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Chiropractic News

August 2011

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Modular vs. complete EHR certification

SannaKnowing which EHR solution is best for you can make all the difference in meeting “meaningful use” requirements.

By Mark Sanna, DC, ACRB Levell II, FICC

One of the most important decisions you will confront over the next few years is which electronic health record (EHR) to adopt for your practice.

Making the wrong decision not only places the $44,000 in American Recovery and Reinvestment Act (ARRA) incentive dollars per eligible provider at risk, but could also jeopardize your financial future, as reimbursement shifts from the relative value model of the past to the qualitative value model of the future.

The decision of which EHR to chose is even more complex due to the lack of clarity provided by some vendors about whether their product is “certified,” and what level of certification it has obtained. Verifying EHR certification is an essential first step in your decision-making process.

You can’t begin to qualify for ARRA incentive dollars — let alone achieve “meaningful use” — if the EHR you select does not have a certification number from the Office of the National Coordinator (ONC) for Health Information Technology.

Complete EHR certification

One of the key requirements that many decision makers find confusing is the distinction between “modular” and “complete” certified EHRs. If you are unsure of the level of certification of the EHR system you are considering, or whether it is certified at all, check the ONC’s website for the “Certified Health IT Products List” (

If an EHR is listed as having obtained “complete EHR” in the product classification column, that HER is good to go for a provider practicing in the appropriate practice setting (either ambulatory or inpatient).

For most practitioners in an outpatient office setting, if your EHR is designated “complete EHR – ambulatory,” you know it’s certified for ARRA incentives by the ONC.

Check your version number

Once you have determined that your EHR is complete, check the version number of your product. Look at the product version number column and make sure the version you’re using, or considering purchasing, matches the certified version.

If it’s not, upgrade your software. This is because the Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as a part of ARRA, meant that additional functionality had to be added to virtually every EHR on the market — and that means upgrades to include that functionality in your practice.

Making the decision to purchase an EHR with complete certification is relatively easy compared to the potential pitfalls that await those who chose to go with modular certification.

Modular EHR certification

Modular certification allows products to be partially certified. In other words, they don’t need to meet all the criteria for meaningful use. This means that only a subset of the requirements

are certified — those criteria and features the vendor feels are appropriate for the product, and for which they have submitted the product for testing.

For example: An office note generating product. These products are designed to help facilitate the process of documentation and are not designed as comprehensive EHR systems.

These products may only have modular certification for those functions that are part of the product’s scope. They would not typically include other EHR features such as immunization registry tracking, patient reminders, or e-prescribing.

ARRA incentives

Modular certification, however, can make sense in several ways. You should be able to use, or continue to use, products that meet your specific needs and function well in your practice. However, this can cause confusion when you need to determine whether your EHR system is certified for meaningful use.

Products that receive modular certification do not qualify for ARRA incentive payments unless they are augmented by one or more secondary products that enable the provider to achieve meaningful use.

In order to receive ARRA incentives, you are responsible for ensuring that your EHR solution is certified. For products that have received complete certification, this is straightforward. However, for modular products, it becomes your responsibility to assemble a complete solution from the modular products you have chosen to implement.

The pitfalls of “package solutions”

For modular certification, collect the ONC certification numbers for each of the products in use, and then re- submit these numbers (and products) to ONC as a “package solution.”

The products will then be assessed by ONC as a comprehensive solution, and if they meet all of the necessary criteria, ONC will issue a new certification number, specific to that combination of products, that will be used by you to attest to meaningful use.

If you are using an office note- generating specific EHR, you’ll need to purchase and implement a minimum of one other secondary product to provide the missing features necessary for meaningful use and they’ll need to then submit all of the EHR packages to ONC for adjudication.

The burden of proof

The burden of proof is on you to be sure your modular EHR “package of products” can be certified to meet meaningful use. When using modular products, it is not the vendors’ responsibility to do so.

The road to meaningful use will be more challenging if you’re choosing modularly certified products. You will need to become familiar with the ONC certification requirements and be sure that your package solution has all the bases covered.

MarkSannaMark Sanna, DC, is the CEO of Breakthrough Coaching. He is a member of the Chiropractic Summit, the ACA Governor’s Advisory Board, and a board member of the Foundation for Chiropractic Progress. He can be reached at 800-723-8423 or through

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