The Northwestern Medical Enterprise Data Warehouse received meaningful use certification for both of our Inpatient and Outpatient modules back in June 2011. Since then a lot of people have been contacting me to learn about our certification experience and I hope these series of posts makes it easier for others to get the information they are seeking. Part one will focus on how we determined our scope for certifying a data warehouse.
First, a little background for new readers;. For those unaware of our setup, we are basically a medical data warehouse that receives data from multiple participating entities (Inpatient and Outpatient) on the campus. The data warehouse is used both for research and for operational reporting purposes all aimed at enhancing patient safety and quality of care.
Although the EMRs deployed on the campus were either certified or offered certification modules for additional costs, all of them would have required significant process and workflow changes which were aimed at meeting meaningful use needs and thus not very efficient. The flexibility provided by developing the capabilities within the EDW made it an obvious choice for some of the meaningful use criteria.
This FAQ post on the ONC website indicated that a data warehouse would need certification to qualify for meaningful use and so we started our journey back in November of 2010. The goal was to receive stage one certification for the following Meaningful Use criteria:
- Submission to immunization registries (170.302.k)
- Public health surveillance (170.302.l)
- Reportable lab results (170.306.g)
- Clinical Quality Measures (170.306.i)
- Mandatory Security Criteria
The most common hurdle shared by those who want to certify a home grown system is the lack of a defined scope.
When we started out, the only thing pre-determined was the deadline for certification. Based on the deadline for the stage one reporting to begin, we had targeted to get our hospital certification by Jun 14, 2011 and our Eligible Provider certification by Jul 27, 2011. However, as clear as it was that we needed to get certified, the certification process was painfully unclear. In fact, my first few weeks were spent trying to identify the project scope.
Unfortunately I quickly discovered that most of the information (including the test scripts on the ONC website) available was rather specific to certification needs for complete EHRs. I wasn’t sure how certain test scripts would be translated to a module like a data warehouse. I submitted questions to the usual channels (ONC/CMS) and realized soon that they had many others asking them questions and a response wasn’t gauranteed. I knew we couldn’t be the only ones who would need certification for a home grown system and decided to see if others were in the same boat as us.
As part of the Healthcare Datawarehouse Association (HDWA), I polled other healthcare data warehouses and soon discovered that not only were others in the same boat but we all had the exact same questions; except no one yet had any answers to the questions.
I finally thought I would ask one of the ONC-ATCB (CCHIT) and see if they could help me answer the questions shared by data warehouses across the country. I was pleasantly surprised to find that they were very willing to answer our questions and realized I had finally made a breakthrough in defining that elusive scope. The timing was just right since CCHIT was planning on launching their EACH program soon (January of 2011) that was aimed at non-vendors like us who wanted to certify their home grown systems. I spent a big portion of the next few months working with the EACH certification team and scoping out what we would need to demonstrate on testing day.
The best part of identifying an ONC-ATCB early was the ability to explain to their certification team just how a data warehouse differed from an Electronic Medical Record (EMR) System.
Unlike an EMR system, where a physician actively records data directly into the system based on a live patient encounter, a data warehouse receives a periodic copy of the data in those systems. The data warehouse is typically used by data analysts who write queries using SQL to extract data. As such, some of the parameters like emergency access were simply not applicable to the data warehouse. Access to the database is very heavily secured and granted on a case by case basis. Since the data warehouse is never used for directly impacting patient care decisions, we would never be presented with a case where a data analyst would need to access to a specific patient’s chart urgenty. As such, we received an exemption for the Emergency Access criteria.
Once our scope was defined, the next step was to develop the core infrastructure for Meaningful Use. This phase was comparitively easier for us largely because Northwestern had already been using the EDW for calculation and development of clinical quality measures including and thus we had a of the core infrastructure and expertise in place to support meaningful use.
Stay tuned for future posts which will discuss how we went about developing our modules and our key take aways from certification day.