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EMR Stimulus Myth #2: “I have a CCHIT certified EHR so I am good to go for meaningful use”

It is likely that CCHIT will be one of the accredited certification body under the EHR incentive program. HOWEVER, given that there is no formal EHR certification program available from ONC yet, no existing certification, including from CCHIT, means much towards meaningful use.

As I covered in EMR Stimulus Myth #1, even if you implement an ONC certified EHR (when the certification program is finalized), it does not get you to meaningful use. Providers have to meaningfully use the certified EHR and report on defined clinical qualify measures over a set reporting period to meet meaningful use. Given that no EHR today is certified, how should you proceed with EHR purchase decision?

If you are making the decision to buy an EHR now, YOU MUST VETT THE EHR VENDOR prior to purchase so that you minimize the risk of buying the wrong EHR. Vetting should include the assessment of EHR against the current definition of certified EHR from ONC plus the match of EHR to the makeup of your organization. Of course, any promises of future from the vendor should be baked into the contract you are executing with them. EHR needs of a solo or a small practice group is much different than a larger group/clinic/hospital.

People often find real value in getting the assistance of a meaningful use expert for this assessment. The pitfalls avoided make it worth the investment. You don’t want to purchase and implement an EHR and then find out your EHR won’t meet the meaningful use requirements. That would be a depressing realization.

About David:
David Lee is the Principal at eRECORDS, Inc.  David has provided successful healthcare technology, CRM and financial product consultancy for the past two decades and most recently, guiding healthcare organizations to “meaningful use”.   You can reach David at david.lee@eRecords.com or visit www.eRecords.com.

CCHIT has published their comments made on the Interim Final Rule (45 CFR Part 170, RIN 0991-AB58), published in the Federal Register of Jan 13, 2010, “Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology.” Or as I like to call it, the EHR Certification criteria.

Here’s 3 paragraphs that kind of describe CCHIT’s broad feedback on the EHR Certification criteria:

Before offering detailed suggestions, the Commission wishes to highlight three overarching concerns with the IFR as written:

• Scope. While “Complete EHR”sounds like a desirable certification, the package of requirements in the IFR may not match the needs and expectations of doctors and hospitals, nor the realities of the marketplace, for EHRs. By including two functions of an administrative/billing system in the scope of EHR certification, ONC may exclude one third or more of the offerings in the current EHR marketplace, while suddenly forcing hundreds of billing products to undergo unnecessary certifications. In other areas, the scope falls short of being complete: for example, an EHR that does not offer competent electronic management of progress notes would be unusable and medico-legally unsound, and an EHR that fails to prominently display patient advance directives in an emergency could compromise patients’ rights at their time of greatest vulnerability.
• Interoperability. The Commission and its expert volunteer panels believe that certain criteria and standards in the IFR represent a step backwards in progress toward EHR interoperability. For example, well-defined standards for receiving electronic laboratory results in the doctor’s office and for exchanging clinical summaries had already been recognized by the Federal government and widely supported by industry – as evidenced by the certification of over 80 EHR products to those standards in 2008. Yet under the IFR, that standard for receiving laboratory results, and the specific implementation guidance for exchanging clinical data, have been dropped. Where one standard was previously recognized for clinical data exchange, the IFR offers two different, incompatible standards. Conversely, other interoperability criteria in the IFR, such as the requirement that EHRs be capable of transmitting biosurveillance data to public health authorities, could immediately increase EHR cost and complexity while benefits remain years away because public health authorities lack standards-compliant infrastructure and systems for receiving that data.
• Functionality. Some of the IFR criteria define required functionalities of an EHR too microscopically, adding unnecessary complexity and creating barriers to innovation. Other criteria are too vague to be reliably verified in a testing process, creating a risk that the expectations of providers, payers, and the public regarding the performance, safety, and benefits of Certified EHRs will not be met. A particular concern surrounds the reporting of quality measures, with the IFR calling for standards and measures that are yet to be defined or that require significant revision to make them computable from EHR-based data.

I’ll be interested to hear people’s comments about CCHIT’s feedback on the HHS EHR Certification Criteria.

