The Drummond Group has just officially announced on their blog their intent to apply for and test EHR software to provide an alternative EHR certification to CCHIT. Here’s a few portions of their announcement:

After a thorough review of the recent NPRM along with months of consideration, DGI is excited to announce that we will be applying to be an ONC-ATCB this year.

As mentioned before, receiving the HHS requirements to become an authorized EHR testing and certification body was the missing piece in our decision to move forward. Now that we have that piece, we feel confident in announcing our intention to formally apply.

In our review of the NPRM, we found it sound, reasonable and a big step forward for formal testing and certification criteria to support Health IT. We will offer our comments as requested, but overall it was an excellent effort.

And this point about Drummond Group’s long term plans for EHR certification:

Last point. We won’t spend too much time here on this blog talking about the Permanent Certification program given the more immediate concerns of the Temporary Certification program. We will say we plan on being part of the Permanent Certification program. More importantly, we want to convey that since our initial press release last November, we have known that we are not in EHR testing for the short haul, but rather, the long term.

Sometimes it’s the little things you catch at an enormous conference at HIMSS that are the most powerful. One of those came for me when I was talking to the VP of marketing from one of the EHR vendors on the floor. This was one of the most interesting people I met with at HIMSS.

As we were talking he kind of said off hand that one of the visitors to his booth had said Allscripts isn’t CCHIT certified.

Now I should clarify. Allscripts was CCHIT certified back in 2007. However, they didn’t do CCHIT certification and in 2008 but they still haven’t done any of the 2011 full CCHIT certification or Preliminary ARRA certification either.

As a side note, CCHIT has moved or taken down the previous years certification lists from their website (not sure why or where they moved them) (UPDATE: You have to drill down to the categories and you can find the previous years). However, they are listed on the EMR and EHR wiki.

The interesting point here is that Allscripts, an EHR company with possibly 21% EHR market share, hasn’t bothered with the CCHIT certification.

I have no doubt that Allscripts will be HHS certified (or whatever they end up calling the certification). However, they haven’t seen the need to go after the CCHIT certification. No doubt there sitting there waiting to get a cheaper EHR certification. This is true for a few hundred other EMR vendors as well.

Another interesting sign of the move away from CCHIT certification and on to the HHS certification.

And yes Allscripts, I am still mad at you for shutting me out of your party at HIMSS despite having registered and read the dozen or so emails you sent reminding me that I registered, but never telling me that I had to stop by your booth for a wristband.

I must admit that I’m so happy to be home from HIMSS. It was a fantastic couple of days, but it’s always nice to be at home. Not to mention, posts are so much more fun on a regular keyboard with 2 monitors. Of course, my email box is full of the notes that I took during the various interviews I did at HIMSS. So, you can expect a lot more posts talking about the things I learned and saw at HIMSS. Not to mention a video series of innovative and interesting products at HIMSS (Sponsored by Practice Fusion).

For my first post after HIMSS, I decided that I couldn’t help but post about the CCHIT town hall at HIMSS. I really said a lot of what I thought on my twitter account, but I’m sure that many missed it. So here’s a short summary of my thoughts with some other commentary on Mark Leavitt’s swan song at HIMSS.

The first thing that bothered me most is what has bothered me about CCHIT for a long time. However, this time I could document first hand the things that CCHIT was saying that was confusing doctors about what the CCHIT EHR certification was all about. Here’s what I recorded them saying (usually on their powerpoint too) that really doesn’t tell the whole story:
“Maximal assurance of comprehensive, integrated EHR capabilities”
Maximal assurance of what? That the EHR is comprehensive? No doubt doctors will see this as saying that a certified EHR will have all of the EHR features that they need. However, how does CCHIT know that it will have all the features all of the various types of practices need? Of course they don’t. They would even admit that it doesn’t. It just is able to run their test scripts based on a list of requirements. That’s where they confuse doctors.

“EHR with all necessary functionality”
and
“Everything you need in an EHR if you do the comprehensive certification.”
Same principle as the previous comment. How can they know what’s necessary? They don’t.

As I sat there listening to this, I wondered if I should get up and ask them a question. I wasn’t sure that me asking a question would be of any value. Then, I decided that I should at least try and help those in the audience to understand the real benefits (or lack thereof) of CCHIT certification. So, I got up and asked the following question (more or less):

What type of assurance does CCHIT offer to doctors? Does it offer better patient care? Are certified EHR more likely to be implemented successfully? What assurance can you offer beyond just talking about the process you went through to create the criteria?

