I receive several inquiries every week from consultants, hospitals and vendors who are trying to understand the differences between "complete" EHR certification--when a vendor's system is certified as a whole--and "modular" EHR certification--when a facility uses individually certified EHR modules to piece together one fully certified system.
It seems that some healthcare facilities opt to purchase or license certain parts from a vendor's certified EHR. But I'm not sure these folks have delved deeply enough into their CMS EHR incentive technology review to realize that this could pose a much bigger problem.
If a vendor presents an application for testing and receives complete certification, its individual modules do not automatically inherit certification as stand-alone modules. Rather, that vendor must obtain separate certification for each individual module.
I imagine that a hefty percentage of eligible hospitals will try to use combinations of complete and modular products to meet Meaningful Use criteria. My advice to those facilities: Conduct a thorough analysis to make sure your bases are covered as far as certification is concerned.
Additionally, vendors should tailor their efforts more toward this crowd. For those vendors with EHRs that have only been certified as "complete," go back to your original ONC authorized temporary certification body as soon as possible, and go through the process of having each module tested for individual certification.
It might be a pain initially, but it will make for happier clients in the long run.
Jim Tate is president of EMR Advocate, LLC and author of The Incentive Roadmap - The Meaningful Use of Certified Technology: Stage 1.