I always love when people are interested in doing guest posts on this site. This is going to be the first in a series of blog posts about some of the misinformation that’s out there about the EMR stimulus, certified EHR, and meaningful use. I hope you enjoy!

My name is David Lee and I am a principal of a healthcare technology consulting firm called eRECORDS, Inc. Day in and day out, I talk to independent physicians, practice group owner and community clinics about HITECH Act and “meaningful use”.  My company takes pride in providing accurate and up to date information to the physicians and clinics so that they can make intelligent decisions about meaningful use.

I am continually amazed at the misinformation surrounding meaningful use and the one that scares me more than anything else is ”My EHR vendor told me that if I implement their certified EHR, I will meet the meaningful use requirements and collect EHR incentive payments.”

It is true that a “certified EHR”  is a key component to meeting the requirements of “meaningful use”.  However, a “certified EHR” is not the silver bullet to meaningful use.  Let me share some important facts:

• Fact: Although the definition and requirement of a certified EHR has been released by the ONC, there is no organization recognized or approved by the CMS to certify EHR to meet the requirements of the meaningful use criteria.
• Fact: Even if your organization implements a certified EHR (when certification bodies are appointed and your EHR vendor passes the certification), this does not get you to meaningful use..
• Fact: Meeting meaningful use requirements involve qualified providers meaningfully using a certified EHR and reporting clinical quality measurements.  The key words are “meaningfully using” and “reporting” not simply having a certified EHR.

Don’t be fooled by any vendor claiming that they are certified or promising they will be certified.  Although some EHR vendors are better prepared to meet the certification when available, not a single vendor today is certified for the EHR incentive payment program.  More importantly, you cannot meet the requirements of “meaningful use” by simply implementing a certified EHR. It is vital that you find experts who can provide accurate assessment and plan for “meaningful use”.

This is a continuing series where David will share and hope to clear the myths about HITECH Act and “meaningful use”.

About David:
David Lee is the Principal at eRECORDS, Inc.  David has provided successful healthcare technology, CRM and financial product consultancy for the past two decades and most recently, guiding healthcare organizations to “meaningful use”.   You can reach David at david.lee@eRecords.com or visit www.eRecords.com.

I’ve written a number of times about Drummond Group becoming an EHR certification organization in order to obtain the EMR stimulus money. Well, the Drummond Group has created a blog to keep you informed about theri partcipation in EHR testing/certification.

Here’s the most important part of their first post on their blog:

It appears Booz Allen Hamilton (BAH) will be developing both the testing certification documents as well as the framework for authorizing certifying body for EHR certification.

Once that final piece of the puzzle is revealed, we can begin making more detailed plans for EHR certification. Until then, we believe attempting EHR certification is, at best, premature and, at worst, potentially a significant waste of time and money for ourselves, the certifying vendors and the adopting physicians and hospitals.

However, this waiting period does not mean we are idle. We will be making regular posts here on various EHR certification topics. Since many of you are not familiar with us, we will share a bit more about DGI and our qualifications to be an authorized HHS certifying body for EHR. We have a great deal of experience in system-to-system interoperability and are excited to bring that knowledge to the EHR community. Since we are getting so many emails from vendors interested in EHR certification, we will talk about some of the concerns we are hearing and thoughts on how to best address them.

This is exactly why you should want to be certified by Drummond Group and not CCHIT. I agree with them saying, “attempting EHR certification is, at best, premature and, at worst, potentially a significant waste of time and money for ourselves, the certifying vendors and the adopting physicians and hospitals.“

I just found this really nice interview by InformationWeek with David Blumenthal, Health IT Czar. Here are a few snippets of what David Blumenthal said with my own commentary in italics.

Congress set very ambitious goals for the HITECH legislation. The concept of meaningful use is novel, and a very powerful and important concept. The process of defining meaningful use has gone through many months, through many public hearings.

I think David Blumenthal realizes that meaningful use is going to be a major problem for many doctors offices. I think we’re going to hear him blaming Congress for the “ambitious” HITECH legislation which has his hands tied. It probably does, but it’s too bad he can’t just say it that way if it is the case.

