Let there be light: HHS publishes interim final rules on Initial Set of Standards, Implementation Specifications, and Certification Criteria for EMRs

December 31, 2009

Scrambling to meet the end of year deadline set forth in the ARRA HITECH statute, HHS hits the mark with its release of the interim final 45 CFR Part 170, Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology. I will have more to say about the contents over the coming days and weeks as I review it.

My initial reaction is that the content is pretty good — it’s not very precise nor is it actually independently verifiable (yet) but the folks at HHS have done well. The meat of the materials for most EHR firms starts on page 51 with the actual meaningful use and certification requirements map. In yesterday’s press conference Dr. Blumenthal confirmed that no certification body requirements language is yet present and there are no certifying bodies that have been authorized to perform certifications against this criteria. All of that is “coming soon” he said. So, while the interim rules are out, my caution is that you should still not be bullied by EMR vendors because nobody can say that they are HHS certified yet.

HHS Interim Final 45 CFR Part 170, Health Information Technology: Initial Set of Standards, Implementation …

  • hzwerling
    This is one of the criteria for meaningful use...

    “...Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules... ...We propose to describe clinical decision support as a health information technology functionality that builds upon the foundation of an EHR to provide persons involved in care processes with general and person-specific information, intelligently filtered and organized, at appropriate times, to enhance health and health care.”

    Does anyone know precisely what is meant by "Implement five clinical decision support rules?"
  • Cheryl
    What about those institutions already automated? Would their system have to be certified also if it is not?
  • Cheryl -- yes, to receive incentive payments all institutions need to be certified (not just automated).
  • edwina1
    EMR's has been a topic that has been discussed for so long, it makes me wonder if it will ever become a widespread initiative, or if it will be left up to the provider's discretion.
  • It's actually just at the provider's discretion today and into the future -- the only "requirement" comes from Medicare incentives and at some point Medicare penalties (which I don't think will be imposed).
  • Thanks for the EMR information, I have something to read now in 2010. :)
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