EMR Certification by ONC ATCB

EMR Certification (also called EHR certification) of electronic medical records or electronic health records is required for any vendor to be listed in the ONC Certified HIT Product List.  More companies are realizing that not only general purpose EMRs for Acute Care / Inpatient and Ambulatory, but also specialty systems for Radiology, Oncology, and other applications can and should be certified.  This enables clients to access incentive funds, and avoid penalties later.  It also provides a good housekeeping seal for vendors so that their prospective clients know that their product may reduce the risk of non-compliance.

The Centers for Medicare and Medicaid (CMS) of U.S. Health and Human Services (HHS) Department has stipulated that “…eligible professionals (EPs), eligible hospitals and critical access hospitals (CAHs) participating in Medicare and Medicaid programs…” must “…adopt and successfully demonstrate meaningful use of certified electronic health record (EHR) technology…”

The ability to receive an incentive payment depends upon use of a certified EHR or EMR technology.  It is important to ensure that these entities use an EMR that is certified by an Authorized Testing and Certification Body (ATCB).  The ATCBs are approved by the HHS Office of the National Coordinator for Health Information Technology (ONC) to provide this meaningful use certification.

The process of applying for certification consists of Application, Pre-Testing,Testing, Test Results Review, Certification, and submission for listing on the ONC Certified HIT Product List (CHPL).

There are organizations listed that are authorized by CMS to perform Complete EHR and/or EHR Module testing and certification. These ONC-ATCBs are qualified to test and certify EHRs to the criteria adopted by the Secretary of HHS under Subpart C of Part 170 Part II and Part III as stipulated in the Standards and Certification Criteria Final Rule.

We provide guidance to healthcare companies on achieving ONC ATCB Certification and attesting to Meaningful Use.  Please contact us at [email protected] for complete details on the steps to become ONC Certified.

It is ironic that the emphasis and incentives have focused on EMR implementations but not on ICD-10. The EMR will be the container for the ICD-10 CM diagnosis codes, ICD-10 PCS codes for inpatient, and the CPT-4 codes for Ambulatory procedures.  Some people lose sight of this when implementing their EMR system.  Any reasonable Meaningful Use Assessment should include scope dedicated to how the EMR and new coding standards will impact the revenue cycle.

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Michael F. Arrigo

Michael is Managing Partner & CEO of No World Borders, a leading healthcare management and IT consulting firm. He serves as an expert witness in Federal and State Court and was recently ruled as an expert by a 9th Circuit Federal Judge. He serves as a patent expert witness on intellectual property disputes, both as a Technical Expert and a Damages expert. He leads a team that provides Cybersecurity best practices for healthcare clients, ICD-10 Consulting, Meaningful Use of Electronic Health Records. He advises legal teams as an expert witness in HIPAA Privacy and Security, medical coding and billing and usual and customary cost of care, the Affordable Care Act and benefits enrollment, white collar crime, False Claims Act, Anti-Kickback, Stark Law, Insurance Fraud, payor-provider disputes, and consults to venture capital and private equity firms on mHealth, Cloud Computing in Healthcare, and Software as a Service. He advises self-insured employers on cost of care and regulations. Arrigo was recently retained by the U.S. Department of Justice (DOJ) regarding a significant false claims act investigation. He has provided opinions on over $1 billion in health care claims and due diligence on over $8 billion in healthcare mergers and acquisitions. Education: UC Irvine - Economics and Computer Science, University of Southern California - Business, studies at Stanford Medical School - Biomedical Informatics, studies at Harvard Medical School - Bioethics. Trained in over 10 medical specialties in medical billing and coding. Trained by U.S. Patent and Trademark Office (USPTO) and PTAB Judges on patent statutes, rules and case law (as a non-attorney to better advise clients on Technical and Damages aspects of patent construction and claims). Mr. Arrigo has been quoted in the Wall Street Journal, New York Times, and National Public Radio.

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