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?
Considering all the possible approaches the HIT Policy Committee could have taken to Meaningful Use, the path they have taken is rather narrow. The criteria extend with each review cycle the thoroughness and depth with which data driving medical disease management are acquired. A prudent vendor would look at this as a clear indication of capabilities application architectures will have to deliver and a convergence in content among products. A vendor will want to show that it is ready to deliver Meaningful Use through the entire suite of stimulus reviews. This is a well defined business challenge.
John:
I whole heartedly agree with you. WebDMEMR’s development schedule has been on par with the Meaningful Use Matrix Tagged for CCHIT Reference. This document lays out a generalized view of the functionality necessary to conform with meaningful use, not CCHIT. I actually took a look at the Preliminary ARRA criteria, can believe that there are some criteria that only apply to client-server EMRs? With no option for web based applications? These test scripts are geared towards client – server based technologies, I found that many of the criterion did not make sense for a web based EMR. For example, I noticed one requirement states that the technology must use Kerberos. This is technology is only primarily available and necessary for client – server based EMRs. Representing a web based company, how are we supposed test ourselves if the test scripts are based on the wrong technology? CCHIT’s answer was: the federal governement imposed that criteria.. we have no say in that.. I highly doubt the federal government would restrict all other emr technologies.. CCHIT is incompenent, and are playing on the EMR communities fears. I definitely will not buy into it.
Lourdes,
Interesting point that I’d never heard made before. Do you mind if I post your example for others to comment on? The kerberos thing is sad since it is such a client server thing. You’d think they would have taken that into account.
John,
Sure be my guest
[…] However, one problem I’d never heard of was something that Lourdes from WebDMEMR said in a comment on my post about EHR certification recommendations: WebDMEMR’s development schedule has been on par with the Meaningful Use Matrix Tagged for CCHIT […]
I agree with you and that is what MD-2 is being developed based on. We are taking what we think (and our Physician consultants/users) would be of value from the certification and adding to our development efforts. Then once the government criteria comes out/finalizes we will be close to getting the certification done, since most of it would have already been done. Great article!