One of my regular readers, Jack, sent me the following email:

“One (actually I had many….) of the real question marks I had since 2005 about CCHIT and certification of EMR was that, “Should every vendor that applies be able to pass certification?”, or put another way, “What kind of certification is it that allows everyone who applies to pass and be certified?” My notion of certification was that not everyone who applies can make it. Why have certification if everyone passes it?”

Then, he followed up with these comments:

“In prior years, I think every vendor that paid their money passed certification. I can’t ever remember an instance of a vendor failing. If its that easy to get certified…what good is it? What benefit is there? Are we really weeding out products that just don’t cut it? If so, where are they? The ones that don’t apply?”

Of course, the sad answer to Jack’s questions are that EHR certification isn’t a benefit. At least not a benefit to the doctors. The only exception now is that it is a necessary requirement to get EMR stimulus money, so having an EMR vendor that is certified will make it possible to try and get the EMR stimulus money if you so desire. Outside of that, the certification doesn’t really provide a benefit to the doctor.

EMR vendors get some benefit as far as marketing and giving them a tool to provide a false assurance to the providers who don’t understand what EHR certification is really all about.

Back to the point of every EHR vendor that pays becoming certified, yes that does diminish the value of the certification. When CCHIT first came out, we talked about this in amazing detail on EMRUpdate.com. We discussed all sorts of options and methods for certification. One such thread discussed the idea of providing grades instead of just a straight up pass/fail certification. In fact, the grades should likely be given on a feature by feature basis.

The challenge with giving grades for EHR is that it’s quite subjective. Plus, which subjective viewpoint do you use. Do you give it an F for specialists and an A for general medicine? At that point, you’re becoming so granular that it’s just not able to scale in any reasonable manner.

What’s the solution? If I knew, I’d probably be doing it. What is clear is that EHR certification wasn’t meant to help doctors.

In case you missed the announcements on Thursday and Friday, Drummond Group announced the first ONC-ATCB certified EHR (3 of them) and CCHIT announced their first set of ONC-ATCB certified EHR (21 full ONC-ATCB EHR). I also got word today that HHS finally updated their website with the Drummond Group ONC-ATCB.

Of course, we have a few hundred more EHR software out there that are going to be announced. It’s just a matter of how quickly the ONC-ATCB are going to be able to pump out the certifications. Not to mention the EMR vendors completing the list of requirements.

As one EMR vendor told me this weekend. We could have easily rolled out the features that the EHR certification requires to become certified. However, that wouldn’t have been very useful for our users. Then, he went on to say that he’d rather spend an extra month or two to make the certified EHR requirements part of a really nice and useful dashboard than to just roll out some shoddy features that satisfy the EHR certification requirements, but don’t make sense to doctors.

Makes you wonder about these first EHR vendors that have been certified. Just because the EMR is an official ONC-ATCB doesn’t mean you will actually want to use that EMR software.

InfoGard Laboratories, the nation’s first accredited IT security testing laboratory, is approved by the Health and Human Services, Office of the National Coordinator for Health IT as an ONC-Authorized Testing and Certification Body (ONC-ATCB) for the certification of Complete EHRs and EHR Modules for both ambulatory and inpatient settings. -Source

And now there are three official ONC-ATCB for EMR vendors looking to get their EHR software certified. Looks like InfoGard has been doing NIST certifications for a long time now and EHR certification will just be another certification for them.

Info Gard will be the third officially approved ONC-ATCB alongside Drummond Group and CCHIT which were announced previously. There’s also been rumors that Weno Healthcare is trying to become an ONC-ATCB as well.

Maybe I’m just missing it, but I wasn’t able to find other details on InfoGard’s EHR certification plans, pricing, and timeline. If someone else finds it, please let me know. It’s a little disappointing that their press release didn’t include a link to this type of information like Drummond Group and CCHIT did.

Drummond Group has recently published an FAQ about EHR certification. I’m guessing that the FAQ will continue to grow over time. They do cover some important topics. Here’s one of the FAQ that I found particularly interesting (and pretty sad too).

Q: My software is developed for a specialty practice (e.g. dental, etc.) and some criteria are not relevant for my customers. To be a Complete EHR, do I still need to certify over all the criteria?

A: There is not a specialized criteria set beyond the general categories of ambulatory or inpatient, and thus specialized software are required to satisfy the same criteria as general EHRs. The concept is that even if a user will not utilize all the features of a certified EHR that the certified EHR must still have this functionality present within it. Regarding criteria that do not fit a specialty’s typical use, ONC address this type of situation in their Standards and Certification Criteria Final Rule. They talk more of the situation with ED/inpatient settings and comments that growth charts are not needed. Here are the relevant sections that show the aggregated comments they received and their response.

Comments.  A few commenters noted this certification criterion applies more

directly to specialties that predominantly treat children.  For other specialties, this criterion would add unnecessary cost and complexity to many HIT products that they would use.  Many commenters suggested that a growth chart component should not be required for EHR technology designed for an inpatient setting, as it is not feasible to track this data in a meaningful way over a long enough period of time in an inpatient setting (which is typically of a short and infrequent duration).  A couple of commenters suggested that non-traditional forms of growth charts should be accepted.  One commenter suggested that the certification criterion establish a baseline, but should not limit the expansion of this capability to other ages.  Other commenters made specific suggestions for different age ranges, such as including children under the age of two and lowering the upper age to ages less than 20 years old (e.g., 18).

Response.  As we stated above with respect to the calculation of BMI, we believe

that Certified EHR Technology should be capable of performing this capability

regardless of the setting for which it is designed.  Moreover, with respect to whether growth charts should be applicable to Complete EHRs and EHR Modules designed for an inpatient setting, we remind commenters that children’s hospitals qualify as eligible hospitals under the Medicaid EHR incentive program and will also need to demonstrate meaningful use of Certified EHR Technology.  We do not preclude Complete EHR and EHR Module developers from designing novel approaches to displaying growth charts.  Finally, we concur with the commenter that suggested this certification criterion should be a baseline.  We reiterate that this certification criterion establishes a floor, not a ceiling, and we encourage Complete EHR and EHR Module developers to include additional functionality where it will enhance the quality of care that eligible professionals and eligible hospitals can provide.

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.