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Should Certification Programs Require Real World Testing?

Under stage II of the meaningful use program, providers and hospitals need to demonstrate the capability to share medical information with other healthcare organizations. Stage II requirements are more rigorous and interoperability is a major area of focus. EHR software products need to prove that they have sharing capabilities in order to be certified.


Even though many applications have been 2014 certified for use in stage II by providers, many organizations are unable to exchange data reliably and consistently with others. This is the case even when both parties are using the latest and certified versions of their respective systems. Sometimes the necessary data is sent successfully but the receiving entity cannot process it and vice versa. In other cases, the exchange process generates errors after which doctors are forced to process data manually.


But why is this process not working in spite of the certification process put in place by CMS? The answer may lie in the certification procedure itself. Providers and hospitals exchange clinical data through electronic templates called consolidated clinical document architecture or C-CDA. It was developed by the health IT organization Health Level 7 so that vendors have a common standard.


However the C-CDA documents are considered to be open templates and EHR vendors are allowed to customize the implementations for their clients. This often entails changing layouts or adding and modifying specific fields to accommodate end-users. Sometimes these documents are coded improperly or with just enough variation that they do not work with other applications.


During the certification process, the software needs to only create the individual elements to populate a C-CDA. It is not necessary for the vendor to actually produce the required documents or show that an exchange of data has reliably and consistently taken place. This means that though many practices purchase certified software expecting that they will be able to exchange data with any other certified system, the reality is very different.


More rigorous testing with sample data under real-world conditions may be the key to solving the problem of data sharing. Since the customizability of C-CDA documents is one of the reasons for variability, it may also be necessary to reduce flexibility options in favor of more control by the ONC. A public repository of correctly implemented C-CDAs can also serve as a guide for IT vendors.


Dovetail dental software is a certified dental mobile 2014 EDR/EHR web-application and is HIPAA compliant. It is tailored to help dentists become eligible to take advantage of Meaningful Use incentives.