Welcome to EMR and EHR

Today we got news of the new ONC-ATCB EHR certifying bodies: CCHIT and Drummond Group. However, this is really just the start of the EHR certifying bodies. ONC released that “Applications for additional ONC-ATCBs are also under review.”

One of those possible additional ONC-ATCB EHR certifying bodies is Weno Healthcare. This EMR Daily News guest blog post (Thanks Michelle for pointing it out) asserts that Weno Healthcare has submitted their application to be an ONC-ATCB EHR Certifying body. They also offer this interesting insight:

Until recently, only one body was promoted to do this testing and certification. Because of no competition, their prices were out of the ballpark for smaller technology companies who may have built the better and cheaper mouse trap for doctors and hospitals, but could not afford the fees for certification. The technology companies that certified their products earlier are not considered certified by the new rules today, so all technology vendors must go through an ONC-ATCB in order to be re-tested and certified, if they choose to do so.

If Weno is approved as an ONC-ATCB, more technology vendors can afford the testing and certification fees. Weno savings can be as much as $19,000 for complete EHRs. These savings will certainly provide physicians and hospitals with more cost effective certified technology options to choose from. Again, competition is a good thing because it brings prices down and quality up.

Comparing the Weno Healthcare EHR certification price above with the CCHIT and Drummond Group EHR Certification prices, it’s going to be really interesting. That puts the costs of EHR certification (not counting software development costs) at:
Weno Healthcare: $14,000-18,000
Drummond Group: $19,500
CCHIT: $33,000

Of course, this assumes that Weno Healthcare becomes an ONC-ATCB and that the prices don’t change. I won’t be surprised if they do change. Plus, there could be other EHR certifying bodies.

An article by Government Health IT’s Mary Mosquera has some interesting data from ONC about the number of EHR certifying bodies there might be available to EHR vendors. Here’s the most relevant section:

So far, ONC has received six or seven completed applications out of the 30 it sent to organizations that have requested them since July 1, said Dr. David Blumenthal, the national health IT coordinator, at a meeting of the advisory Health IT Policy Committee.

ONC released in June its final rule for the temporary certification program, which lays out steps organizations must take to be authorized by ONC to both test and certify that EHRs can perform the functions required for meaningful use.

“We are optimistic that we will have a new landscape in the certification realm in which, instead of having a single certification body, there will be more opportunity, a broader pipeline for certification, hopefully more price competition and shorter waiting times to get certification,” Blumenthal said at the committee meeting July 21.

6-7 applications to certify EHR software and 24 more out there that could come in. That sure blows the initial projection of 5 EHR Certifying body applications out of the water. I’m not really sure the business model for these organization. The customer base is about 300 EMR companies. That’s a pretty small market for these organizations to share.

I imagine this is really bad news for those people at CCHIT too. Mostly because CCHIT’s only product is certifying EHR software. At least other organizations like the Drummond Group do a number of certifications. Who would have guessed that the ARRA EMR stimulus money that looked so promising for CCHIT could become the legislation that drives them to irrelevancy?

After noting that CCHIT had gone quiet and posting about Drummond Group’s view of the EHR certification final rule, it seems appropriate that CCHIT has finally come out with their own comments.

The CCHIT blog post was done by Alisa Ray but says it’s a statement from Karen M. Bell, MD, Chair, CCHIT. I think that’s a bad sign for those of us who like executives that blog that Karen Bell sent the blog post through Alisa Ray, but maybe Karen’s still just getting setup on the new job.

There’s nothing really all that shocking or newsworthy in the CCHIT blog post. Here’s the cliff notes version (with some of my own commentary):
-CCHIT will apply to be a “ONC Authorized Testing and Certification Body (ONC-ATCB).” – Not a surprise since EHR Certification is CCHIT’s only business model.
-CCHIT will continue their “independently developed programs.” – They used their favorite word “assurance” in correlation with their programs again. Sadly, they just assure doctors that some programmer knows how to run their test scripts before paying CCHIT $30k+ to get their EHR certification. They don’t assure that an EMR is more usable, or has a higher implementation success rate, or that it saves more lives or increases reimbursement. Nope. Those assurances would run at least $100k to certify;-)

At least in the blogosphere, there’s been a number of healthcare IT bloggers proclaiming the end of CCHIT. Sadly, I’m not one of those. I think they’ll be around for a while and there’s still A LOT more educating that needs to spread about what an EHR certification is and what it is not.

Also, Michelle at Occam PM wrote a blog post that includes some interesting word clouds of the CCHIT and Drummond Group bog posts. An interesting view of what was said.

If you’ve read this blog and/or EMR and HIPAA, you’re quite familiar with my feelings about CCHIT. I just don’t see the value that they add for doctors. If they could show me how they help doctors and not just EMR vendors who want a third party validation to sell more product, then I’d be willing to change my mind. But I digress…

Looks like with the new head of CCHIT Karen Bell taking the reigns, the CCHIT blog has mostly gone quiet. Mark Leavitt did post a good bye on his last day. Sadly, not a single person commented on that blog post saying thank you, best of luck, or anything. So much for 1723 readers subscribed to their blog. I honestly feel a little bad that no one commented. While I disagreed with many opinions that Mark and CCHIT represented, Mark always seemed like a very sincere guy that did care.

Besides that, there’s a post about preparing for the EMR stimulus, but it just links to an outside article. Maybe they should link to some of my articles or even my EMR selection e-Book. I bet they’d like that.

I can imagine how frustrating the EMR stimulus must be to them. Not to mention HHS’s inability to finalize the details of EHR certification bodies and meaningful use. They are kind of in a wait and see pattern until HHS finishes their work.

CCHIT did put out a new search tool. I’m just glad they’re not developing EMR software. Their search tool is one of the most confusing things I’ve seen. At least the lists were easy to understand (once I found them).

We’ll see if CCHIT starts blogging again once HHS gives us some meaningful details.

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’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.