exchanging CCD/CCR clinical data. Think of this piece as the phone line in the international conversation.
Although that was a major oversight, it is being quickly (relative to how quickly things happen in healthcare IT) addressed through something called the “Direct Project” ( According to a February 2, 2011 News Release from, the goal of the Direct Project is an:
“easy-to-use, internet-based tool that can replace mail and fax transmissions of patient data with secure and efficient electronic health information exchange”
Towards this end, there have been committees, meetings, etc. and some standards have emerged.
The Direct Project has widespread support. According to Dr. Doug Fridsma, on his March 21 “HealthIT Buzz” posting, “support for the Direct Project represents approximately 90% of market share covered by the participating health IT vendors”.
In the next post, we’ll address the technological underpinnings of the Direct Project.
  • CCD/CCR –The ASTM Continuity of Care Record (CCR) and the Continuity of Care Document (CCD) HL7 standard. The HL7 CCD standard actually resulted from a collaborative effort between HL7 and ASTM to harmonize the data format between ASTM’s Continuity of Care Record (CCR) standard and HL7’s Clinical Document Architecture (CDA) standard.
  • HITECH – In February of 2009, the American Reinvestment and Recovery Act (ARRA) allocated $19 billion in funding for hospitals and clinics that make “meaningful use” of certified Electronic Medical Record (EMR) systems. The Health Information Technology for Economic and Clinical Health (HITECH) Act lists criteria for eligible hospitals and vendor software

Monday, July 11, 2011

What is ONC?

ONC is the Office of the National Coordinator for Health Information Technology. The Office of the National Coordinator operates within the Office of the Secretary for the U.S. Department of Health and Human Services (HHS). ONC’s primary focus is the coordination and implementation of health information technology and electronic exchange of health information.  
According to ONC’s website, their mission includes the following:
  • Promoting development of a nationwide Health IT infrastructure that allows for electronic use and exchange of information that:
    • Ensures secure and protected patient health information
    • Improves health care quality
    • Reduces health care costs
    • Informs medical decisions at the time/place of care
    • Includes meaningful public input in infrastructure development
    • Improves coordination of care and information among hospitals, labs, physicians, etc.
    • Improves public health activities and facilitates early identification/rapid response to public health emergencies
    • Facilitates health and clinical research
    • Promotes early detection, prevention, and management of chronic diseases
    • Promotes a more effective marketplace
    • Improves efforts to reduce health disparities
  • Providing leadership in the development, recognition, and implementation of standards and the certification of Health IT products;
  • Health IT policy coordination;
  • Strategic planning for Health IT adoption and health information exchange; and
  • Establishing governance for the Nationwide Health Information Network.
The position of the National Coordinator was established in 2004 by George Bush’s administration and legislatively mandated by the HITECH Act. Farzad Mostashari, a physician and public health expert, currently holds the position of National Coordinator. Mostashari took the position in July 2009.
ONC has played a large role in the Medicare and Medicaid Electronic Health Record Incentive Programs established under the HITECH Act. ONC wrote the Final Rule documentation, a staged approach to adopting capabilities, standards and specifications required for achieving meaningful use. To date, only documentation on meeting the measures for Stage 1 of meaningful use have been released to the public. Furthermore, ONC was tasked with establishing a program for the testing and certification of health information technology as being in compliance with certification criteria to meet defined meaningful use requirements. ONC wrote testing requirements, test cases and test tools with NIST and established ONC-Authorized Testing and Certification Bodies (ATCB’s) to perform the testing and certification of EHR systems. ONC has selected six organizations to serve as ATCB’s. ONC also maintains the ONC Certified HIT Product List (CHPL), a list of certified Inpatient and Ambulatory EHR systems. The CHPL can be viewed here.

Tuesday, July 5, 2011

What is a CAH?

A CAH is a critical access hospital.  
A CAH is a hospital that is certified to receive cost-based reimbursement from Medicare. The reimbursement that CAHs receive is intended to improve their financial performance in order to reduce hospital closures. Each hospital must review its own unique situation to determine if becoming a CAH would be beneficial. CAHs are certified under a different set of Medicare Conditions of Participation which are more flexible than the acute care hospital Conditions of Participation.
The following is a list of criteria that a hospital must meet in order to be considered a CAH: 
  • Located in a state that has a State Flex Program
  • Designated by the State as a CAH
  • Located in a rural area
  • Provide 24-hour emergency care services
  • Provide no more than 25 inpatient beds; a CAH can also operate a rehabilitation or psychiatric unit with up to 10 beds
  • Have an average annual length of stay of 96 hours or less
  • Located more than 35 miles from the nearest hospital or CAH (or more than 15 miles in areas with mountainous terrain or only secondary roads)
  • Participate in Medicare
In addition to receiving cost-based reimbursement from Medicare, some other advantages of becoming a CAH are having access to Flex Program grant funds, flexible staffing and services, and having the CAH network with acute care hospitals for support.

Thursday, June 16, 2011

What is an EP?

