My EHR Certification Recommendations – For EMR Vendors

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No one asked (well at least not publicly), but I wanted to share my opinions on what EMR vendors should be doing in regards to EHR certification. I guess you could say this is a small sample of the advice I’d offer as an EMR vendor advisor albeit not EMR vendor specific and with less detail. Take it for what it’s worth.

If I’m an EMR vendor today, I’d definitely avoid going out and getting either the CCHIT Certified 2011 or the Preliminary ARRA 2011 EHR certifications. One reader of this site emailed me an estimate of $100,000 up front and $9,000 renewal fee per year for the CCHIT certifications they were considering. Certainly it could be less if you just go with the Preliminary ARRA certification, but regardless the cost is quite large.

Instead, I’d take a more reasoned approach. There are 2 important things for an EMR vendor to consider when it comes to EHR certification.

1. EMR vendors need to be able to sell product and allay customers concerns about your EMR not being certified. Many people will be asking for EHR certification and even more people will be asking for the EHR stimulus money.
2. EMR vendors want to make sure that they’re well positioned to become HHS certified (at least most of them) once HHS pulls back the curtain and shows us what that will be. However, they don’t want to waste development dollars on features that don’t improve their product.

With these two considerations in mind, my suggestion is for EHR vendors to take a look at the Preliminary ARRA Certification (in particular the Meaningful Use Matrix Tagged for CCHIT Reference document (pdf) is a good start). Take the list of criteria that CCHIT has created and matched up with the meaningful use matrix. Then, evaluate the criteria to see which ones you don’t have and would be of value to your customers. Next, prioritize that list and add those criteria that add value to your EHR development plans.

The concept is simple. Despite my ripping on CCHIT, there are certain aspects of their criteria which are incredibly valuable to a doctors office. Take those criteria that will provide value to your EHR end users and spend your development time adding value to your product. Then, once HHS/ONC/CMS publishes the final criteria for achieving EHR certification you will have hopefully already developed a number of the criteria while not wasting time developing CCHIT criteria which won’t be required by HHS/ONC/CMS. Once we know what the real EHR certification criteria is going to be, you can decide which “certified EHR” option is best going forward.

There is one caveat to this suggestion. You’re going to have to be able to tell a compelling story to some clinics about why you aren’t doing CCHIT certification. However, from what I’ve heard from other EHR vendors and my experience talking to people, it’s not a huge hurdle to explain how you’re going to get them access to the EHR stimulus money and how CCHIT certification would have increased the cost of your EHR product while not improving the life of the doctor. Let them know that you evaluated the CCHIT criteria list and implemented those of value. Then, list one CCHIT criteria that doesn’t add value and they should see pretty clearly why you made a good choice.

What do people think of this advice? Does it make sense? Is there something else I’m missing?