We finally now have the first ONC approved EHR certification bodies (Officially ONC-ATCB or ATCB or ONC Authorized Testing and Certification Body). The first 2 ONC-ATCB are very familiar names that we’ve been talking about on EMR and HIPAA for a long time: Drummond Group and CCHIT.

In an HHS and ONC press release they also noted that “Applications for additional ONC-ATCBs are also under review.”

Drummond Group has already posted information on their website about their EHR certification and testing plans. The most useful item is this 10 page EHR Testing, Pricing and Certification guide (PDF).

Lots of interesting information in the PDF which I’ll likely talk about later. The pricing however is worth noting now. It’s on page 8 of the PDF document and has certification set at $19,500 for the Complete Remote EHR certification and $23,500 plus travel for the Onsite EHR certification tests. There’s also pricing for the modular certification.

I haven’t found any published prices on CCHIT certification, but in the past the CCHIT EHR certification costs were $37,000 for the complete CCHIT certification and $33,000 for the Preliminary ARRA certified EHR.

Looks like we might have a bit of an EHR certification price way on our hands. $20k is still a lot of money for EHR certification, but $10-15k difference is quite a bit of money.

Here’s a short quote from the CCHIT press release about their time frame for accepting EHR certification applications and when we might see the first certified EHR.

CCHIT plans to launch its authorized HHS certification program on September 20 at 1:00 PM Eastern time with a Town Call Web-cast describing its application and testing process. CCHIT will take new health IT developer applications immediately after at http://cchit.org and the first group of HHS certified complete EHRs and EHR modules will be announced within weeks of that launch. More information about the Town Call will be available at http://www.cchit.org/towncalls. The call will be recorded for later viewing.

It will be interesting to see if Drummond Group of CCHIT can produce the first officially certified EHR vendor and which vendor will hold that distinction.

UPDATE: Weno Healthcare looks to be another potential ONC-ATCB (if they get approved) and their EHR certification pricing looks to be in the $14k-$18k range.

Alfred from Infomd.net recently made the following comment:
If the product you use is CCHIT certified, it is a pretty safe bet to say that they will be certified under the Meaningful Use rule. Meaningful Use is but a subset of what it takes to become CCHIT certified

Here’s my response to Alfred:
Alfred,
I don’t think that the new certified EHR is a subset of CCHIT. There are some similarities and concepts, but it’s not a subset.

However, I think you’re right that many CCHIT certified vendors will become ARRA certified. Mostly because the EHR vendor that has the CCHIT certification has chosen to make EHR certification a priority for their company. So, they’ll likely make the ARRA certification a priority as well.

It is worth asking if you want to be tied to an EHR company that focuses so much on certification. One could make the argument that an EHR vendor that focuses so much on EHR certification might not be focusing enough on the customer’s needs. These 2 focuses will obviously create very different EHR products.

See Also this post: EMR Stimulus Q&A: Do You Have to Use a CCHIT Certified EHR Vendor?

Long time readers will know that I’m not a fan of EMR certification. It seems quite pointless since it provides no assurance to the doctor of anything of value. EMR Certification doesn’t ensure a higher implementation success rate. EMR Certification doesn’t improve patient care. EMR Certification doesn’t improve doctor’s bottom line.

With that said, we’re still stuck with the term “certified EHR” in the HITECH Act EMR stimulus money legislation. So, EMR certification is going to be around for the foreseeable future.

CEO Mike from Medscribbler EMR posted an interesting look at the cost of CCHIT EMR Certification and the impact that it could have on EMR vendor selection and long term viability of EMR vendors. I’ve included his comments below:

Note: See my post about whether you have to use a CCHIT Certified EMR vendor before reading Mike’s comments.

Using the CMS’s own data and report a CCHIT EMR will spend between $125,000 to $350,000 in programming costs to be certified (add at least $20,000 for actual certification) An existing EMR not CCHIT certified they predict will spend $175,000 to $700,000 to meet the standards (plus the $20,000.)

Certification has to be done for each year, for three, so a 2011 certification does not guarantee MU certification for 2012.

Self certifying for Open Source are not exempt from requirements so it stands to reason they will have the same expense.

