Recently proposed changes in how electronic health record (EHR) software will be certified, combined with uncertainty around how software use by specialties will be measured, leave behavioral healthcare providers less clear about how to proceed. But software vendors say organizations with funding available to implement EHR systems continue to move ahead cautiously.
For the past few years, volunteers representing behavioral healthcare providers and software vendors have been working diligently with the Certification Commission for Health Information Technology (CCHIT) to develop guidelines for EHRs used in behavioral health settings. As members of the nonprofit CCHIT's Behavioral Health Work Group, these volunteers have surveyed the market and developed a list of over 100 software features to support the specialized needs of behavioral health, such as treatment plans. To support an eventual BH software certification, they have looked at everything from standalone certification of large, full-featured packages to certification for software “plug-in” modules that add functions to other, certified ambulatory EHR packages.
Overall, CCHIT has made considerable progress with vendors and providers because it has been clear for several years that federal funding would be tied to the use of certified systems.
But in August, a report by the Office of the National Coordinator's HIT Certification and Adoption Workgroup (ONCHIT) dropped a bombshell. The group report criticized elements of CCHIT's approach, arguing, among other things, that CCHIT paid too much attention to complex EHR features and functionality and not enough to interoperability. It recommended that Health & Human Services (HHS) take responsibility for establishing certification criteria and that it focus those criteria on HHS objectives for meaningful use of EHRs, notably security, privacy and interoperability.
The report also suggested that multiple organizations, not just CCHIT, ought to be involved in certifying that vendors and providers meet the EHR standards. (However, CCHIT is expected to provide a preliminary or “gap” certification that health IT systems are HHS-qualified until the final meaningful use regulation is published in December.)
“This changes everything,” said Mike Morris, president of Anasazi Software Inc. and treasurer of the Software and Technology Vendors Association (SATVA). “HHS is going to take the reins, and the nature of CCHIT may change dramatically.”
The turbulence resulting from the ONCHIT report only adds to the uncertainties already faced by community behavioral health organizations (CBHOs) and software developers. At present, CBHOs are not among the groups eligible to receive the $20 billion in Medicare and Medicaid incentive funding available from the ARRA HITECH Act for demonstrating meaningful use of an EHR. And, despite the efforts of CCHIT and its specialized work groups, there is as yet no HHS definition for meaningful use of EHRs in behavioral health or any other specialist care niche.
It is more likely that, in the rule-making process, the Centers for Medicare and Medicaid Services (CMS) will apply a subset of the EHR meaningful use measures developed for general medicine as a starting point for certifying specialist EHRs. But no one knows for sure. Another possible scenario is that HHS will provide a new, simplified EHR certification and that CCHIT will provide a richer, separate seal of approval for more complex software features.
Steven Daviss, MD, chair of the Department of Psychiatry at the Baltimore Washington Medical Center, co-chairs the CCHIT Behavioral Health Work Group. As his team prepares to deliver its behavioral health software guidelines to CCHIT for a review and comment period, he admits the atmosphere is uncertain. “People are trying to read the tea leaves. There's a real moving target for the meaningful use definition,” he said, “and with the community behavioral health organizations not eligible for the incentives, there's a question of whether we should even bother to try to align with them.”
To understand the impact of these changes, specialty medical software vendors and their customers may have to wait until the general HHS EHR certification is fully defined in early 2010, after which HHS will likely address the more complex EHR requirements of specialist providers.
Sue Reber, CCHIT marketing director, noted that in fields ranging from behavioral health to long-term care, there are reasons for an ongoing certification process that go beyond qualifying for EHR incentives under the ARRA HITECH Act. “There is a need to create a common floor for what the software should do,” she said.
CCHIT behavioral health certification guidelines are expected to enter a public comment period this fall, which should allow for their completion in spring 2010. According to Anasazi's Morris, these guidelines should be helpful as providers consider and select software products. But for now, it is unclear what the differences between HHS and CCHIT certification will be.
“There is confusion in the marketplace,” he said. “Even with the best of intentions, it is difficult for vendors to address this when the target changes every week. The picture in behavioral health just keeps getting cloudier.”
David Raths is a freelance writer.
When will behavioral health become ‘meaningful'?
So far, the meaningful use of EHRs as defined by ONCHIT extends as far as hospitals and primary care physicians. This definition includes such capabilities and measures as computerized provider order entry, or the percentage of patients with LDL under control, or the percentage of high-risk cardiac patients using aspirin prophylaxis.