I first heard about the new Secure, Branded App Store for Hospitals and Healthcare called Happtique in early December on Techcrunch. At its core, I think it’s an interesting idea to try and filter through what the article claims are “23,000 mobile health apps available for iOS and Android.” Helping physicians and hospital administrators filter through these apps could be valuable. Plus, most hospital administrators would love a way to have a phone that was limited on which apps it could download.

Well, it seems that the company has shifted gears a little bit. As Brian Dolan from Mobi Health News reported, Happtique is taking the first steps to setting up a certification for mobile health apps.

Happtique, a healthcare-focused appstore, announced plans to create a certification program that will help the medical community determine which of the tens of thousands of health-related mobile apps are clinically appropriate and technically sound. The company has tapped a multi-disciplinary team to develop the “bona fide mHealth app certification program” within the next six months. The program is open to all developers and will be funded by developer application fees.

It will certify apps intended to be used by both medical professionals and patients.

While I think that providing some way for people to filter through the large number of mobile apps, I think certification is a terrible way to go about it. Many people know I’ve written many an article about CCHIT pre-EHR incentive money and how screwed up the CCHIT EHR certification was for the industry. I think it’s just as bad news for Happtique to create a certification for the mobile health industry.

Turns out that Happtique seems to have agreed with this idea back in October 2010 where they said in a MobiHealthNews interview, “We are not in the business of opining whether an app is ‘good’ or ‘bad’ though. That’s not our role. Apple doesn’t do that and others don’t either. If the FDA indicates that an app is a medical device and needs to be regulated, well, that’s a different situation and we can take it out of the store.” Seems they’ve seen a different business opportunity.

They have a couple recognizable names on their board to create their certification including Howard Luks and Dave deBrokart (better known as e-Patient Dave), but I believe they’re going to find that it’s an impossible task. First, because they won’t have the breadth of knowledge needed to create certification requirements for every type of mHealth app. Second, what value will the certification really provide? Third, how do you make the certification broad enough to apply to all 20,000+ apps while still providing meaning to those using a very specific mHealth app? Plus, I’m sure there are many other issues I haven’t thought of yet.

The problem with these certification ideas is that they start with great intentions, but always end up bad.

HITECH Answers recently posted a great post that gives a run down of the EHR Incentive program’s progress in 2011. Here’s their list with my own analysis and commentary of each point.

123,921 Eligible Professionals have registered for EHR Incentives, 15,255 have successfully attested to meaningful use in the Medicare program.
This seems like such a HUGE difference in numbers. That’s just over 12% of Eligible Professionals that registered attested to meaningful use. Does this mean that we’re going to see a tidal wave of meaningful use attestation in 2012? Possibly.

I believe that we’ll see more eligible professionals attesting to meaningful use in 2012. However, the question is how many of those other 108,666 will attest to meaningful use in 2012 and how many are like the Happy EMR Doctor who just registered to see the MU process. I wonder how many first hand meaningful use experiences by doctors will scare doctors away from MU attestation.

3.077 Eligible Hospitals have registered EHR Incentives and 604 of those have successfully attested to meaningful use.
This is almost 20% of hospitals that have registered that have attested to meaningful use. It’s not surprising that this number is a lot higher than eligible professionals. I still believe that the wave of meaningful use attestation will come from these other 2473 hospitals and probably many more that still haven’t registered. I haven’t seen a good number of how many hospitals are in the US. Does anyone know that number? The EHR incentive money that goes to hospitals will dwarf those of eligible professionals.

$2,533,689,145 has been paid out in Medicare and Medicaid Incentives.
$2.5 billion sent out in 2011. I just went back to the first time I tagged meaningful use on this site on April 3, 2009 (coincidentally I have 19 pages of 10 posts each tagged with Meaningful Use). Amazing to think that it’s taken basically 3 years to spend $2.5 billion on EHR.

277 hospitals have received payments under both Medicare and Medicaid and of those 12 were CAHs.
That’s about half of the hospitals that have attested to meaningful use under Medicare are also getting the Medicaid EHR incentive money as well.

