To successfully participate in the EHR Incentive Program in 2011 or 2012, you had to have an EHR that was certified based on the 2011 Edition of the EHR standards, implementation specifications and certification criteria. When CMS released the Stage 2 rule, the Office of the National Coordinator for Health Information Technology (ONC) also released an updated version of EHR standards, implementation specifications and certification criteria, referred to as the 2014 Edition. 2013 participants were able to use technology certified to either or both editions. For 2014, participants were originally required to use EHRs based on the 2014 Edition, regardless of program stage in which the participant intended to participate. However, because of vendor delays in obtaining 2014 Edition certification, CMS created a new hardship exception for 2014 only for eligible professionals or eligible hospitals who were unable to participate in the EHR program because of an inability to fully implement a 2014 Edition EHR as a result of vendor delays in obtaining updated certification. In 2015, participants are expected to use 2014 Edition EHRs.
The 2014 Edition updates the standards, implementation specifications and certification for EHRs to ensure that EHRs are capable of meeting the requirements of Stages 1 and 2. To the terms “Complete EHR” and “EHR Module,” the rule adds a third term: Base EHR. The Base EHR must include fundamental capabilities all practitioners would need to have. To put it into context, the Base EHR is one component of a Complete EHR and could be developed as a Module to be combined with others to meet the requirements for a Complete EHR. This new term allows for more flexibility for physicians and hospitals. The idea is that physicians and hospitals will only need to buy EHRs with as much functionality as they need to participate successfully in the EHR Incentive Program, rather than all of the bells and whistles. Instead, they can purchase a Base EHR and then only enough Modules, interfaces, add-ons, etc. as is necessary to collect information and report data on applicable criteria. For instance, a Base EHR need only be certified to collect and report data on one clinical quality measure (CQM). An EHR Module might be purchased that is certified to report other CQMs as selected by the physician or hospital.
To qualify for participation in the EHR Incentive Program beginning in 2015, you must use an EHR that fulfills all of the requirements of a Base EHR plus has the functionalities needed to meet the menu set objectives you select. A Base EHR must include the functionalities listed here. For additional information on the requirements for EHR certification, visit the ONC website.
The organizations below have been accredited to certify EHRs: