One of the better EMR bloggers out there, Margalit Gur-Arie, recently posted what she calls “EHR Mythology 101″ on The Health Care blog. Below I’ve copied her major topics and a few comments of my own about each topic. You can read her post for her comments.

The current EHRs on the market are outdated legacy systems
I’ve heard this comment a few times recently. Although, it’s mostly from industry insiders and not doctors. I don’t think doctors really know the difference or know the differentiation. Not because they couldn’t know, but they’ve just not generally invested the time to know the difference. It’s no wonder they come looking for any help they can find to narrow down the 300+ EHR vendors (I heard two people saying 600 this weekend) on the market.

Either way, there’s a reason they’re called legacy systems and the concept of doing agile development on a legacy system is universally bad (not just in Healthcare).

EHR prices are small fortunes
I’m still in disbelief that physicians are still paying small fortunes for an EMR. It’s just CRAZY!! There are so many other options out there.

EHR implementations fail because the software is unusable

Margalitit offered this comment, “[EHR Implementation Failure] has been linked however to lack of change management, poor choice of product, wrong expectations, insufficient training, lack of commitment and all sorts of peripheral lack of preparedness.”

A study to why the implementations fail would be a good one. I agree that unusable software is unlikely to be the real cause for most failures.

CCHIT certification doesn’t mean anything
CCHIT certification doesn’t mean anything. ARRA (HHS) certification does mean something. It just so happens that CCHIT will be providing the ARRA EHR certification. So, CCHIT matters because they certify EHR software for the government same as Drummond Group and likely a number of other certifiers will do. Either way, it doesn’t mean anything for doctors. I have yet to see any study that shows that EHR certification of any type helps doctors in any way. There’s a reason the VP of marketing was on the EHR certification call and not the clinical director. It’s a marketing tool and not a tool for doctors.

EHRs should be like Facebook
True. Facebook is more like a PHR than an EHR. Facebook is definitely different than an EHR, but I think there’s still many things that EHR vendors could learn from what Facebook’s been able to create.

EHRs should be about Clinical care not Billing
Should is the operative word. There’s a lot of things that should happen and then there’s the reality. EMR Billing is here to stay and will forever be a major part of an EMR. However, I think it is worthwhile to consider what an EMR might be like if it was about clinical care and not billing.

Big monolithic EHR products are bad

I heard some interesting discussion about this topic this weekend. I’ll be writing about it more in the future on EMR and HIPAA. At the end of the day, the idea of having one neck to ring when something goes wrong is a big deal. It’s been a big deal outside and inside healthcare and it will win the day in this case too.

Now I’m not an advocate of what I call Jabba the Hutt EMR vendors either. However, you can be a monolithic EHR vendor and not be like Jabba (big, slow to move, dominating, powerful, but have a hard time changing).

Physicians should wait until the perfect EHR is ready

I don’t fault physicians for waiting to know about meaningful use and certified EHR before implementing. However, those physicians who say they’re waiting for the perfect EHR really just don’t want to implement an EHR. There’s no such thing as a perfect EHR. The only perfect thing I know on this earth is my wife.

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.

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.“

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

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.”