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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.

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.

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?

There’s been a series of posts done on EMR and HIPAA that I think are worth highlighting on this site. They basically cover the status of where we’re at in understanding what will be defined as “certified EHR” in order to get the ARRA EHR stimulus money.

First, take a look a post talking about the HIT Policy committee meeting on EHR certification where they discussed and approved a number of items related to defining certified EHR.

After that initial meeting, CCHIT held a town hall meeting to present their new CCHIT Preliminary ARRA Certified EHR certification plan. Then, take a look at a bit of a comparison of the Preliminary ARRA Certified and CCHIT Certified that was presented at the same meeting.

Finally, no discussion of these EHR certifications is complete without taking a look at the costs for the new CCHIT EHR certifications. That link also discusses the new EHR certification bodies that are likely to be created and recognized by HHS to be able to certify EHR software in order to obtain the ARRA EHR stimulus money.

At EMR and EHR we welcome people to submit guest blog posts on our contact us page. We’re happy to post them with your name and a link to your website or anonymously. This week’s guest blog post comes from a doctor who wishes to remain anonymous but has some real questions about CCHIT’s involvement in the EMR world. Enjoy!

Companies are lobbying the Administration to keep product-testing and standard-setting within the sole jurisdiction of a nonprofit body called the Certification Commission for Healthcare Technology. Founded in 2004 with industry money and grants from nonprofits, CCHIT now receives $7.5 million a year under a contract with the federal government. The other half of CCHIT’s $15 million budget comes from fees paid by companies. Mark Leavitt, chairman of CCHIT, is a former tech vendor. He sold his electronic health records company to GE in 2002 and later became chief medical officer of the Healthcare Information & Management Systems Society (HIMSS), a trade group in Chicago. Seven of the CCHIT’s 19 voting members work for vendors or for-profit tech consulting firms. -– Chad Terhune, BusinessWeek, May 4, 2009, The Dubious Promise of Digital Medicine: Why huge spending on electronic records won’t produce quick improvements in efficiency or care.

$15 million dollars per year! To do what? Where is all the money going? I wonder how much Mark Leavitt makes per year? How much are the voting member paid per year? Boy, would I love this job! And what about the fact that almost half the voting members work for vendors or consulting firms! Is there a conflict of interest?

Does anyone have any additional information on CCHIT? This really makes me curious. Alarms are going off all over the place when I hear the basic information about CCHIT, how much they take in per year ($15 million) and what they actually do (certify a few EMR Systems).

There’s been a lot of talk around the blogosphere about the new EHR certification pathways proposed by CCHIT. However, Neil Versel is reporting on his blog that there’s a rumor that ONC is planning a July meeting with several people that are considering starting up an EHR certification program.

Makes complete sense to me. David Blumenthal does seem open to the idea of not having CCHIT be the sole certification body. Certainly he’ll feel some big time pressure from the various big EHR vendors out there, but I’m hopeful that David Blumenthal will be able to do well and keep at least some competition in the EHR certification process.