Behavioral health and long-term post-acute care are perhaps the two most significant areas left out of the meaningful use program.

“When we look at the big circle of care, there’s a huge hole -- behavioral health,” said Mark Caron, CIO of Capital Blue. “Behavioral health is a mess.”

And at least similar words could be used to describe the status of EHR implementation in many long-term and post-acute care settings.

"The problem is there really is no good definition” of what an EHR is particular to behavioral health and LTPAC units, said Larry Wolf, co-chair of ONC's certification and adoption workgroup and CIO of Kindred Healthcare, adding that because some health entities' EHR definitions actually pre-date the HITECH Act,  “We have shades of grey that are very important."

[See also: Can voluntary EHR certification improve meaningful use?]

The group, co-chaired by Intermountain CIO Marc Probst, was charged with recommending how to advance EHR adoption across behavioral health and LTPAC, via voluntary certification.

To establish a baseline that software providers see a value in achieving, Wolf outlined a 5-factor framework to the HIT IT Policy Committee on Tuesday:

1. Advance a national priority or legislative mandate: Is there a compelling reason, such as a National Quality Strategy Priority, that the proposed ONC certification program would advance?
2. Align with existing federal/state programs: Would the proposed ONC certification program align with federal/state programs?
3. Use the existing technology pipeline: Are there industry‐developed health IT standards and/or functionalities in existence that would support the proposed ONC certification program?
4. Build on existing stakeholder support: Does stakeholder buy‐in exist to support the proposed ONC certification program?
5. Appropriately balance the costs and benefits of a certification program: Is certification the best available option? Considerations should include financial and non‐financial costs and benefits.

Wolf continued that ONC hopes to strike the balance between costs and benefits, building on existing certification programs not standing up a new one, and to be judicious about where to put regulations in place because along with the benefits come risks.

"What's becoming increasingly obvious is that … we have to be able to see the rest of the continuum," National Coordinator Karen DeSalvo, MD said, adding that behavioral health and LTPAC entities also need to know that the products they buy are able to interoperate.

She asked the committee to think about how to support adoption without an incentive program. 

“There are ways we can consider it but maybe this is a chance to think about market-based solutions that are modular," DeSalvo said.

When ONC unwrapped the notice of proposed rulemaking for 2015 certification in mid-February, it tuned the process to ideally trigger innovation, with a focus on more modular EHR options.

Should the recommended framework gain purchase in meaningful use it will be voluntary -- at least initially.

“Voluntary may turn out to be in the eye of the beholder,” Wolf added, “or the letter of the law.”

[Editor's note: An earlier version of this article erroneously stated that the NPRM ONC released in mid-February was for meaningful use Stage 3. Instead, it pertains to 2015 EHR certification. The article is now reflects that.]