22% of eligible professionals that have been paid EHR incentives are Family Practitioners and 20% are Internal Medicine.
I must admit that I would have thought that the percentage of family doctors that got paid EHR incentive money would have been a lot higher. I guess when you have so many other specialty areas I shouldn’t be that surprised. I also wonder why the internal medicine number is so high. These numbers actually make me believe that a lot of family practice doctors are sitting out when it comes to meaningful use.

41 States Medicaid programs were open for registration. Two additional States launched in January of 2012.
I wonder what’s holding back the other 7 states. From what I’ve seen all the states will eventually get there.

More than 1500 EHR products have been certified by ONC-ATCBs.
That’s a lot of EHR software. I still put the EHR company list at about 300 EHR vendors. 1500 includes multiple versions of the same software, partial EHR certification for products like data warehouses, ePrescribing, etc. The best thing that’s come from the ONC-ATCB program is that it has made EHR certification basically irrelevant in the EHR selection process. Every EHR vendor is certified now. This is much better than the false assurances that EHR certification provided before. I still dislike what EHR certification has done to the industry, but at least it’s not misleading doctors the same way it was before.

For those of you that are relatively new to EMR and HIPAA, you might not appreciate this post as much as long time readers of EMR and HIPAA. A few years back, I admit that I was pretty harsh on CCHIT and their EHR certification. I remember one guy stopping me at a conference and after realizing who I was asked, “so what’s your issue with CCHIT?” I was happy to answer that I thought they misled the industry (doctors in particular) by saying that the CCHIT certification provided an assurance that the EHR was a good EHR. They never came outright and said this, but that’s what EMR sales people would communicate during the sales process.

In fact, EHR certification was incorrectly seen by many doctors and practice managers as the stamp of approval on an EHR being of higher quality, more effective, easier to use, and was more likely to lead to a successful EHR implementation. EHR certification today still has some of these issues. However, the fact is that the EHR certification doesn’t certify any of the great list above. If EHR certification of any kind (CCHIT or otherwise) could somehow assure: a higher implementation success rate, a better level of patient care, a higher quality user experience, a financial benefit, or any other number of quality benefits, then I’d support it wholeheartedly. The problem is that it doesn’t, and so they can’t make that assurance.

So, yes, I do take issue with an EHR certification which misleads doctors. Even if it’s the EHR salespeople that do the misleading.

I still remember the kickback I got on this post I did where I said CCHIT Was Marginalized and the post a bit later where I said that the CCHIT process was irrelevant. Today, I came across an article on CMIO with some interesting quotes from CCHIT Chair, Karen Bell. Here’s a quote from that article.

In addition, the Office of the National Coordinator for Health IT’s (ONC) new program has provided two new reasons for certification: proof that an EHR can do the things that the government wants it to do, and to enable eligible providers and hospitals to get EHR incentive money.

“The idea is not to assure the product will do all things that are desired for patient care, instead, the idea is to stimulate innovation,” said Bell. As a result, the program is considered a major success because more than 700 certified health IT products are now on the ONC website. “The idea was to get a lot of new products started. This is a very different reason for certification than what we began doing several years ago,” she said.

However, just because CCHIT or another ONC-Authorized Testing and Certification Body (ONC-ATCB) doesn’t test and certify for a particular ability, that doesn’t mean the EHRs don’t have it. “It’s just up to [the provider] to make sure the vendors have it,” said Bell.

I first want to applaud Karen Bell and CCHIT for finally describing the true description of what EHR provides a clinic assurance that:
1. The EHR does what the government wants
2. You are eligible for the EHR incentive money
Then, she even goes on to say that it’s up to the providers to make sure the vendors have the right capabilities for their clinic.

I imagine Karen and CCHIT would still probably say that the CCHIT “complete” EHR certification provides assurance that…< fill in the blank >, which the ONC-ATCB EHR certification doesn’t provide. The happy part for me is that even if CCHIT says this, no one is really listening to that message anymore.

Yes, CCHIT has essentially become irrelevant.