What does this mean:

1. Forget collecting MU with Open Source software.

2. If you are using no CCHIT software it is unlikely the software will be qualified by the vendor.

3. Even fewer EMR vendors will certify than those that did so for CCHIT.

4. Innovation is dead if MU certification becomes generally why an EMR is purchased as this will also set the preception of useability. Vendor design resourcess will go to MU not useability.

5. If MU EMRs fail to get widespread purchase, those EMRs who certify are dead (including some current larger market share ones, as they will undoubtably spend a ton on marketing to maintain their share.) The MU EMRs will also then presummably be left behind by the innovators for useability.

6. Certifying bodies, especially CCHIT may be in trouble because there will be fewer takers, or they will charge a lot more pushing EMR prices up.

7. Regardless everyone is going to pay a lot more for an EMR making the MU payment mote.

Medscribbler could be certified, we are still evaluating this, because there are a lot of CCHIT EMRs now dead in the water – certification is no guarantee of success – we believe useability is – and how do we balance useablity which will guarantee success with certification which may or may not?

AK sent me the following EHR Certification question:

Is it necessary to get CCHIT certified vendor just because you want to qualify for incentives or regardless you MUST go for a certified solution?

Because I make the case that one should go with the one that provides the most amount of value.

You only need to use a certified EHR (doesn’t have to be CCHIT certified either, but HHS Certified) if you want to get the EMR stimulus money. The only caveat is that if you don’t show “meaningful use” of a “certified EHR,” then in a few years there are 1-5% Medicare penalties for not using one and showing meaningful use. However, many people strongly believe that those penalties will actually never be implemented. Of course, that part is just conjecture and may or may not happen.

So, there’s nothing forcing physicians to use a certified EMR solution. More and more people are doing as you describe, ” go with the one that provides the most amount of value.” They make the valid argument that if you get $44k in EMR stimulus money and lose $50k in productivity then you would have been better to go with an EMR that can’t get you stimulus money, but still maintains or even improves your productivity (among other EMR benefits).

At one of my EMR stimulus speaking engagements, a physician came up to me after the presentation and asked, “If I don’t accept Medicare or Medicaid, then do I care about meaningful use or certified EHR?” The easy answer was, nope. He can just decide on the right EMR without having to worry about government requirements.

Some have suggested that insurance companies might impose the certified EMR or meaningful use requirements, but I personally think that’s pretty unlikely.

I found this interesting tidbit in the final rule for the EHR Temporary Certification Plan:

“In the Proposed Rule, we stated that we anticipated that there would be no more than 3 applicants for ONC-ATCB status. Based on the comments received, we now believe that there may be up to 5 applicants for ONC-ATCB status. In addition, we believe that up to 2 of these applicants will not have the level of preparedness that we originally estimated for all potential applicants for ONC-ATCB status.”

Interesting to hear that there are likely to be 5 applicants to certify EHR software. Of course, we know that 2 of those bodies are CCHIT and Drummond Group. I also know of one other, but I’m traveling and so I can’t look up the name. Although, I only know this other one based on a conversation. I’ve never seen anything in print.

That leaves a couple other possible EHR certifying organizations. Does anyone know who else is interested?

Well, it always seems to happen when I go out of town on vacation that HHS finally decides to go to work and make some announcements. The final rule for the Temporary EHR certification rule is out and will be published to the Federal Register on June 24th. It’s non-final format is available at the Federal Register’s Public Inspection Desk. Does anyone else kind of squirm when they read about this final rule for a temporary EHR certification. Final and temporary just don’t sound right together, but that’s what we have.

The Healthcare IT Guy attended an HHS ONC press conference and added a nice little summary of what was said:

*As of today if you’re interested in being a certification body you must request the HHS Certifying Body application in writing
*On July 1 ONC will start accepting applications
*By the “end of the summer” (HHS’s words) there will be one or more certifying bodies open for business (accepting products)
*By “this fall” (again, their words) there will be fully HHS certified products available

One important clarification was made by ONC — there is no grandfathering in CCHIT or previously certified products. Everybody is going to be re certified using the new NIST rules. This means that if you have even 2011 CCHIT certification now it won’t mean anything, you have to go through the process again. CCHIT is offering their “ARRA Interim Certification” but beware — the rules say that you have to follow the NIST plans, not what CCHIT developed. So, if you have the ARRA Interim Certification you may not have pay again but you still will be required to change your software to meet the HHS/NIST test plans and requirements.

