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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 anybody was doubting that Drummond Group was ready to be a player in the EHR certification rule, I think this blog post should make them think twice. You can tell from the tone of the post that Drummond Group had been waiting for HHS to issue the final rule so they could get moving.

In the same blog post, Drummond Group provides a short summary of some of the major changes to the rule after the comments:

* Waiving of the 30-day delay in the effective rule. This is by far the most significant “change” in terms of how it impacts vendors, providers and hospitals. Typical procedure for Final Rules is to have 30-day delay after it is on the Federal Register before it becomes “effective”, but this can be waived in certain situations. What this means practically is that once the Final Rule goes into the Federal Register, say around July 1, the Temporary Certification Program will be active and ONC can begin processing applications from organizations like ourselves intending to be ATCBs. ONC does give themselves 30 days to process and approve the application so you still may not see an ATCB officially testing until possibly August.

* Temporary Certification Sunsets No Earlier than 12/31/11. The NPRM had stated that the Temporary Program ends (and the Permanent Program begins) when there is an accredited ONC-ACB. Now, the Temporary Program is given a clear window of operation through the end of 2011, and it may be extended if an ONC-ACB is not found by then. This gives more stability to the Temporary Program.

* All ATCBs Must Support Remote Testing. The NPRM had previously only required support of testing at the local ATCB facility. Now, remote testing is required for all ATCBs. Remote testing can be done either at the development site (vendor) or deployment site (provider or hospital implementation). Based on our DGI surveys, remote testing was by far the preferred method, and ONC also received the same feedback.

Drummond Group also suggests that ONC really did listen to the comments that were given. I don’t doubt this actually. The people I’ve met from ONC really do seem like good people that are trying to do their best within the government limitations. It’s just unfortunate that the government limitations are so onerous.

Now the real fun begins as the various EHR certifying bodies start to appear and EMR vendors get to decide which body they should use.

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.

In case you missed it, I posted on my other site about the NIST EHR Certification testing website. I still haven’t had much time to dig deep into what’s available, but one of my readers sent me the following (excuse the lack of form since they probably didn’t intend it to be published):

Boy, I don’t know what to think. Much of this seems to be piles of words referring to zillions of links.

However, I did find a place where it talks about the “Draft Test Procedures.” Under that heading it lists the “Draft Test Method” for a category such as Maintain Active Medication List. It shows, for instance, that you must be able to enter something like:

RxNormCode Medication Brand Name (generic name) Dose Form Route Frequency DateStarted DateStopped
205875 Diabeta (glyburide) 2.5 mg Tablet By mouth(po) every morning 9/16/09
617314 Lipitor (atorvastatin calcium) 10 mg Tablet By mouth(po) daily 5/5/08

and then modify, and later list. So, I guess if a system didn’t have the ability to enter “route” then does this mean the system fails? Or, does allowing an improper form of “route” for the med make it fail? Unclear. On the other hand, because you can enter and modify all of the above, does it “pass”? What is missing, from my opinion, is the useability factor. My docs, for instance, like to see the history of dispensing of a given medication. Knowing and being able to easily see the various dispensings of amoxicillin is key to practicing good medicine. The Draft does not address that and is, in my opinion, a major missing point. One can have a system where doing anything takes lots of clicks and typing, or common things can be done in a few steps.

The rest of the Draft Test Methods are the same. Enter this, change that, make a list.

It would be nice if someone could tell me what it is I’m missing.

Does anyone else get the feeling that this certification stuff is going to be a mess and add little value for doctors?

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.

Anyone that works in Healthcare IT knows who John Halamka is and so of course I was interested in his post of his top 10 impressions after HIMSS. It’s an interesting list and I think he does a pretty good job of looking at things from a very high level. Here they are as posted on his blog:

1. Meaningful Use is everywhere. Vendors are promising EHRs, modules, appliances, and services to help clinicians achieve it. I had dinner on Monday night in a small Indian vegetarian restaurant. Sitting next to me were 3 engineers from Bangalore who were arguing about the details of Meaningful Use in between bites of vegetable curry. I could not escape Meaningful Use anywhere!

2. Certification is everywhere. It’s particularly ironic that many vendors claimed their systems were certified, even though the certification NPRM was just released today, making compliance with the new certification process in time for HIMSS impossible.

3. Cloud computing, Software as a Service and ASP models are popular tactics to accelerate EHR rollouts. There are still lingering concerns about how to ensure privacy in a cloud environment.

4. Several firms such as Intersystems, Axolotol, and Medicity are offering HIE platforms that include many of the standards noted in the IFR. The marketplace for HIE products is just emerging and it’s hard to predict who will become the market leader.

5. The Continuity of Care Document is gaining traction. I found many vendors supporting CCD exports from their EHRs. A company called M*Modal , has developed natural language processing technology that captures dictated content in its original context (ontology-driven
rules) as a CDA document.

6. Consultants abound. It’s clear that Regional Extension Centers and Health Information Exchanges will require expertise and staffing from professional firms. They all had large booths at HIMSS.

7. 30,000 people attended, including 10,000 I did not recognize (just kidding). It’s clear to me that many IT professionals, even those with limited healthcare domain expertise, attended HIMSS to better understand how they could participate in the euphoria of HITECH stimulus dollars.

8. Self service kiosks for patient identification and self-registration are now mainstream. Just as we print our airline boarding passes, we can now use credit cards or biometrics to check into ambulatory care appointments and automatically settle all co-pay balances.

9. Image exchange in the cloud is being offered by several vendors. As I mentioned in Monday’s blog, Symantec announced an appliance for small clinician offices that cloud enables all imaging modalities using a facebook-like social networking invitation to share/view images.

10. PHRs and patient engagement are becoming more mainstream. Google and Microsoft continue to innovate in the non-tethered PHR marketplace.