All Vendors Exit Stage Left

Stage 1 product certifications end this year, September 30 for Inpatient products and December 31for
Ambulatory. In many of my conversations with systems suppliers who are considering the next step in
ONC Certification, they refer to it as ‘Stage 2 Certification’, can’t blame them, done it myself.
Remember it all started with Stage 1 two years ago, so naturally you would expect Stage 2 to follow
Stage 1. But with the Feds and ONC it could never be that simple.

When ONC issued the final Stage 2 rules last year they made a very purposeful and distinct break
between Stage 2 Meaningful Use, and the vendor test criteria. Instead of referring to ‘Stage 2 Test
Criteria’ they labeled them the 2014 Edition Test Criteria. Providers are subject to Meaningful Use
Stage 2 rules, while vendors seeking certification come under the 2014 Edition of Test Criteria. There’s
a real difference, some pretty big ones.

The ONC now refers to your Stage 1 certification as the ‘2011 Edition Test Criteria’, no more Stage 1.  

Typically a systems/software firm starts by carefully reviewing the provider MU Stage 2 attestation
criteria since they are all over the web. Next, they try to translate the MU list to product requirements or
test criteria and then confusion follows. Although the MU attestation criteria for Stage 2 resembles the
Certification test criteria there are differences. For example, one big difference is a provider needs to
attest to about 25 MU criteria and some Quality Measures to get the Stage 2 money. But you as a
vendor need to pass on about 40 certification test criteria and nine QMS elements to become 2014
Edition Certified.  

Another example under Stage 2, is a provider must attest to completing a HIPAA compliance risk
analysis, that’s just one question, (answer is ‘yes’, subject to audit of course). But for a vendor
completing a certification test under the 2014 Edition you must address eight very specific tests for
privacy and security.

A related question ties back to what I mentioned at the top of this piece, your current Stage 1
certification ends this year. Actually ONC says your 2011 Edition certification ends and you must test
out on the new 2014 Edition to continue to sell certified systems /software. But as of July 1st there were
only four (4) vendors that have been successful in achieving 2014 Edition Full EHR Inpatient
Certifications, while under Stage 1 there were dozens. 2014 testing is turning out to be a real challenge
for many vendors, far more difficult than I think ONC expected. Some think ONC will extend the Stage 1
vendor certifications beyond 12/31/13 if they do not get enough vendors through 2104 Tests by
September. That would seem a likely solution, but given Dr. M’s pointed comments about vendors
‘gaming the system’, I doubt it.   

The reason ONC made the break between certification test criteria and MU attestation criteria is when
they decided to extend Stage 1 of provider attestation into 2014 (originally it was to die in 2013) they
did not want to extent the vendor certifications as well. Why? I guess they just wanted to keep your feet
to the fire!  Which raises the next  question; How can a provider attest to Stage 1 in 2014, when all the
vendor certifications for Stage 1 die in three or six months? Simple, ONC now allows the provider to MU
attest under Stage1 using a 2014 Certified system. If you have clients or prospects that have not
attested to Stage 1 and plan to do so in 2014, they must be running your 2014 Edition certified
software for at least ninety days in 2014.  

It seems that ONC has taken vendors off the Stage, and reduced them to simply an old Edition.

Frank Poggio
The Kelzon Group
June 27, 2013
Copyright 2013, All rights reserved.

This article first published in HISTalk, July 12, 2013