I can’t remember anyone in the past year asking me about CCHIT certification. From my experience, many people care about ONC-ATCB EHR certification, but they really couldn’t care less if it comes from CCHIT, Drummond Group, ICSA Labs, SLI Global, or InfoGuard (That’s all of them right?). Have any of you had other experiences?

I also do enjoy the irony of this post coming right after my post about differentiation of EMR companies (Jabba vs Han Solo). CCHIT is the reason that I know so much about the challenge of EHR differentiation. CCHIT’s efforts provided some very valuable (and lengthy) discussions over the past 5 years about ways to help doctors differentiate between the 300+ EHR vendors. As you can see from my comments above, I was just never satisfied with CCHIT being the differentiating factor. As you can see from my post yesterday, I’m still searching for a satisfactory alternative for differentiating EHRs. Until then, we’ll keep providing an independent voice a midst all the noise.

If you’ve been following this blog for a while, then you probably remember my many rants about the lack of value in EHR certification. In fact, Jim Tate asked me at HIMSS where my dislike of CCHIT came from. I think I told him that I probably got it from EMRUpdate. Certainly that’s where I learned a lot about EMR and EHR and certification in general. However, as I consider his question, my real distaste with CCHIT and quite frankly EHR certification is that it provides little to no value to doctors.

Looking back at all the discussions I had last week with those attending HIMSS, I’m really happy to say that EHR certification was almost never a discussion. Pretty much everyone either was a certified EHR or was almost done with the EHR certification process (which is in line with ONC’s desire that all EHR software be certified).

I still feel that certification provides little value, but I’m really happy to see that EHR certification has basically left the discussion. If everyone has it, then doctors don’t and won’t look to it as a way to select an EHR. I think that’s a very good thing.

As I’ve thought more about EHR certification, it’s funny that someone hasn’t come out with some healthcare IT certifications that would actually provide value to doctors and healthcare. Here’s just a few ideas off the top of my head of items that could be meaningfully certified:

• Privacy
• Security
• Data portability
• Freedom of data
• SaaS hosting services

The interesting thing is that many of these certifications could be provided well beyond EMR software and into other healthcare IT products (and even beyond if someone so desired). Certainly the existing EHR certifications try and provides some of these items, but they’re so general and non specific that they aren’t very useful.

For example, the privacy certification could include not only that the data is encrypted but could specify which type and level of encryption is used. Plus, the certification could actually test the encryption to make sure it was implemented properly. I know some eFax vendors that would love this type of certification.

A certification that provides value wouldn’t likely be a simple pass fail certification. Maybe you do set a bar for each requirement that allows you to place a certification badge on that product. However, users should be able to dig into the details of the certification and see what was found during the process. For example, if you make sure they handle passwords correctly, a certification should provide a list of protections that are built into the software that’s being certified (ie. minimum characters, required characters, 2 factor authentication, number of failed passwords before lockout, etc).

If I weren’t so busy with my healthcare IT blog network, I’d consider doing some of this myself. Not only is it a great business, but could really provide value to healthcare. If you start it, just save me a spot as an advisor.

One of my readers recently linked me to an article from back in July that talks about providers lack of understanding of EHR certification and the possibility of EHR certification bodies beyond CCHIT. Here’s an excerpt from the article:

The Office of the National Coordinator for Health Information Technology has made it clear that it wants multiple EHR certification bodies, but that message apparently has not made it out to many physician practices. According to a survey by Burlington, Vt.-based consulting firm CapSite, 69 percent of healthcare providers are unaware that there will be alternatives to the Certification Commission for Health Information Technology in terms of certifying ambulatory EHR systems.

Additionally, 52 percent of the 850 providers surveyed incorrectly believe that CCHIT certification is a prerequisite to receiving Medicare and Medicaid bonus payments for meaningful use of EHRs. In reality, ONC will designate authorized testing and certification bodies, which then will test and certify EHRs on behalf of vendors.

