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June 21, 2010

Drummond Group’s View of EHR Temporary Certification Program Final Rule

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If anybody was doubting that Drummond Group was ready to be a player in the EHR certification rule, I think this blog post should make them think twice. You can tell from the tone of the post that Drummond Group had been waiting for HHS to issue the final rule so they could get moving.

In the same blog post, Drummond Group provides a short summary of some of the major changes to the rule after the comments:

* Waiving of the 30-day delay in the effective rule. This is by far the most significant “change” in terms of how it impacts vendors, providers and hospitals. Typical procedure for Final Rules is to have 30-day delay after it is on the Federal Register before it becomes “effective”, but this can be waived in certain situations. What this means practically is that once the Final Rule goes into the Federal Register, say around July 1, the Temporary Certification Program will be active and ONC can begin processing applications from organizations like ourselves intending to be ATCBs. ONC does give themselves 30 days to process and approve the application so you still may not see an ATCB officially testing until possibly August.

* Temporary Certification Sunsets No Earlier than 12/31/11. The NPRM had stated that the Temporary Program ends (and the Permanent Program begins) when there is an accredited ONC-ACB. Now, the Temporary Program is given a clear window of operation through the end of 2011, and it may be extended if an ONC-ACB is not found by then. This gives more stability to the Temporary Program.

* All ATCBs Must Support Remote Testing. The NPRM had previously only required support of testing at the local ATCB facility. Now, remote testing is required for all ATCBs. Remote testing can be done either at the development site (vendor) or deployment site (provider or hospital implementation). Based on our DGI surveys, remote testing was by far the preferred method, and ONC also received the same feedback.

Drummond Group also suggests that ONC really did listen to the comments that were given. I don’t doubt this actually. The people I’ve met from ONC really do seem like good people that are trying to do their best within the government limitations. It’s just unfortunate that the government limitations are so onerous.

Now the real fun begins as the various EHR certifying bodies start to appear and EMR vendors get to decide which body they should use.

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