The Secretary of Health and Human Services should consider creating information technology certification programs beyond those being adopted for complete electronic health records systems and EHR modules, according to the Electronic Health Network Accreditation Commission.
Farmington, Conn.-based EHNAC, which certifies transactions processors for meeting specific performance criteria, in a comment letter makes the case for certification of other I.T. services. These could include claims clearinghouses and value-added networks, financial services, electronic prescribing, and health information exchanges, among others.
The organization understands the reasoning for the proposed certification rule's definition of an accredited certification body that is limited to certifying EHRs and EHR modules. EHNAC, however, is concerned that a "minimum" definition in a final rule will eliminate itself and other entities from consideration if HHS designates organizations to certify HIEs.
Bringing in additional entities is important to the overall goal of rapidly 'e-Enabling" the health care environment, according to EHNAC. "To that extent, the Secretary should consider a full range of certification activities on their own merits, each being integral to the goals and objectives of HITECH," the comment letter states. "Moreover, if and when the Secretary does (as we believe she should) require Health Information Exchange Certification/Accreditation, we want to ensure that entities other than ONC-ACBs will be considered for that role. To that extent, we urge specific provisions in the proposed rule to allow for that possibility."
Other recommendations in the comment letter include:
* Evaluate the temporary certification program for a year before issuing a proposed rule for design of a permanent program;
* Eliminate the requirement for a certified laboratory to produce evidence of meeting technical criteria;
* Eliminate the ability to conduct unannounced visits to organizations being certified. "We have found that organizations need the time to prepare and gather appropriate documentation, staff and resources to undergo rigorous accreditation/certification review. While unannounced visits are designed to prevent some 'cheating,' we have consistently shown that they are not a fair judge of what a product or organization is capable of actually accomplishing."
* Eliminate the requirement for a certifier to have its own facility and permit on-site certifications; and
* Permit more time for organizations to develop certification programs. "Based on our experience, ONC is not allowing enough time before the fall of 2010 for organizations to develop such a process, even on a temporary basis. Therefore, this severely limits the candidates that can apply to be the temporary certification organizations."
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