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Thoughts on the New CCHIT EHR Certification Paths

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Earlier today I posted a general explanation of the various CCHIT EHR certification paths as they were talked about at today’s CCHIT town call meeting. If you haven’t read that, go read it first and then come back so you know what I’m talking about when I say EHR-C, EHR-M and EHR-S.

Some of the comments made on the CCHIT town call today really got under my skin (imagine that). I just have to get them out there. Many of them I actually sent out on my twitter account in real time.

CCHIT Does Not Protect Doctors
The first one that reminds me of fingernails on a chalkboard is they repeatedly mentioned that the EHR-C certification was a protection for doctors. I’ve discussed this issue with CCHIT many times before. So, I don’t want to rehash it all here. However, I just don’t understand why CCHIT can continue to perpetuate this idea when no study has shown that it’s actually the case.

In fact, there have been many stories of clinics uninstalling CCHIT certified products for non-CCHIT certified products, because the certified EHR was unusable. Other people like to point to an EHR company that can pay for CCHIT EHR certification has more skin in the game and is less likely to fail. The facts show that many CCHIT certified EHR company are going under. So much for CCHIT EHR certification helping to protect the doctor.

Certainly a doctor selecting an EHR needs to be careful to select an EHR vendor that’s on firm ground. They also need to find an EHR that will be usable for them. They also want to select an EHR which they can implement successfully. Sadly, CCHIT has shown no proof (and in some cases the opposite effect) that it can solve any of these problems. CCHIT is planning for user ratings and usability measures, but we’ll talk about the challenges with those in future posts.

CCHIT EHR-C Certifcation
At one point in the CCHIT town call, they said, “An EHR-C would be done by EHR vendors who want a more comprehensive solution.” An EHR vendor doesn’t go and do this laundry list of requirements that’s made by someone other than their customers because they want a more comprehensive solution. In fact, I had one EHR vendor tell me that they went through the EHR certification list and found about 100 or so CCHIT requirements that produced no benefit to their customers.

Why then, you might ask, have EHR vendors been doing the EHR-C certification?

Up until now it’s been all about marketing their EHR. CCHIT has done a great job making doctors FEEL like a certified EHR is a safer bet despite that not being the case. The number of EHR vendors that were doing CCHIT certification was going down each year. That’s because EHR vendors didn’t care about the features, they just wanted to be able to tell sales leads that they were certified. Of course, this year we’ve seen a major spike with EHR vendors getting certified in anticipation of the possible ARRA funding requirement.

I’m not trying to say all the CCHIT certification requirement list is bad. Some of it is good and should be implemented, but that doesn’t mean 1. that an EHR-C vendor is going to be usable and 2. that ALL of the CCHIT requirements were worth the cost to implement.

CCHIT EHR-M Certification
EHR-M is an interesting twist on EHR-C certification. Basically CCHIT’s saying they’ll just take a specific component of the EHR-C certification and make sure it works. Sounds reasonable. I think this was designed for hospital systems (and sometimes group practices) which might use a combination of systems to accomplish possibly even more than a standalone EHR product could provide. Really could help solve the Hospital CIO’s problem with CCHIT that I posted previously.

One sticky issue with the EHR-M certification is if a hospital system used 5 different software packages as part of their implementation. If any 1 of those 5 software packages decides not to get EHR-M certified then, that location is up a creek. Certainly if they’re a large enough customer they probably have some pull. However, this could be a potential issue if all your vendors aren’t on board with EHR-M. I guess they could maybe just do the EHR-S certification for the system that isn’t EHR-M certified?

CCHIT EHR-S Certification
You thought I was going to be all negative in this post. Well, you’re wrong. I actually kind of like the idea of the EHR-S Certification. I’m not sure how it’s much different than trying to measure meaningful use, but that’s the topic for one of my next posts. That said, I like the idea of a relatively low cost way to certify your use of an EHR.

This does a pretty good job of solving the open source EHR certification problems. It handles the home grown EHR system problems. It deals with the smaller EHR vendors that don’t want to spend their development dollars on the full EHR-C certification problem. It even works for hospital systems that have a mixture of all sorts of systems, but have the required functionality.

The real challenge I see with EHR-S certification is how can CCHIT scale this certification and still keep the costs reasonable enough for a site to want to do this certification. However, if this is the certification type selected by ONC and HHS, why should CCHIT be the only one to do the EHR-S certification? Why couldn’t the requirements be open source and implemented by a whole group of certifying bodies? CCHIT is non-profit after all, so why should they care if other organizations participate in the EHR-S certification? Plus, by having multiple organizations doing the EHR-S certification you have some competition which keeps prices down.

I think it is also worth mentioning that this EHR-S certification could possibly shift the cost burden of EHR certification from the EHR vendors and on to the doctors. Not something many doctors are going to really like. It could easily be seen as a gamble for doctors to pay for the certification in hopes of getting the $44k EHR stimulus money jackpot. Although, the criteria for certification will be published and you should know if you’re going to pass or not before you get started (hopefully). So, let’s call it an educated gamble.

So much more to cover. More coverage of all these issues tomorrow.

June 17, 2009 I Written By

John Lynn is the Founder of the blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: and, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

New EHR Certification Pathways from CCHIT

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I participated in both of the CCHIT “town calls” that happened this morning and yesterday. I did miss the beginning of today’s call, but looking through the slides it looks like the presentation was more or less the same for both town calls. You can see the slides from both CCHIT presentations here. Between this and the HIT Policy Committee meeting yesterday there’s almost too much to digest. So, in my regular fashion I’m going to break down my analysis into lots of bite sized chunks.

The biggest change that was proposed/announced during the CCHIT meeting was three EHR certification pathways:
EHR-C: Certified EHR Comprehensive
EHR-M: Certified EHR Module
EHR-S: Certified EHR Site

Basically, the EHR-C is the same certification that CCHIT has been doing since the beginning. Certainly the requirements for the EHR-C certification could be changed, added to, modified in order to meet the ARRA requirements, but for all intents and purposes this is what CCHIT has been doing for years.

The EHR-M certification is where CCHIT will certify certain modules from a software vendor. If my understanding is correct, CCHIT plans to take the various criteria that comes out of ONC and HHS and then use those criteria to decide which modules will be certified. An EHR vendor, or even other HIT product vendors, could choose to just get e-Prescribing EHR-M certified. I guess the thought here is that a hospital system, for example, could use one software vendor for e-Prescribing, another for EHR, and another for HIE and as long as they are all EHR-M certified, then the hospital could qualify for ARRA incentives.

The EHR-S certification is essentially where CCHIT will certify a site (better defined as an organization) to show that they meet the various ARRA requirements. It was made abundantly clear that the EHR-S certification only certifies that the site meets the ARRA requirements and not necessarily that the software that site is using meets the requirements. I’m sure this will be a topic worth discussing. Basically, the EHR-S certification tries to certify that a site is using an EHR to the ARRA requirements.

How’s that for a summary of the new EHR certification pathways? Did I misunderstand anything or leave anything out? Let me know in the comments and I’ll update anything that’s not clear.

Now, look forward to more commentary on the benefits and challenges of these paths, the timeline that CCHIT has proposed, CCHIT EHR ratings, CCHIT Certification codes, and of course plenty more discussion on the latest meaningful use draft document. I’ll try to space out the posts as much as possible so as not to overwhelm you.

I Written By

John Lynn is the Founder of the blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: and, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus.