Bridge Certification Program

The Bridge Certification Program is a compliance stabilization initiative administered by Technology Compliance Partners (TCP). The program supports eligible federal EHR Incentive participants in restoring active ONC certification status while minimizing operational disruption.

Program Charter

Administered by: Technology Compliance Partners (TCP), an independent nonprofit Health IT compliance board and vendor network governed by a board of directors.

Effective Date: March 11, 2025

Last Updated: February 11, 2026

Current Jurisdiction of Administration: State of California

I. Statement of Authority and Regulatory Framework

The Bridge Certification Program operates within the regulatory framework established by:

The Centers for Medicare & Medicaid Services (CMS);
The Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, including Meaningful Use and Promoting Interoperability;
The Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program.

CMS and applicable state Medicaid agencies establish participation requirements, certification standards, documentation expectations, audit procedures, and enforcement mechanisms under the EHR Incentive framework.

Technology Compliance Partners (TCP), as an independent nonprofit Health IT compliance board and vendor network, administers this program within that structure for the purpose of certification verification, documentation alignment, and compliance stabilization for eligible providers.

II. Purpose and Objectives

The Bridge Certification Program exists to support eligible providers who:

Previously attested to adopting ONC-certified EHR technology under the Federal EHR Incentive Program;
Accepted federal EHR Incentive funding; and
Do not currently maintain an active ONC-certified EHR associated with their NPI at the time of administrative review.

The program is supportive and non-punitive in nature.

Its objectives are to:

Provide an optional resource pathway for eligible providers;
Reduce administrative and operational burden;
Facilitate timely restoration of active certification status;
Support providers in meeting ongoing participation obligations;
Promote workflow continuity and stability.

The program operates prospectively and does not modify historical attestation outcomes.

III. Jurisdictional Scope

The Bridge Certification Program applies to healthcare providers who:

Are enrolled participants in Medicare or Medicaid;
Previously attested under the Medicare or Medicaid EHR Incentive Program and accepted incentive funding;
Maintain active enrollment status; and
Are administratively designated as having no active ONC-certified EHR associated with their NPI within TCP's review or confirmation process.

The program applies to eligible individual (Type 1) and organizational (Type 2) NPIs where the individual provider previously attested and accepted funding.

The program is currently administered within the State of California and may expand to additional jurisdictions consistent with TCP governance.

The program does not operate retroactively and does not alter prior attestation determinations.

IV. Scope of Activities

The Bridge Certification Program may include:

Administrative confirmation of certification status;
Provision of CHPL navigation and verification tools;
Optional connection to ONC-certified EHR technology;
Establishment of certification association with the provider's NPI;
Implementation and onboarding guidance;
Documentation of remediation activity;
Issuance of defined administrative records.

The program may operate alongside a provider's existing practice management system and is structured to minimize disruption to established workflows.

It is intended as a stabilization mechanism that supplements long-term EHR evaluation and vendor selection decisions.

V. Eligibility Criteria

Participation is voluntary and available to providers who meet all of the following conditions:

Prior acceptance of federal EHR Incentive funding;
Attestation under Meaningful Use or Promoting Interoperability;
Active Medicare or Medicaid enrollment;
Administrative designation of no active ONC certification;
Completion of a review discussion with TCP.

Providers may initiate inquiry through outreach or self-verification mechanisms. Eligibility is confirmed through administrative review.

Providers retain discretion to pursue independent vendor selection.

VI. Operational Framework

The program follows a structured administrative process:

Certification status review;
Provider notification of certification status;
Provision of verification resources and guidance;
Optional election to participate in Bridge Certification;
Establishment of ONC certification associated with the provider's NPI;
Required implementation guidance session;
Confirmation of certification activation;
Issuance of administrative documentation.

Implementation guidance is required prior to issuance of a Letter of Compliance.

The program applies from the date of remediation forward.

VII. Documentation and Records

Upon completion of the administrative process, TCP may issue:

Certification transcript reflecting ONC-certified product association with the provider's NPI;
Internal remediation record;
Letter of Compliance.

Letter of Compliance

The Letter of Compliance is a dated administrative document indicating that, as of issuance:

The provider maintains an active ONC-certified EHR associated with their NPI;
Certification status has been verified within the program framework;
The provider has completed the required administrative and implementation review process;
The provider's active certification status satisfies the applicable federal program requirements and corresponding state statutes governing electronic health record participation, as specifically cited within the Letter itself.

For purposes of the Letter of Compliance, "compliance" is defined narrowly by reference to the relevant state statutory provisions and federal participation requirements cited within the document.