The Office of National Coordinator is still committed to developing the Nationwide Health Information Network. Many of our federal colleagues and quite a number of larger healthcare organizations are on the verge of using NHIN as it was originally conceived and configured for their own purposes, and we’re continuing to invest in it.

At its last meeting the HIT Policy Committee adopted recommendations that they have not yet formally transmitted to me to encourage the development of a more flexible, adaptable, less complicated method of health information exchange than the Nationwide Health Information Network. And that’s something that we’ll be studying.

I think this is a good move. This national network in its current state just doesn’t seem like it’s going to have much affect on small doctors offices, which last I checked make up a large part of our healthcare system. I think in politics they call this move taking it to the people.

InformationWeek: Once you get clinicians using e-medical records, who pays to maintain the exchange infrastructure?

Blumenthal: It’s a short-term issue. Long term it’s going to become an expectation on the part of the clinician and patient that information is going to be exchanged. And I think it will become a cost of doing business in the healthcare sector just as physicians and nurses consider it a cost of doing business to buy stethoscopes and run an office.

Doctors will hate to hear this quote. Although, they shouldn’t be too upset. In reality, they’ll be passing this cost on to the consumers. Now how we get to the point Blumenthal talks about is beyond me. That’s a huge gap to cross.

InformationWeek: Will the Certification Commission for Heath IT–CCHIT– remain the organization doing these certifications, or will there be others?

Blumenthal: We’ll have to see what the regulation actually is and see where CCHIT fits in. CCHIT is clearly going to have the option to participate in certification going forward, but I can’t tell you what role exactly it will play.

Translation: I don’t care about CCHIT. If they want to participate great, but I’m playing no favorites here.

CCHIT’s Mark Leavitt has published his analysis of the $400,000 contract that NIST awared to Booz Allen Hamilton to develop a framework for electronic health record certification (see certified EHR).

Honestly, it seems that Mark’s as confused as everyone about this whole process. This is an interesting development since I would have thought that CCHIT would have had a close relationship with HHS, ONC, NIST, CMS, etc. The fact that CCHIT and Mark Leavitt are kind of left in the dark and full of lots of questions is not a good sign for CCHIT and fans of CCHIT. It is a good sign for those who don’t care for CCHIT.

I can’t help but repost something that HISTalk posted about one of the companies that’s now CCHIT preliminary ARRA certified and the meaning of said certification:

From Lester Bangs: “Re: ARRA certification. Companies like this one (and they aren’t alone) get checked off on SOME of the ARRA criteria (which are changing) and get labeled as Pre-ARRA Certified by CCHIT. Amazing. And we wonder how folks are confused.” I found CCHIT’s disclaimer more interesting (click the above screen shot to enlarge) since it clarifies that the certification is preliminary, possibly irrelevant depending on the standards that are eventually approved, and possibly worthless since CCHIT may not even be a recognized certification body by them.

I’ve always loved HISTalk, but I’m even happier to see that him and I agree about CCHIT certification. I’m sure Mark Leavitt is really glad he’s cutting out of CCHIT when he did.

A while back I wrote about the great news that the Drummond Group was planning to compete with CCHIT in doing EHR certification. The news coming out of HHS has been slow coming for these new EHR certification bodies, but I just received this email from the Drummond Group. In it they assert that they’re still planning to become an EHR certifying body for purposes of getting EMR stimulus money. Below is the full email:

As our 2009 year closes, we wanted to reach out to the many EHR vendors and interested parties who have contacted us about EHR certification and update you on the current state of our EHR certification program. Like you, we are currently waiting for HHS to release their meaningful use definitions and, just as importantly, their certification requirements. In his recent blog post (http://healthit.hhs.gov/blog/onc/index.php/2009/12/07/marking-the-road-ahead/), Dr. Blumenthal of the ONC indicated the publishing of the plans for the new certification program will not be released until early 2010. This is a bit disappointing as we were expecting this in late 2009. Regardless, we remain very excited about the future of EHR certification.