As most of you know I have a real disdain for misinformation. I’m all about exposing the truth and spreading the knowledge as far as possible. So, you can imagine my reaction to providers not understanding that there are multiple EHR certification bodies and that all of the EHR certification bodies can provide doctors access to the EMR stimulus money.

The only problem is that I’m guessing that most readers of this blog already know this information. I like to think that readers of this blog are smarter and more informed than those who don’t. I was going to do a poll to see who knew what. Only problem is that reading above you’d know the answers.

Either way, if readers of this blog work to inform the people around them that there are multiple EHR certifying bodies (Drummond Group and InfoGuard with others on the way) and that it doesn’t matter which EHR certifying body you use then I think we’d have some impact for good on the EHR world!

One of my more interesting meetings at AAFP was with a company called SLI Global Solutions. The meeting was so interesting, because SLI Global Solutions plans to apply to become an ONC-ATCB organization very soon. This coming after the announcement of the first ONC-ATCB certified EHR from Drummond Group and CCHIT along with the announcement of InfoGard as an ONC-ATCB and Weno Healthcare’s plans to become an ONC-ATCB.

We obviously had a long conversation about the EHR certification, but suffice it to say that SLI Global Solutions is going full steam ahead to become an ONC-ATCB. It sounds like they’ve been doing a number of other certifications previously. They’ve even done some consulting work in healthcare.

When I asked SLI Global Solutions what they thought would help them to differentiate themselves from the other ONC-ATCB, one response was that they were really good at providing feedback and helping organizations through the certification process. I personally think that many EHR vendors and other healthcare organizations that need to certify for the EMR stimulus money are nervous about the unknown issues related to certification. If SLI Global Solutions can provide them a feedback loop then it could go a long way to relieving the nerves. This is the main suggestion Jim Tate makes in his post about selecting an ATCB.

I asked SLI Global Solutions how much they planned to charge for the EHR certification. Here was their response, “We have not finalized the pricing yet because we are contemplating ancillary services pre and post certification but we will likely be in the $20,000 USD ballpark.”

With SLI Global Solutions, that would make 5 ONC-ATCB and I’m guessing there are other companies like this that will become certifying bodies as well. I’m all about competition and so the more ONC-ATCB the merrier.

It does make me wonder how many ONC-ATCB the market can support. Not to mention, there’s the interesting question of whether they’re a bit late to the party. I guess time will tell.

Today, CCHIT announced their first ONC-ATCB certified EHR a day later than Drummond Group’s ONC-ATCB announcement. Although, CCHIT is announcing 33 EHR vendors (21 complete ONC-ATCB certified EHR and 12 module certified). No real surprises on this list. They were the previously CCHIT certified EHR companies. That gives us 36 total ONC-ATCB EHR right now (or 24 if we’re talking complete EHR certification).

Here’s the list of Complete ONC-ATCB certified EHR:
ABEL Medical Software Inc.
ABELMed EHR – EMR / PM

Allscripts
Allscripts Professional EHR

Aprima Medical Software, Inc
Aprima

athenahealth, Inc
athenaClinicals

CureMD Corporation
CureMD EHR

The DocPatientNetwork.com
Doctations

eClinicalWorks LLC
eClinicalWorks

Epic Systems Corporation
EpicCare Inpatient – Core EMR

Epic Systems Corporation
EpicCare Ambulatory – Core EMR

GE Healthcare
Centricity Advance

gloStream, Inc.
gloEMR

Intuitive Medical Software
UroChartEHR

MCS – Medical Communication Systems, Inc.
iPatientCare

Medical Informatics Engineering
WebChart EHR

Meditab Software, Inc.
IMS

NeoDeck Software
NeoMed EHR

NextGen Healthcare
NextGen Ambulatory EHR

Nortec Software Inc
Nortec EHR

Prognosis Health Information Systems
ChartAccess

Pulse Systems
2011 Pulse Complete EHR

SuccessEHS
SuccessEHS

Here’s the list of module ONC-ATCB EHR Certifications:
NOTE: CCHIT does make a comment that some of these may become complete EHR certifications later.
Allscripts
Allscripts ED