The Letter of Compliance remains valid contingent upon continued active certification status.

If certification becomes inactive, the administrative status may be updated accordingly.

All records are maintained consistent with TCP documentation retention policies and applicable regulatory expectations.

VIII. Relationship to Other Programs

The Bridge Certification Program operates within TCP's broader Federal EHR Incentive administrative framework.

It is distinct from:

The CalDXF Program;
Independent vendor contracting;
General health IT advisory services.

Participation in one TCP program does not require participation in another.

IX. Duration and Sunset

The Bridge Certification Program is structured as a time-limited compliance stabilization initiative.

The maximum projected duration of the program is seven (7) years from its effective date, unless earlier modified or sunset by TCP's governing board.

TCP may modify or sunset the program with advance public notice.

Archived versions of this Charter will remain available for transparency.

Governance and Oversight

This program operates under the oversight of TCP's governing board. Program structure, scope, and administrative procedures are subject to periodic internal review. Material changes to program scope or eligibility are approved through board governance processes and reflected in the version history below.

Definitions

Bridge Certification: "Bridge Certification" refers to the administrative process through which an eligible provider establishes an active association between their National Provider Identifier (NPI) and an ONC-certified Electronic Health Record (EHR) technology that meets the minimum federal certification requirements in effect at the time of review.; The term reflects that the certified EHR technology:; The program is referred to as a "bridge" because it establishes certification continuity between a provider's existing practice management system and a currently certified EHR technology.
Active ONC Certification: "Active ONC Certification" means that:; If certification is canceled or otherwise rendered inactive, the provider is not considered to maintain Active ONC Certification unless alternative documentation is provided and verified.
Administrative Designation: "Administrative Designation" refers to TCP's internal classification of a provider's certification status following formal review.; A provider may be designated as either:; Administrative Designation occurs only after file review and verification. Self-verification alone does not constitute formal designation.
No Active Certification Status: "No Active Certification Status" means that, following administrative review, TCP has determined that no EHR technology meeting the definition of Active ONC Certification is currently associated with the provider's NPI.; This designation is administrative in nature and reflects certification verification status at the time of review.
Eligible Provider: "Eligible Provider" means a healthcare provider who:
Grant Recipient: "Grant Recipient" refers to a provider who received federal EHR Incentive funding pursuant to attestation under the Medicare or Medicaid EHR Incentive Program.
Active Enrollment: "Active Enrollment" means enrollment in Medicare or Medicaid in good standing, as defined by CMS or the applicable state Medicaid agency, regardless of current billing volume.
Certification Transcript: "Certification Transcript" refers to documentation provided to the provider confirming:; The Certification Transcript serves as proof of Certified Electronic Health Record Technology (CEHRT) association.
Remediation: "Remediation" refers to the administrative process through which a provider:; Remediation applies prospectively from the date certification is established.
ONC-Certified EHR Technology: "ONC-Certified EHR Technology" means health information technology certified under the ONC Health IT Certification Program pursuant to 45 CFR Part 170 and meeting the applicable certification edition requirements in effect at the time of review.
EHR Incentive Program: "EHR Incentive Program" refers to the Medicare and Medicaid Electronic Health Record Incentive Programs, including Meaningful Use and Promoting Interoperability, which required attestation to adoption of Certified Electronic Health Record Technology (CEHRT) in exchange for federal incentive funding.
Practice Management System: "Practice Management System" refers, within TCP's administrative framework, to any health IT system that does not meet the definition of Active ONC Certification, including systems with expired, sunset, or otherwise inactive certification status.
Implementation Guidance: "Implementation Guidance" refers to the required onboarding and technical review process conducted prior to issuance of a Letter of Compliance, including confirmation of:
Certification Revocation: "Certification Revocation" refers to the administrative update of certification status when an Active ONC Certification becomes inactive due to cancellation, lapse, or termination of association with the provider's NPI.
Letter of Compliance: A dated administrative document issued by TCP indicating that, as of issuance, the provider maintains an active ONC-certified EHR associated with their NPI, certification status has been verified within the program framework, and the provider has completed required administrative and implementation review processes. Compliance is defined narrowly by reference to relevant state statutory provisions and federal participation requirements cited within the document.

Version History

Version 1.0 – March 11, 2025 – Initial adoption
Version 1.1 – February 11, 2026 – Clarified Letter of Compliance definition

For related disclosures, statutory references, and program policies, see the TCP Disclosures Section.