In this period of waiting, we have been speaking to many industry leaders and stakeholders to gain as much information as we can to ensure our EHR certification program will meet the needs of end-users and be viable for EHR vendors, especially small and medium sized companies. Once we get news of the HHS certification program, we can begin formalizing our EHR certification process. When we know more, we will make sure we keep you updated about our plans.

Thank you for your interest in us and EHR certification. May you and yours have a joyous holiday season and an even better 2010.

Joani Hughes
Interop Certification Coordinator
Drummond Group Inc.
www.drummondgroup.com

Check out the following descriptions of the first four EHR vendors to become CCHIT 2011 and Preliminary ARRA EHR certified per Jim Tate’s guest blog post on Hitech Answers:

eHealth Made EASY, Version 3 by eHealth Made EASY, LLC, achieved Preliminary ARRA 2011 Certification for ‘CMS Quality Reporting” in both the Eligible Providers and Hospitals domains. They look to be on track to supply the ‘meaningful use’ reporting functionality across the entire range of platforms. I’m guessing they could become the reporting engine for quite a few hospital systems and EHRs.

KIS Track, Version 5.1, by Kaulkin Information Systems, achieved Preliminary ARRA 2011 Certification for ‘Patient Electronic Access to Health Information’ for Eligible Providers. Looks like they may be getting into the patient portal market.

Medios, Version 4.5, by IOS Health Systems, passed inspection on 27 of 27 objectives for Preliminary 2011 ARRA Certification for Eligible Providers. It appears they are interested in the Ambulatory EHR market.

ABELMed EHR-EMR/PM, Version 11, by ABEL Medical Software Inc., is the first EHR vendor to achieve the CCHIT 2011 Comprehensive Ambulatory Certification. Usability testing is now a part of the CCHIT Ambulatory Certification and in this area ABELMed scored 4 out of 5 stars.

My personal takeaways:

Takeaway #1: Four EHR vendors and I’ve only really heard of one of the four. Sifting through all the EHR vendors is just going to get more and more difficult.

Takeaway #2: How will these vendors and the users of these EMR vendors feel if HHS comes out with some drastically different or drastically simplified criteria for EHR certification?

Healthcare Informatics has been doing a number of really interesting interviews lately. One of their most recent ones is an interview with RiK Drummond, CEO of The Drummond Group. You may have seen that the Drummond Group will be certifying EHR for ARRA funding. So the interview with Rik Drummond is pretty interesting. It is in 2 parts, but here are some highlights from the first part (since the second part isn’t up yet):

In regards to the cost of EHR certification (looks like Drummond Group EHR certification could still be pricey):

GUERRA: So you don’t have a better sense of whether they feel the current pricing is too high or if the certification process is too long? You’re not getting a more definite sense of what it is they’re coming to you for?

DRUMMOND: We’ve been kind of overwhelmed with a lot of this for the last three or four weeks, so we’re going back to interview some of them just to see what the actual problem is. I should know more in probably three or four weeks.

I expect that this is like normal testing where pricing is always an issue. Every test that anyone does, people think it’s too high because it’s one more cost to add in the end. The flipside is we find that once people understand what pricing gives them – it’s almost the last part of their software cycle – they see the cost is not nearly as high as they would anticipate, because it’s a cost of shifting from internal testing to external testing, and it also gives them a big marketing boon because someone is stamping their seal of approval on you, you’ve met these conditions. And that marketing boon is worth anything, you pay for that sort of thing.

In regards to establishing the EHR criteria and CCHIT certification (glad to see they like the separation of requirements making and requirements testing):

DRUMMOND: We think it’s very important to keep the stakeholder groups who define the requirement areas distinct from the testing parts, if at all possible. That doesn’t mean it can’t be the same organization, but it means you have to have some really clear boundaries. So CCHIT has both of those combined, and we always try to avoid having those two combined very closely.

Our focus would be very much on working with CCHIT, our working in parallel with them, but we all have to use exactly the same test criteria to make this whole thing work. So it has to be defined somehow so that happens. We need to focus on the technical aspects in making everything come together appropriately, so that when people go buy these products they can say, “Well, I’m one step into meaningful use. I have one key component in place. Now, I have to show how I use it to get the rest of it.”