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 Arrigo, an expert witness, and healthcare executive, brings four decades of experience in the software, financial services, and healthcare industries. In 2000, Mr. Arrigo founded No World Borders, a healthcare data, regulations, and economics firm with clients in the pharmaceutical, medical device, hospital, surgical center, physician group, diagnostic imaging, genetic testing, health I.T., and health insurance markets. His expertise spans the federal health programs Medicare and Medicaid and private insurance. He advises Medicare Advantage Organizations that provide health insurance under Part C of the Medicare Act. Mr. Arrigo serves as an expert witness regarding medical coding and billing, fraud damages, and electronic health record software for the U.S. Department of Justice. He has valued well over $1 billion in medical billings in personal injury liens, malpractice, and insurance fraud cases. The U.S. Court of Appeals considered Mr. Arrigo's opinion regarding loss amounts, vacating, and remanding sentencing in a fraud case. Mr. Arrigo provides expertise in the Medicare Secondary Payer Act, Medicare LCDs, anti-trust litigation, medical intellectual property and trade secrets, HIPAA privacy, health care electronic claim data Standards, physician compensation, Anti-Kickback Statute, Stark law, the Affordable Care Act, False Claims Act, and the ARRA HITECH Act. Arrigo advises investors on merger and acquisition (M&A) diligence in the healthcare industry on transactions cumulatively valued at over $1 billion. Mr. Arrigo spent over ten years in Silicon Valley software firms in roles from Product Manager to CEO. He was product manager for a leading-edge database technology joint venture that became commercialized as Microsoft SQL Server, Vice President of Marketing for a software company when it grew from under $2 million in revenue to a $50 million acquisition by a company now merged into Cincom Systems, hired by private equity investors to serve as Vice President of Marketing for a secure email software company until its acquisition and multi $million investor exit by a company now merged into Axway Software S.A. (Euronext: AXW.PA), and CEO of one of the first cloud-based billing software companies, licensing its technology to Citrix Systems (NASDAQ: CTXS). Later, before entering the healthcare industry, he joined Fortune 500 company Fidelity National Financial (NYSE: FNF) as a Vice President, overseeing eCommerce solutions for the mortgage banking industry. While serving as a Vice President at Fortune 500 company First American Financial (NYSE: FAF), he oversaw eCommerce and regulatory compliance technology initiatives for the top ten mortgage banks and led the Sarbanes Oxley Act Section 302 internal controls I.T. audit for the company, supporting Section 404 of the Sarbanes Oxley Act. Mr. Arrigo earned his Bachelor of Science in Business Administration from the University of Southern California. Before that, he studied computer science, statistics, and economics at the University of California, Irvine. His post-graduate studies include biomedical ethics at Harvard Medical School, biomedical informatics at Stanford Medical School, blockchain and crypto-economics at the Massachusetts Institute of Technology, and training as a Certified Professional Medical Auditor (CPMA). Mr. Arrigo is qualified to serve as a director due to his experience in healthcare data, regulations, and economics, his leadership roles in software and financial services public companies, and his healthcare M&A diligence and public company regulatory experience. Mr. Arrigo is quoted in The Wall Street Journal, Fortune Magazine, Kaiser Health News, Consumer Affairs, National Public Radio (NPR), NBC News Houston, USA Today / Milwaukee Journal Sentinel, Medical Economics, Capitol ForumThe Daily Beast, the Lund Report, Inside Higher Ed, New England Psychologist, and other press and media outlets. He authored a peer-reviewed article regarding clinical documentation quality to support accurate medical coding, billing, and good patient care, published by Healthcare Financial Management Association (HFMA) and published in Healthcare I.T. News. Mr. Arrigo serves as a member of the board of directors of a publicly traded company in the healthcare and data analytics industry, where his duties include: member, audit committee; chair, compensation committee; member, special committee.

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