Allscripts
Allscripts PeakPractice

Health Care Systems, Inc.
HCS eMR

NexTech Systems Inc.
NexTech Practice 2011

nextEMR, LLC
nextEMR, LLC

PeriGen
PeriBirth

Sammy Systems
SammyEHR

T-System Technologies, Ltd.
T SystemEV

Universal EMR Solutions
Physician’s Solution

Vision Infonet Inc.,
MDCare EMR

WellCentive
WellCentive Registry

Wellsoft Corporation
Wellsoft EDIS

Drummond Group just posted the news of the first 3 EHR vendors which have been officially certified EHR for the ARRA EHR stimulus money. Looks like Drummond Group won the race to be the first to certify an EHR.

The interesting thing for me is the list of 3 EHR vendors that became the first certified EHR:
PARADIGM (QRS Inc.)
ifa EMR (ifa united i-tech Inc.)
ChartLogic EMR (ChartLogic, Inc.)

I consider myself pretty well informed about EMR vendors, but I only realy knew 1 of the 3 and I’d maybe heard of one other, but just by name. As all the ONC-ATCB certified vendors start completing their EHR certification, I think we’re going to learn about a WHOLE lot of EMR vendors that very few people knew about previously.

I also find it interesting that all 3 EHR vendors have already updated their website in some way to represent the new ONC-ATCB EHR certification.

Note: We need a new way to identify the certified EHR. ONC-ATCB just doesn’t have the right ring to it. I might work on this problem.

The good people over at >HITECH Answers must have more time on their hands than I do. They got on the CCHIT conference call where they talked about their newest ONC ATCB certified EHR program. Here’s a portion of the HITECH Answers summary which includes some CCHIT pricing details:

The ONC-ATCB Certified 2011/2012 Toolkit will help prepare health IT companies and EHR developers for testing. You can purchase the toolkit for $1000. Pricing will be in tier levels and range from $8K to $34,300K. They want to do the testing in a single day. There can be an accumulative approach where modules can be certified and added to the current certification without having to retest previously certified criteria.

It still feels wrong that they charge you $1000 for the toolkit you’ll need to use in order to pay them $34k more dollars to become certified. Uhh…yeah.

The fact that you can use a cumulative approach to certification is a difference between CCHIT and Drummond Group. Drummond Group has said that you would have to recertify everything if you wanted to do more modules.

HITECH Answers also mentioned that CCHIT has a program called EACH (EHR Alternative Certification for Hospitals) that will certify EHR technology in place for legacy and custom programs. They’d been calling this the EHR site certification before.

They also did a quick poll on the CCHIT call with the following results:
“Using the interactive polling option of the meeting, CCHIT asked attending vendors what their plans on certification were. In a quick response from about 250 vendors, 24% said they were intending to certify immediately, 45% said in the next few months, and 8% where not sure.”

Don’t ask me what the other 23% of responses were. However, these results do point to my belief that most EHR vendors will certify.

I’ve written previously about the cost of EHR certification with Drummond Group and CCHIT. However, this just addresses the hard cost of certification that’s paid to the certifying bodies. This cost doesn’t take into account a lot of other costs associated with becoming a certified EHR like the cost to develop and test the features that certification requires.

Keith Boone on his blog Healthcare Standards has done a great blog post that evaluates the other costs associated with certifying an EHR software beyond the fee you pay to the certifying body. If you’re an EMR vendor, this is an article that you definitely want to look at and consider. Plus, I’d love your feedback on things he missed or where he might have missed costs or estimated to high on costs.

Here’s Keith’s projections for EHR certification costs based on his estimates:
Average yearly developer salary: $80,000
Fully Burdened yearly cost: 200,000 – 240,000
Times the length of the project (~5.5 years)
Total certification labor cost: $1.1M – $1.32M

Of course, this number matches the estimates that came out with the HITECH act as well. ONC estimated between $500k-$1.5 million. So, this is pretty close.

I’ll leave the impact (good or bad) of this expense open for discussion. I think most people know where I stand on it.