An Alternative to EHR Certification for Hospitals…Is it for you?

CCHIT (, as many of you know, is one of the ONC ( authorized testing and certifying bodies (ATCB). Long before the advent of Meaningful Use, CCHIT offered its own certification for EMR software which is still available. Last week, CCHIT announced another possibility for hospital certification: EACH–EHR Alternative Certification for Hospitals.

Because CCHIT recognizes that many hospital settings have a variety of software solutions, they are now offering an alternative method to obtain certification to meet meaningful use. You may benefit from this solution if your facility falls into one of the following categories:

  • Complex hospital where one vendor rarely has a solution for the complex system needs of the facility, thus the IT solution involves multiple vendor’s products.
  • Facilities with home-grown systems designed to fill a specific need.
  • Facilities with legacy systems where the vendor decided to not seek certification.
  • Facilities with systems that are certified for modules and there are gaps to certify the system as a complete EHR.

There are three phrases of EACH, and they are not free. You must complete phase one and two before you can apply for phase three. When you successfully complete phase three, CCHIT will forward your information to ONC for inclusion in its Certified Health IT Product List (CHPL).

  • Phase 1: Orientation (become familiar with the process)
  • Phase 2: Readiness tool (gap analysis of your system)
  • Phase 3: Testing and certification (cost varies with complexity).

There may be financial aid available for critical access hospitals.

The EACH program for hospitals was announced on January 18, 2011, and there are plans to roll out a similar option for physician offices in the second quarter of 2011.

Is this for you?  If your current system is certified as a complete EHR, you are golden.  If not, conduct your own return on investment to see if it makes sense to pursue this option.  If Meaningful Use is in your future, it may be more cost effective than changing systems.  For more information on this program, go to or click here.

Ginger Wooster, MBA, MT (ASCP)
Director of Regulatory Affairs & Applications Specialist
Orchard Software Corporation

Comments (0) Jan 20 2011

A Sneak Peek at ONC’s Proposed Criteria for Stage 2 Meaningful Use

On Wednesday, January 12, 2011, the ONC published a request for comments on their proposed requirements for Stage 2 Meaningful Use. Comments will be accepted until 5 pm on February 25, 2011. You can find the document, which also contains instructions for submitting your comments at:

Because Stage 2 is a stepping stone to Stage 3, some Stage 3-proposed criteria are included in this document. However, ONC would like comments for Stage 2 only at this time.

Until the comment deadline, all comments will be available for public inspection at Follow the search instructions on that website to view public comments.

Stage 2 Criteria of interest to laboratories include:

  • CPOE (by licensed professional) for at least 1 medication, and 1 lab or radiology order for 60% of unique patients who have at least 1 such order (order does not have to be transmitted electronically)
  • Incorporate lab results as structured data (40%): This will be moved from menu to core objectives, but only where results are available.
  • Submit reportable lab data for Eligible Hospitals (EH): This will be moved from menu to core objectives.
  • Submit reportable lab data for Eligible Providers (EP): Ensure that reportable lab results and conditions are submitted to public health agencies either directly or through their performing labs (if accepted, and as required by law).

Stage 2 also includes new criteria that were not part of Stage 1. While not specific to laboratories, they may be of interest:

  • 30% of visits have at least one electronic EP note, which can be scanned, narrative, structured, etc.
  • 30% of EH patient days have at least one electronic note by a physician, NP, or PA, which can be scanned, narrative, structured, etc.
  • 30% of EH medication orders automatically tracked via electronic medication administration recording
  • 80% of patients offered the ability to view and download via a web-based portal, within 36 hours of discharge, relevant information contained in the record. Inpatient summaries include: hospitalization admit and discharge date and location, reason for hospitalization, providers, problem list, medication lists, medication allergies, inpatient encounters. Data are available in human-readable and structured forms.
  • EPs: online secure patient messaging is in use
  • Patient preferences for communication medium recorded for 20% of patients.
  • List of care team members (including PCP) available for 10% of patients in EHR.
  • Record a longitudinal care plan for 20% of patients with high-priority health conditions.

And finally, ONC is considering adding a group reporting option to allow group practices to demonstrate meaningful use at the group level for all EPs in that group.

I’m sure you all have opinions on this issue. Please take advantage of the comment period, now until 5 pm on February 25, 2011, to let your voice be heard.

Ginger Wooster, MBA, MT (ASCP)
Director of Regulatory Affairs & Applications Specialist
Orchard Software Corporation

Comments (0) Jan 14 2011

ONC Issues Final Rule for Permanent Certification Program for Health Information Technology

The Office of the National Coordinator for Health Information Technology (ONC) issued a final rule on January 3, 2011, to establish the permanent certification program for health information technology.  The permanent certification program provides new features that will enhance the certification of health information technology, which is a core requirement for Meaningful Use incentive payments under the HITECH Act.

The temporary certification program will continue to be in effect until it sunsets on December 31, 2011, or at a later date when the processes necessary for the permanent certification program to operate are completed.  The transition to the permanent certification will have no effect on existing certifications and should be as seamless as possible.

New features of the permanent certification program include:

  • Certification bodies will be accredited by one ONC-Approved Accreditor (ONC-AA). Certification bodies authorized under the temporary certification program (ONC-ATCB) will not automatically become ONC-ACBs, they must first obtain accreditation from the ONC-AA.
  • An ONC-ACB will have to renew its status every three years.
  • An ONC-ACB may also be accredited by National Institute of Standards and Technology (, through its National Voluntary Laboratory Accreditation Program ( to test health information technology for purposes of the permanent certification program in order to serve as a “one-stop-shop.”
  • Certification bodies authorized by the National Coordinator (ONC-Authorized Certification Bodies or ONC-ACBs) are required to conduct post-certification surveillance.
  • ONC-ACBs are permitted to perform “gap certification.”  When the Secretary adopts new and/or revised certification criteria in future rulemakings, gap certification will be available as a more efficient certification option to have previously certified complete EHRs and EHR modules tested and certified to only the applicable new and/or revised certification criteria.

For more information about the permanent certification program and the final rule, please visit

For more information about the Office of the National Coordinator for Health Information Technology, please visit

To read the final rule, please visit

Ginger Wooster, MBA, MT (ASCP)
Director of Regulatory Affairs & Applications Specialist
Orchard Software Corporation

Comments (0) Jan 07 2011