An EP is an Eligible Professional. Different types of EPs are eligible for the Medicare and Medicaid programs. Unlike eligible hospitals, EPs are not eligible to participate in both the Medicare and Medicaid programs. Below is a listing of the eligible professionals in each program:
Eligible Medicare EPs include:
  • Doctors of Medicine or Osteopathy
  • Doctors of Dental Surgery or Dental Medicine
  • Doctors of Podiatric Medicine
  • Doctors of Optometry
  • Chiropractors
Eligible Medicaid EPs include:
  • Physicians
  • Nurse Practitioners
  • Certified Nurse - Midwife
  • Dentists
  • Physicians Assistants who practice in a Federally Qualified Health Center (FQHC) or Rural Health Center (RHC) that is led by a Physician Assistant
Medicaid EPs also must have a minimum of 30% Medicaid patient volume (20% minimum for pediatricians) or practice predominantly in a FQHC or RHC and have at least 30% patient volume to needy individuals.
Hospital based providers, defined as a provider who provides 90% or more of their services in either the inpatient or emergency department of a hospital, are not eligible for the Medicaid or Medicare programs.

Tuesday, June 7, 2011

What is an EHR?

An EHR is an Electronic Health Record. It is an electronic record of patient health information collected over one or more encounters in any healthcare setting. Generally, the following information is included in the patient health information:
  • Demographic Information
  • Problem Lists
  • Medication and Allergy Lists
  • Vital Signs
  • Medical History
  • Immunization Information
  • Lab and Radiology Reports
  • Billing Information
EHRs have the ability to generate a complete record of a clinical patient encounter, as well as aiding other healthcare-related activities through the system’s interface including evidence-based decision support, quality management, and outcomes reporting.
The implementation of EHRs has several advantages including reducing costs, improving quality of care, promoting evidence-based medicine, and improving record keeping and mobility. Some disadvantages include the cost of implementing EHR systems and the time required to learn new systems.

Thursday, May 26, 2011

How does NIST fit into HITECH Certification and Meaningful Use (MU)?

NIST is the National Institute of Standards and Technology and was formerly known as the National Bureau of Standards (NBS) between 1901 and 1988. NIST is a measurement standards laboratory which is a laboratory of metrology, the science of measurement, which establishes standards for a country or organization. NIST is a non-regulatory federal agency within the U.S. Department of Commerce. NIST's mission is to promote U.S. innovation and industrial competitiveness by advancing measurement science, standards, and technology in ways that enhance economic security and improve quality of life. Their core competencies include measurement science, rigorous traceability and development and use of standards.

The American Recovery and Reinvestment Act of 2009 encourages eligible professionals, eligible hospitals and critical access hospitals to move toward the use of electronic health records. The ARRA legislation calls for the Office of the National Coordinator (ONC) for Health IT, in consultation with NIST, to establish a program for the testing and certification of health information technology as being in compliance with certification criteria to meet defined meaningful use requirements.

In collaboration with ONC, NIST developed testing requirements, test cases, and test tools in support of the health IT certification program. NIST’s approved test procedures can be viewed here. Questions about the test procedures can be sent to NIST at

What is ARRA?

ARRA is the American Recovery and Reinvestment Act of 2009. This Act, commonly referred to as ‘the Stimulus’ or ‘The Recovery Act,’ was passed by Congress on February 17, 2009. ARRA was the government’s response to the economic crisis. The Act includes a number of projects and programs but its immediate goals were the following:  
  • Stimulate economic activity and invest in the nation’s long-term growth
  • Provide assistance to those most impacted by the economic recession
  • Produce new jobs and protect existing jobs
  • Increase levels of accountability and transparency in government spending
ARRA contains general incentives related to health care information technology in, such as the creation of a national health care infrastructure, and specific incentives designed to encourage the adoption of certified electronic health record (EHR) systems among hospitals and providers. In addition to the programs related to the healthcare industry, ARRA also addresses tax incentives for individuals and companies, and programs related to education, infrastructure, transportation, energy infrastructure, housing, scientific research, government buildings and facilities, etc.
To read more about ARRA and track the spending related to this Act, visit

Tuesday, May 24, 2011

What is the HITECH Act?

The Health Information Technology for Economic and Clinical Health (HITECH) Act is part of the American Recovery and Reinvestment Act of 2009 (ARRA) which was passed February 17, 2009. According to the Final Rule documentation, two titles of the ARRA , Title IV of Division B and Title XIII of Division A, constitute the Health Information Technology for Economic and Clinical Health Act or HITECH Act. Title IV amends the Social Security Act to establish incentive payment programs for eligible professionals, eligible hospitals, critical access hospitals and Medicare Advantage Organizations to encourage these entities to adopt meaningful use of healthcare information and certified electronic health records.

The bill has four main goals to improve health information technology:
  • Give the government a leadership role in the development of standards in the general use of and the exchange of electronic health information. These standards are intended to improve quality and coordination of care.
  • Invest billions of dollars in healthcare infrastructure and incentive programs to reward eligible professionals (EP) and hospitals that use certified systems to electronically exchange patient information.
  • Save billions of dollars by improving quality and coordination of care and reducing medical errors and duplicative care.
  • Strengthen requirements on security and privacy related to healthcare information.
While the U.S. Government has been encouraging the healthcare industry to move toward electronic health records since 2004, they received limited response. President Bush set aside millions of dollars to fund demonstration projects to ‘test the effectiveness of health information technology and establish best practices for more widespread adoption in the healthcare industry’ and established the Office of the National Coordinator for Health Information Technology to lead the way. The HITECH Act, put in place by the Obama Administration, has established a less voluntary approach since there are financial incentives for those who participate and financial penalties for those who choose not participate or do not adopt in a timely manner.

Friday, May 20, 2011

Common Acronyms for HITECH Certification and Meaningful Use (MU)

While reading through all of the HITECH Certification and Meaningful Use (MU) articles, procedures, laws, etc., one difficulty I've found in fully understanding the documentation is due to the number of acronyms used by the writers. So, I thought it might be helpful to get a list of the most common acronyms and not only define what they stand for, but write a short piece on each to give people an idea about how each fits into certification and meaningful use (MU).
Here's my list:
  • HITECH - Health Information Technology for Economic and Clinical Health Act
  • ARRA - American Recovery and Reinvestment Act of 2009
  • NIST - National Institute of Standards and Technology
  • ONC - Office of the National Coordinator for Health Information Technology
  • CMS - Centers for Medicare & Medicaid Services
  • EHR - Electronic Health Record
  • EP - Eligible Professional
  • CAH - Critical Access Hospital
  • PQRI - Physician Quality Reporting Initiative
  • A/I/U - Adopt, Implement, or Upgrade
  • CCN - CMS Certification Number
  • CQM - Clinical Quality Measure
  • HIT - Health Information Technology
Over the next week or so I will post the definitions of these acronyms - tune back in to read more about these important certification and MU concepts.
If there is an acronym that I left off that you think should be included in the list, post a comment and I will research it for you!

Thursday, May 5, 2011

Complete EHR vs. Modular EHR

In order for providers and hospitals to attest to ‘Meaningful Use’ and receive incentive payments, they will first need a Certified Electronic Health Record (EHR).  EHR's can be certified in one of two ways: Complete EHR Certification or Modular EHR Certification. 
Complete EHR
A complete EHR has been tested and certified by an Authorized Testing and Certification Body (ACTB) and meets all of the government’s requirements as a whole.  This means that if an eligible professional (EP) or hospital implements a complete EHR, they can register for the Medicare EHR Incentive Program and begin attesting to Meaningful Use criteria once they have met meaningful use for a consecutive 90-day reporting period.  EP’s and hospitals will need to register on the CMS website to attest Meaningful Use (MU).
Unfortunately, with a complete EHR, you cannot buy individual pieces of the system and assume that the pieces are certified as modules.   
Modular EHR
A modular EHR allows an EP or hospital to combine certified modules from different systems in order to meet the government requirements for a certified EHR.  For modular certification, the ONC Certification Numbers for each of the certified products must be collected and submitted to ONC as a ‘package’ solution.  ONC reviews the package solution and if it meets all requirements for a certified system, they issue a new certification number which is used to attest Meaningful Use (MU).
A modular approach may be seen as a more complex solution due to the work required ensuring all modules integrate together, but the modular approach also has a number of advantages:
·    Complete EHR's can be very expensive compared to the modular approach.
·    If an EP or hospital already has a module(s) in place that staff is familiar with, it may be inefficient and costly to train the staff on a new system.  
·    Transferring data to a new system may be time consuming and costly.
·    The modular approach allows the EP or hospital to use their vendor of choice for each application. 
A modular approach also allows an EP or hospital to buy certain certified modules in addition to self-certifying their homegrown system to meet the requirements on the remaining modules. 
Using a Complete EHR and Certified Modules
The ONC Regulations FAQ 9-10-014-1 clarifies the rules further to include the possibility of using a certified module in addition to possessing a complete EHR if the modular function is preferred or superior to the function in the complete EHR. 
Meeting the definition of Certified EHR Technology can be achieved in numerous ways; including using EHR technologies that perform duplicative or overlapping capabilities (if that is what an eligible health care provider chooses to do) so long as all of the applicable certification criteria adopted by the Secretary have been met and those EHR technologies are certified. Consequently, an eligible health care provider could use both certified capabilities (e.g., CPOE) at the same time in two different sections/departments of its organization. The eligible health care provider would however be responsible for reconciling the data between those two certified capabilities for purposes of reporting to CMS or the States.

Dynamic Health IT
Dynamic Health IT is ready to assist you or can take the lead role in your certification process.  We offer practical and effective solutions, including software addressing HITECH Certification criteria which can easily be integrated with your current systems.  We have expertise with the criteria and certification methodology used by the most popular ATCB’s – CCHIT and Drummond Group.