They both (Mark Leavitt and Alisa Ray) kind of looked like they didn’t quite understand the comment. However, Mark basically responded that CCHIT doesn’t make any guarantee of increasing successful EMR implementations or improve patient care. He said that he didn’t think anyone could make that guarantee. CCHIT assures doctors that it meets the criteria that has been created.

Many people wonder what I have against CCHIT. I actually don’t really have any real ties to CCHIT (see my previous post). It just really bothers me when doctors get the wrong impression based on a miscommunication. I don’t like it when EMR salespeople confuse doctors through EMR sales miscommunications and I don’t like when doctors don’t understand what they’re really getting from a certified EHR.

The real problem is that even writing this post, far too few people will get the real message about the benefits (or lack thereof) that are provided by CCHIT certification. Although, I was pleased by all the people I’d never met before stopped me around the conference and told me that I asked a very important question at the CCHIT town hall.

Enough of that for now. Here’s some of the other items that I tweeted about CCHIT (some additional comments in italics):
CCHIT to certify Oncology and Women’s health(Obstetrics and Gyn). Will doctors care? EMR vendors might.

CCHIT had 23 comprehensive and 23 modular EMR cert applications.
46 brave EMR vendors. Although, I think this number is a little misleading. I talked to one of the EHR vendors that has the comprehensive certification and they said that there are only 2 that really have the comprehensive EHR certification. All the rest are “provisional.” I didn’t check those facts, but that says something if indeed it’s true.

CCHIT has announced site certification, but we don’t yet know if HHS will recognize an EHR site certification, no?
After the ONC town hall we now know that ONC will be fine with this as a secondary method of certification if the EHR certifying bodies see it as appropriate.

Nice to see that Mark Leavitt’s recommendations all use CCHIT products. I have a few other options people might consider that don’t.
Mark also referred to not going after a certification to be like gambling. Coming from Vegas I’m not sure I like his gambling reference. However, I really do think there are other options to CCHIT certification. Drummond Group and a third one I learned of at HIMSS which I’ll be writing about shortly too. Although, it certainly makes sense why Mike wouldn’t have acknowledged the other bodies. Although, isn’t CCHIT a non profit? Shouldn’t they just want the best interest of the industry?

With the government program we don’t create the criteria anymore. -Mark Leavitt of CCHIT

CCHIT site certification will be hospitals first. Ambulatory site EHR certification later?
Makes sense that CCHIT would go where the money is, but not a happy thing for the small doctors offices.

“We’re doing EMR usability at a kindergarten level and some EMR vendors don’t pass that.” -Mark Leavitt
This is a really sad fact. It’s nice of Mark to acknowledge it. One other person I talked to at HIMSS suggested to me that CCHIT shouldn’t be doing EMR usability testing at all. However, I’m really not sure what it says about an EMR that can’t pass the simple usability tests that CCHIT does do.

I’m always amazed at how little connection CCHIT has with ONC/HHS. Seems like a telling thing that they don’t.

FierceEMR has really hit the healthcare IT arena in force over the past 6 months. They even have a big party planned for HIMSS. I’ll probably be stopping by since it’s the day after the New Media Meetup at HIMSS. Well, one of my favorite healthcare IT writers, Neil Versel wrote an article for FierceEMR that really caught my eye. It was titled, “Kibbe: New ONC standards make CCHIT process ‘irrelevant’”

If you’ve read this blog for any time you know that I’m an enormous fan of CCHIT (that was in the sarcasm font in case you couldn’t tell). I even declared the Marginalization of CCHIT back in July of last year. So, obviously I agree with David Kibbe’s assertion that the CCHIT process is irrelevant thanks to the HITECH act. A section of the article linked above describes some of the major problems with CCHIT:

Kibbe long has said the CCHIT certification process discourages innovation by being too complicated and costly for new, small companies that otherwise might shake up the EHR market with lower-priced, easier-to-use products. He also has held that the certification body was too closely tied to the health IT establishment. “CCHIT in effect acted as judge and jury for its own industry’s definition of EHR software, inhibiting alternative approaches that would embrace component or modular architectures, web-based delivery also known as ’software-as-a-service,’ and practical means of achieving interoperable data exchange between applications from different vendors,” he says in a recent blog post.