Nothing that’s all that newsworthy, except it’s nice to finally have a little bit more solid timeline for when there will be some ARRA EHR certification bodies.

I think that Shahid’s analysis of the now meaningless 2011 CCHIT certification is spot on as well. Although, I’m sure we’ll still see quite a few EMR vendors using the marketing power of the CCHIT certification on unsuspecting clinics who don’t know the difference.

Yes, it does also mean that clinics will have to wait until Fall of 2010 (or later) before they’ll really know if an EHR will be a certified EHR or not. Of course, I’ll be very surprised if less than 98% of EMR vendors don’t become ARRA certified.

EMR and HIPAA Answer to EMR Stimulus Questions
Today’s question comes from an EMR and HIPAA reader:
If I may back up, I am not having much luck in finding how we, as a clinic, get ’signed up’ if you will for this program. We already have EHR implemented. We are a rural health clinic that accepts Medicare and caid. We have been told by our EHR provider that they are CCHIT Certified. From what I have read, we are likely eligible however not sure how to get started. Could someone please advise. Thank you

Unfortunately, the answer to this question is that we still don’t know how Eligible Professionals (EP) or Eligible Hospital(EH) are going to be able to “apply” or “sign up” for the EMR stimulus money. I expect we won’t know all the details to actually applying for the EMR stimulus until the end of this year or early next year.

Remember that starting in 2011, you’ll need to show 3 months of “meaningful use” of a “certified EHR” in order to get the stimulus money. That means that CMS has some time before they really have to publish the methods you’ll use to apply for the bonus money. Of course, we all hope it’s published sooner instead of later and ideally before the end of the year so that doctors can plan appropriately for the start of 2011.

Also, to clear up one misunderstanding from the question. CCHIT Certified is NOT the criteria that CMS/HHS will be using to know if you’re using a “certified EHR.” HHS/CMS/ONC have yet to release the final rule for EHR certification bodies and the final criteria that certified EHR software will have to meet to become “ARRA-Certified” or “HHS Certified” (or whatever they end up calling it). We aren’t likely to get all the details on the recognized certification and bodies until at least June and possibly the end of summer.

Justin Barnes, did give some good advice when he said that you should be ‘speaking with your EHR provider to understand how they are going to support you in achieving meaningful use using their “ARRA-certified” EHR.’ Although, I’m a little leery of an EHR company that told you that they are CCHIT Certified and left it at that. It makes me wonder how much they really know about the EMR stimulus money requirements since CCHIT certification doesn’t really matter.

While you wait for more details on the real EHR certifications to happen and for the application process to unfold, you might browse through the meaningful use matrix and other meaningful use details. This is the list of ways that you’re going to have to use your EHR in order to qualify for the money. Certainly would be worth reviewing to see what other EHR features you should be using if you want the EMR stimulus.

Check out the previous EMR and HIPAA EHR Stimulus Question and Answers and please send us other questions you might have in the comments.

I previously posted about the new head of CCHIT, Karen Bell. Most of you probably know that I’m not a huge fan of CCHIT, but I’ve decided that I’d like to give Dr. Bell some advice for CCHIT. Free consulting. How cool is that? Here we go…

If Dr. Bell really wants to solidify CCHIT’s position in the EHR world she’ll find a way to show that the CCHIT EHR certification improves usability, EMR implementation success, reimbursement, etc. CCHIT has some vague terminology about the “assurances” that CCHIT certification provide. Unfortunately, they end up being empty assurances about things that doctors don’t really value.

I’d be really impressed to see an independent study done on the EMR implementation success of CCHIT certified EHR versus non-certified EHR. Or how about a study comparing the usability of CCHIT certified EHR versus non-certified EHR. Let’s see some real data on assurances that doctors actually care about. Do that and everyone will want a CCHIT certified EHR.

Unfortunately, if you do go this route, you need to be open to the possibility that an independent study would find that CCHIT certified EHR have a higher EMR implementation failure rate or that CCHIT certified EHR are less usable. What would CCHIT do then (besides try to manipulate the study to look the way they want)?

