The American Health Information Management Association is concerned that tight timeframes pose a challenge for entities that wish to become testing and certification bodies under the proposed rule establishing electronic health records certification programs.

Consequently, the association urges the Office of the National Coordinator for Health Information Technology "to consider accepting CCHIT certification as the bridge to temporary certification to ease the transition, reduce confusion and expedite the establishment of the permanent certification process," according to a comment letter sent to federal officials.

That means that during the process of transitioning to the temporary certification program, electronic health records products currently certified under CCHIT would remain certified until such time temporary certification entities are operational and the products can be recertified under the temporary program.

So, products certified under CCHIT's 2008 and provisional 2011 certification programs would be considered certified as organizations work toward complying with meaningful use requirements to qualify for Medicare or Medicaid incentive payments. Some products certified under 2007 criteria also would serve as a bridge certification depending on the date they were certified, as certifications under CCHIT are good for three years. Any CCHIT certifications that have not expired when the temporary program begins would serve as a bridge.

AHIMA expects CCHIT will apply to be involved in both the temporary and permanent certification programs. "Should CCHIT be so authorized, we are confident that at least one strong certification body will exist during both the temporary and permanent certification programs," according to the letter.

Other recommendations from AHIMA include:

* Core components of certified EHR modules--which are distinct from complete certified EHRs--should interoperate to support standardization, information exchange and meaningful use;

* ONC should establish relationships directly with code set maintenance organizations to identify a standard mechanism for notifying ONC of changes and updates;

* ONC should set a date for the temporary certification program to sunset, but extend the program if no qualified permanent certification entities are yet authorized by the sunset date; and

* Clarification is needed to explain how instances will be handled if a certification entity approved under the temporary program does not pursue permanent status. What happens to the products certified by the temporary entity?

The comment letter is available at

--Joseph Goedert


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