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.