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?

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.

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?

Today the big news was that Mark Leavitt is leaving his role as chairman of CCHIT. Healthcare IT news reported on the announcement:

“The board accepts Mark’s decision with reluctance but appreciates his commitment to overseeing a seamless transition,” said H. Stephen Lieber, chairman of the board of trustees and president and CEO of the Healthcare Information and Management Systems Society (HIMSS).
…
Lieber said CCHIT trustee Frank Trembulak, executive vice president and chief operating officer of Geisinger Health System, will chair the search committee for Leavitt’s replacement, and that a firm has been retained to conduct the search.
…
“Having the privilege to launch and lead this volunteer-based, nonprofit organization has been one of the most rewarding and educational experiences of my life,” said Leavitt. “Now it is time for me to keep a promise I made to myself and my family when I first took on this role five years ago, knowing that I will leave it in the hands of an exceptional group of volunteers and a highly capable and knowledgeable staff.”

It seems like there’s some mixed reaction to the departure of Mark Leavitt from CCHIT. Some spelling the end of CCHIT, and others saying that it could be a good thing. I personally think that CCHIT isn’t going anywhere anytime soon. I hope they ditch their main CCHIT EHR certification path and just stick to ARRA EHR certification, but time will tell for that.

Personally I want to say that I think Mark Leavitt always came off as a very sincere guy who was trying to do good. I certainly differed with him in many areas, but I think he was just trying to do his job the best he could. I can admire that and I don’t blame him for stepping down. Things around EHR certification are going to heat up and become even more political than it’s been.

Every couple posts I have to write about CCHIT or EHR certification. It’s one of my favorite topics to write about, and I believe it’s one of my readers favorite topics as well (at least that’s what traffic tells me).

Today I want to take a look at what I believe is a new addition to the CCHIT 2011 EHR Certification. At least I hadn’t heard of it before. This is what CCHIT is calling Reference Site Verfications. From what I can gather they’re basically planning to verify that there are 2 live sites that have been using the certified EHR for at least 45 calendar days. For those new EMR, they can be certified with what CCHIT is calling “Pre-Market” status, but the EMR vendor must have 2 approved sites within 1 year of when they were initially certified. I also like that CCHIT is requiring that the 2 approved sites have no financial relationships with the EMR vendor. However, I’m not sure how they’re going to know if this is the case or not.

The questions I have is how they’re going to know and test that the 2 reference sites are using the EMR. According to CCHIT guidelines these EMR sites must be actively using key Meaningful Use components:
Ambulatory: ePrescribing, Drug decision support, Electronic receipt of labs, Problem list, Quality reporting
Inpatient: CPOE for medications, Drug decision support, Electronic receipt of labs, Problem list, Quality reporting

I admit that I love the concept of verifying that the software’s actually being used as it should be being used. My challenge is I haven’t figured out how CCHIT can do this effectively across so many different systems and locations. I know Sue from CCHIT has read some of my previous posts, so hopefully she can respond in the comments and give us more details.

CCHIT has also planned an annual monitoring of the certified EHR systems. Basically a look at one of the previous reference sites and a new site.

I find this reference site plan by CCHIT to be very interesting. I like that they’re trying to find places that actually use the EMR and they use the full set of features of the EMR as well. However, I’m not sure how well they’ll be able to measure this effectively and even if they could I wonder if 2 locations is enough to provide a valuable measure.

Of course, I should also clarify that this is just for the CCHIT 2011 certification and not the certification that CCHIT will be doing for those interested in the ARRA EMR stimulus money. At least that’s my understanding.

I’ve been sitting on this post for a while. I figured it was finally time that we talked an interesting development in the CCHIT EHR certification: EMR usability testing. They first presented some of the details of this testing during the CCHIT training meeting. However, they also partnered with User Centric to formulate their EHR user testing and EMR and HIPAA has had a nice connection with User Centric for a few months now.

First the good. I’m glad that CCHIT is venturing into the realm of EHR usability testing. I’ve often talked about CCHIT Certification being rather useless since just because a piece of software does a certain function doesn’t mean that it does it well or that the EMR is usable. In fact, some of the most “feature rich” EMR software is completely unusable by the majority of people. Kind of reminds me of the days of terminals. If you knew the key strokes, it was incredibly efficient. However, learning the keystrokes was so much harder than a nice graphical interface which could do the same things. Not a perfect comparison, but interesting to consider.

So, the biggest problem with CCHIT measuring an EMR’s usability is that the EMR usability rating does NOT affect the certification outcome. Also, it appears that it will be up to the EMR vendor whether they want this result published or not. I wonder if we’ll get to a place where a few EMR vendors show their usability rating and others don’t. Those that don’t we’ll have to assume scored poorly? We’ll see how all that plays out.

I admit I haven’t looked over the entire EMR usability rating process. So, I can’t say if the process is complete or effective in and of itself. Although, I do have some confidence in User Centric as a company even if they’re trying to bite off the very difficult task of measuring EMR usability.

It does look like they’ll give the EMR software a usability rating that is not just a pass fail score. A rating is a much better thing when we’re talking about a somewhat abstract concept of software usability.

I’m also concerned about the quality of the jurors that they’ll use to try and measure usability. I’m sure they’re great people with great intentions. Honestly, that’s one of the most redeeming qualities of CCHIT. They have a large base of volunteers that are very well meaning. However, I’m not sure how much confidence I have in their ability to rate a software’s usability. For that matter, I’m not sure how well I’d be able to do it and I think I’m pretty familiar with the subject.

In a related issue, when you look at the way their putting together the score, it seems pretty complicated at first look. Like I said, I don’t know the details of the methodology. However, that’s kind of the point. Even if CCHIT does post an EMR vendor’s usability score, will the listening public (Translation: doctors) be able to quickly and easily understand what that score means? Maybe it’s a simple thing to figure out. We’ll see, but the devils always in the details and if I’m selecting an EMR I want it to be usable. So, I’ll be very interested in an EMR’s usability score.

Those are just a few things I noticed with the new CCHIT EHR Usability additions. Is there some other parts of it I missed? Anything else we should know about it? Will this be a valuable addition to the CCHIT Certification? Will EMR vendors revolt against it?

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.