No doubt the CCHIT criteria is no longer meaningful. The only problem is that a question still haunts my mind, “Did we just move the flawed process from CCHIT to ONC?”

We’ve had a lot of discussion in the past about the cost of EHR certification. It’s been one of the biggest complaints about CCHIT and their EHR certification. One of my readers wanted me to post again about the costs and how this will be such a challenge for new EHR vendors.

First, the problem isn’t that a new EHR vendor couldn’t afford the cost if they wanted to pay it. The problem is that it provides very little benefit to the end users and at the end of the day the cost of the EHR certification would be passed on to the doctors who purchase the EHR.

I’m going to use round numbers, but you can see the detailed CCHIT EHR certification costs on my previous post. Basically as it stands today, full CCHIT EHR certification will run a vendor $37k or more to become certified. Of course, if you just want to be Preliminary ARRA Certified (although we don’t even know if that’s true yet either), then it’s only $33k. Yes, you can certify fewer modules, but that won’t make much sense for most EMR vendors.

Yep, that’s right. $33k that an EMR vendor will have to pay for certification which will add little value to end users and decent marketing value for the EMR vendor.

Of course, this doesn’t take into account the development costs to meet the standards (which I should remind you are still not finalized). I read one EMR vendor say that to become CCHIT certified (this was back in 2006 or so) it cost in the six figure range. That’s a lot of money for what?

We know that the Drummond Group and possibly other organizations are planning to certify EHR as well. In fact, the Drummond Group just launched an EHR Certification blog. In the first comment on their blog, they got a question about how much they’re planning to charge for EHR certification.

I’m sure that these organizations will try to undercut CCHIT as far as EHR certification pricing. I’m just not sure it will be enough to make much difference. Why would they undercut them too much?

Brian at new EMR vendor Health Fusion sent me an email discussing some of the posts I’d done about CCHIT certification. In the email, he talked about how many doctors would ask him if his EMR is CCHIT certified. He then told me that his response to those doctors is that it’s not CCHIT certified, but it is is “Stimulus Ready.”

I like the concept of “stimulus ready” instead of certified. First, because I think that CCHIT offers doctors no benefit (as is well documented in my previous CCHIT posts). However, more important is to consider what I think doctors are really asking.

When a doctor asks an EMR vendor if they are CCHIT certified, what they’re really asking is one of two questions (or possibly both).
1. Can you give me some assurance that your EMR vendor has a higher implementation success rate than other EMR vendors? I’ve seen far too many of my colleagues fair or heard stories of too many EMR failures.
2. Can your EMR software get me the HITECH act stimulus money?

The problem is that right now, CCHIT can’t answer either of these questions. The first question they’re likely never going to be able to say with real authority. The second one they are likely to answer at some point, but can’t do yet.

This is why I like the idea of an EMR saying that they are “stimulus ready.” Essentially that means that the EMR vendor is planning to do whatever it takes to get their EMR software certified according to the yet to be released HHS criteria. Let’s hope David Brailer is right and access to the EMR stimulus money will end up being relatively simple.

I recently got a very short email sent to me to a press release about the first EMR to receive the full CCHIT 2011 Comprehensive Certification. I’m not sure what they wanted me to do with the release, and so I guess I’ll do what I normally do and call it the way I see it.

Does this EHR vendor consider the fact that they’re the first EHR to get the CCHIT 2011 Comprehensive Certification as a badge of wisdom that everyone will applaud? I’m guessing they’ve probably never read my past posts about CCHIT. Otherwise, I’m not sure they would have sent me that press release. However, I think it’s worth asking ourselves whether this was a smart move or a stupid one.

Certainly they’re going to get some coverage because their the first EHR certified. This blog post is proof of that. However, even in the short term will doctors care that they have the “comprehensive” CCHIT certifcation as opposed to the ARRA/HHS certification?

The doctors that I talk to aren’t asking for “comprehensive CCHIT certification.” Instead there asking one (or both) of these questions: “How do I get the EMR stimulus money?” and/or “Is yours a certified EHR?” Of course, half of the doctors out there are actually saying “EMR stimulus money? Huh?” but that’s a topic for another post. The interesting part is that in the next 6 months EHR vendors should be able to answer either of the above questions in the affirmative and never be CCHIT certified at all (see Drummond Group EHR Certification as one example).

