I’ve long been a proponent of having multiple EHR certification bodies. Competition does amazing things for a system and having one certification body would be a horrible thing for the EMR world. Certainly we all know that CCHIT is going to be there as an EHR certification body. The question is whether anyone is going to step forward and provide CCHIT some competition. Does anyone know of any groups that are applying to be a certification body? I’d love to know about them.
Russ Reese from MXSecure linked me to a PDF file that describes the features that an ONC approved EHR certification body (PDF) should have. There’s some HUGE problems with this criteria.
First and most important is that it basically requires the EHR certifying organization (they call it a Recognized Certification Body or RCB) be able to create certification criteria. If HHS is going to provide the criteria, then why should a new EHR certification body need the infrastructure and feedback loop to be able to create the criteria? The answer is that they don’t. Seriously, why should a new EHR certification body have to be able to “provide a publicly available roadmap for the development of future certification activities” to be a certifying body?
That’s just part of the problem. The requirements also state that you must have “a demonstrated process for, and experience in, certifying EHR software to criteria recognized by the Secretary.” That basically excludes EVERY organization except for CCHIT. Why should anyone apply?
Add in the requirements of the governing bodies, steering committees, board of directors from every group and you have a recipe for no competition with CCHIT. Certainly I can understand that diversity is important when creating a criteria. However, diversity on those groups, which will cost a lot of money to have in the first place, won’t be important if you’re just ensuring that HHS criteria is met.
At the bottom of the PDF file that talks about these criteria, there’s a place for public comment. Although, I haven’t been able to tell when this document was published to know if we’re within the 60 day window. If someone knows better than I, please let me know in the comments. I’ll be sending off a note myself to try and help change this document. The document is entitled “Interim Guidance Regarding the Recognition of Certification Bodies.” Hopefully the “Interim” means that we can still provide comment on the document.