Bridging the EHR Certification Divide: Vendor Voices from the LTPAC Frontline

Introduction

The Assistant Secretary for Technology Policy/Office of the National Coordinator (ASTP/ONC) Electronic Health Record Certification Program was originally established under the HITECH Act to support federal EHR incentive programs by providing assurance to purchasers and users that health IT systems offered the technological capabilities, functionality and security necessary to meet the meaningful use criteria set for each program phase. The intention was to foster widespread confidence in certified EHR systems as tools for achieving national healthcare quality and interoperability goals. However, some stakeholders were excluded from the initial HITECH Act funding and, even today, do not receive incentives to offset the costs of meeting these compliance requirements.

Although the ASTP/ONC’s EHR certification program has existed for more than a decade, the availability and adoption of certified EHRs and related technologies serving the long-term and post-acute care (LTPAC) sector remain uneven, with few vendors offering technology that is fully certified to the current program. This stands in stark contrast to the acute and primary care space, where certified technology is the norm. The roots of this disparity are multifaceted: LTPAC providers are not currently required to use certified EHR technology, and the certification program itself was originally designed to support EHR incentive programs for eligible providers under the HITECH Act, not LTPAC’s unique needs.

To better understand the issues behind this gap, HIMSS partnered with ADVION, a trade group representing information technology companies serving the LTPAC sector and the senior living market, to conduct a series of listening sessions with a diverse set of LTPAC EHR vendors. This initiative aimed to capture the perspectives of small, medium and large vendors across the sector, providing a snapshot of the current state and informing future policy and innovation.  Vendors represented skilled nursing facility, home health, behavioral health, rehab therapy, senior living and other specialty EHRs. 

Barriers to Certification in LTPAC

A consistent theme in vendor discussions was the significant financial and operational burden associated with certification. Certification is resource intensive, requiring not only substantial up-front investment in program evaluation and technology development, but also ongoing costs for testing, consultants and recertification after major technology updates or regulatory changes. For LTPAC providers, many of whom operate with thinner margins and lower IT maturity than their acute care counterparts, these costs represent a persistent barrier and an opportunity cost, diverting resources from other critical digital transformation priorities.

Misalignment Between Certification Criteria and LTPAC Realities

Another major barrier is the misalignment of certification requirements with the realities of LTPAC environments. LTPAC vendors estimated that 30%-40% of certification requirements are not applicable to their settings, with examples including pediatric measures, MIPS-tied clinical quality measures (nursing homes are exempted from MIPS), and public health reporting requirements that do not reflect LTPAC workflows. As a result, vendors are often forced to develop capabilities solely to meet these certification criteria, even when their customers have no need for those features. This misalignment leads to wasted development effort and further discourages participation in the certification program. 

The LTPAC sector, although obligated to comply with all applicable regulatory requirements beyond certification (such as information blocking), did not receive incentive funding that was made available in 2009. As a result, the sector has been disadvantaged compared to the acute and ambulatory care sectors, which have had the essential funding to support and sustain ongoing compliance efforts. Without comparable resources, LTPAC organizations lack the foundational financial support necessary to maintain effective compliance.

Certification vs. Interoperability

Several vendors highlighted a critical disconnect between certification and true interoperability. While certification was originally intended to assure EHRs’ baseline functionality and security, it does not guarantee that certified EHRs can seamlessly exchange data. Many LTPAC vendors reported ongoing challenges in exchanging data with hospitals and health systems, even when both parties use certified products. Differences in implementation, data structures and standards often require costly workarounds, undermining certification’s value proposition.

Customer Interest and Demand

Customer demand for certified EHR products in LTPAC remains relatively low, except where government contracts require certification. While some customers include certification in their RFPs, most are more focused on functionality and workflow fit than on certification status. Vendors are often able to deliver the necessary features without undergoing the formal certification process, further reducing the incentive to pursue certification.

The Value of Certification

Despite these challenges, some vendors see value in and have obtained certification, particularly for establishing baseline functionality and standardization across the healthcare ecosystem. They also recognize that this could eventually become a requirement.  Certified products may offer more usable data, and, as more technologies become certified, the value of certification could increase. However, most vendors remain skeptical, noting that certification does not address the sector’s most pressing challenges, especially around interoperability and practical utility in LTPAC settings.

Implications for Policy, Innovation, and the Future

The current state of EHR certification in LTPAC reflects a program that does not fit the sector’s needs. High costs, misaligned criteria, low customer demand and persistent interoperability challenges have limited certification’s value for LTPAC vendors. Vendors who have pursued certification report resource conflicts and multi-year timelines, while others have scaled back on certification plans or put them on hold entirely. Without financial incentives or a reimagined certification program tailored to LTPAC’s realities, widespread adoption is unlikely.

Call to Action

If policymakers are considering changes to the EHR certification program, it is crucial to recognize that the current certification approach does not fit the LTPAC environment. Any new requirements must be accompanied by funding for both providers and vendors, technical support and the flexibility to align with the sector’s unique workflows and constraints. LTPAC providers are full partners with acute and ambulatory providers in the continuum of care and patient data needs to flow among all these sectors. Because of this, consideration of the LTPAC sector, as well as other care settings that have received no financial incentives or assistance with regard to adopting EHR systems, is important for any future certification plans. Only by addressing these issues can we bridge the EHR certification divide and ensure that LTPAC providers and the patients they serve are not left behind in healthcare’s ongoing digital transformation.