If my above assumption is correct, then most doctors could care less about CCHIT “comprehensive” EHR certification. Then, that also means that the first EHR vendor to be fully “CCHIT Certified 2011 Ambulatory EHR” is going to look pretty silly having spent a TON of money on certification and development time to be certified. Imagine the great features that could have been developed with that money instead of being spent on a meaningless certification.

One of my favorite bloggers, Will Weider, had a nice idea with a post called “All I Want for Christmas is ARRA Answers.” I liked the idea so much that I decided to take it and post my own questions. Plus, some of his focus on hospitals which don’t interest me as much as ambulatory. So, here are the questions I’m hoping David Blumenthal and company can provide us for Christmas.

1. What’s the HHS EHR certification criteria? Will it be a complex set of criteria with little value (see CCHIT) or will it be a streamlined version that encourages EHR adoption? Especially interesting will be comparing the HHS criteria with the CCHIT preliminary ARRA certification.

2. How will HHS define “meaningful use?” Will they follow the meaningful use matrix as proposed by the HIT Policy and Standards Committees or will they take pieces here and there?

3. Regardless of what HHS defines as “meaningful use,” how does HHS plan on measuring and ensuring meaningful use of an EHR? This will be interesting to see if HHS comes out with a plan that is scalable and difficult to game. Definitely a challenging job to ensure it’s meaningfully done. (I want to see how many times I can write the word meaningful).

4. How will the various meaningful use and certification criteria apply to specialties? Will they come out with a spectrum of meaningful use guidelines for various specialties? Will they create exemptions for certain specialties? or Will they just be vague and provide no guidance for specialties, essentially leaving them with a guessing game?

5. What will be the timeline for ARRA EHR stimulus money? Will it be paid out quarterly based on the most recent quarter or past quarters. Will you have to have ongoing proof of meaningful use quarterly or annually?

6. What will be the process for recognizing new EHR certification bodies? Will they create some barriers that only allow CCHIT to certify EHR? Will other companies like the Drummond Group really join the fray?

I’m sure there are many more. What questions are you hoping to get answered for Christmas? Although, let’s be honest. I think we’re more likely to get a New Years gift of answers than we are a Christmas one.

I’ve get all sorts of interesting emails sent to me because of this site. Many people send me questions and as much as I can I try to answer them. In fact, it’s usually quite fun if I have the time. This time someone sent a couple interesting questions about the EMR stimulus money and their practice which already uses a non CCHIT EMR. I thought the 2 questions she asked might be of interest to other readers of this site and so I’ve copied the EMR stimulus questions and answer below.

Our medical practice has been using a non CCHIT EMR software prior to the stimulus plan. Can my doctors still qualify for the incentive?
Absolutely!! CCHIT certification does NOT matter anymore for EMR stimulus money. Instead what matters is that the EMR is HHS Certified (or whatever name HHS comes up with for their EHR certification criteria). There will be a number of EHR certification bodies (likely including CCHIT) that will be prepared to certify your EMR against whatever criteria is put together by HHS (although technically I think it’s CMS that does this dirty work). They have a deadline of the end of the year to put out the details of what the criteria will involve.

Also, there has been some discussion of the possibility of an EHR “site certification” Basically, even if your EMR software chooses not to become certified, you could possibly get your “site” EHR certified. It’s too early to see exactly how this part of it will play out, but it’s been proposed and I think is likely to happen.

Also, how will Medicare know whether or not a practice is using an EMR software if they are already billing electronically?
This is a good question for which we don’t know the entire answer. Hopefully when HHS releases the definition of what constitutes “meaningful use” (the other key word to get the EMR stimulus money) by the end of the year, we’ll have a better idea of how they’ll measure “meaningful use” in a clinic. My best guess is that it will include some set of reporting and possibly some demonstration of interoperability, but who knows what else they’ll come up with to measure it. Hopefully they’ll keep it as unobtrusive and meaningful as possible. However, this is government work.

Unfortunately, it’s still a bit of wait and see. The good news is that you might actually be in a better position than those that haven’t yet implemented an EMR.

Now that Mark Leavitt announced that he was leaving CCHIT, it’s going to be interesting to see who will replace him as the Chair of CCHIT. Healthcare Informatics has an interview with CCHIT search committee chair and CCHIT trustee, Frank Trembulak (Geisinger Health System EVP and COO) that’s worth reading to understand more about CCHIT plans to search for Mark’s replacement. This is going to be an interesting change to CCHIT. Or will it be a change at all?

What do you guys think, should I apply?