The College of Healthcare Information Management Executives supports the concept of establishing temporary and permanent electronic health records certification programs, but is concerned about whether products can get certified fast enough for providers to receive incentive payments.

"The introduction of two separate certification schemes--one temporary and one permanent--carries a risk of continuing the uncertainty and promoting needless product replacement in the marketplace," the Ann Arbor, Mich.-based trade association says in a comment letter on the proposed certification rule.

CHIME calls for the temporary program to be a provisional or interim one that builds on current certification strategies and is harmonized with the eventual permanent certification process. "We cannot emphasize enough the need for a mechanism that enables the rapid analysis of currently certified programs so that they can be deemed approved after testing against criteria needed to achieve meaningful use."

Recommendations include, among others:

* Clarification is needed in language to define what constitutes a self-developed EHR. Current wording suggests any product modified by a provider or contractor could require certification.

* Changes in certification requirements should be made only when necessary to meet meaningful use evolution or advances in interoperability, not just because a certain amount of time has passed.

* HIT vendors should fully disclose functions for which their products are certified and fully disclose known compatibility issues.

The complete letter is available at

--Joseph Goedert


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