What’s more unfortunate, is that studies like this should have been performed before Congress decided to just include the term “certified EHR” without actually knowing what consequence (good or bad) that term might have on the EHR industry.

As always, Chilmark Research has a nice post up talking about the new head of CCHIT, Karen Bell. You can see the official CCHIT announcement here.

Chilmark brings up two interesting points about what he thinks we can expect from Karen Bell as head of CCHIT.

Dr. Bell knows Washington DC and HHS quite well from her many years there. She is effective in a highly politicized environment and will be able to effectively lead CCHIT through that political minefield.
…
Dr. Bell will put up a Chinese Wall between CCHIT and the HIT vendor organization, HIMSS. She is fully aware of the perceived conflicts of interest between CCHIT and HIMSS and will seek to create some distance between these two organizations.

I first must say that the first part is a really smart move by CCHIT. I’d always wondered why CCHIT didn’t have more influence and connection in Washington. That seems like a core competency that they’d want to have to survive. They should have had all the information from HHS before anyone else and they didn’t. I wonder if Dr. Bell will be able to do that for them now.

The second part seems a bit like Chilmark dreaming and hoping. I have a strong feeling that Dr. Bell does indeed realize the conflict and would desire to create that separation. However, I have serious doubts that she will change much of the structure even if she could (which I think might not be possible).

I say this first because Dr. Bell was a representative on CCHIT’s board of commissioners from 2006-2008. Why didn’t she effect this separation back then? Seems like the board of commissioners would have some reasonable control over this.

The answer might lie in the inability to make such a change. Notice I didn’t say her inability. I said the inability. It’s quite possible that there are just too many external pressures for her to break CCHIT’s strong ties with EMR vendors. Of course, nothing would make me happier than for Dr. Bell to prove me wrong. No doubt that would be a most impressive accomplishment.

With all of this said, the real question is, “Does anyone care?” As Chilmark aptly points out, “have yet to see any demonstrable proof that CCHIT certification has moved the EHR/EMR adoption needle in any statistically meaningful way” Beyond that, if ONC does there job, doctors will finally get the information that it’s ARRA EHR Certification that matters and not CCHIT certification. That will take some time to change, but it’s starting to happen. If (and when?) it happens, will anyone care much about CCHIT anymore?

Time for a break from the regularly scheduled HIMSS programming (sorry there’s just a lot of HIMSS content to still be published) for some thoughts and comments on the EHR Certification Interim Final rule. What can I say? I was inspired by CCHIT’s comments on the EHR Certification criteria.

First, since I mentioned CCHIT’s comments, I have to admit that I think that CCHIT made some very reasonable comments. I’m not sure I really disagree with any of the detailed points that they offer in their comments. What’s probably most interesting in CCHIT’s comments is the last two sections where they talk about the adverse impacts that this rule is likely to have on small EMR vendors and more importantly, small healthcare facilities. I’m not sure I agree completely with their analysis, but it was nice to see CCHIT backing the small businesses.

Now, just a few comments of my own about the major problems with the Interim Final Rule. I’m not going to go through the finer points. Just some major thoughts about what ONC better avoid as they adjust the criteria.

The first challenge that I think they face is the times that they apply certain criteria to hospitals and ambulatory the same way. They’ve actually made a good effort to separate the two entities, but they need to do more since a hospital EMR is VERY different than an ambulatory EMR. In fact, CCHIT even points this out a number of times in their comments as well.

Probably the largest problem I see with this criteria is their inability to take into account the various specialty needs when it comes to an EHR. The criteria basically treats all doctors offices the same. This is a problem that is going to have a widespread effect and is likely to really hinder EHR adoption.

ONC really needs to take a hard look at the criteria and think through how that criteria is going to affect the various specialties and specialty EMR software out there. One concept they should consider is that maybe they aren’t trying to define a certification criteria for an “EHR software” for one market (healthcare), but instead are trying to define a certification criteria that will work for “EHR software” across 100 markets (each of the specialties).

Certainly, we’re going to see a lot of consolidation happening in the EMR industry. However, the more I think about it, the more I think that there’s not just one EMR industry, but that there’s a whole collection of industries out there. Every time an EMR software is installed in a new specialty, it’s like they’re trying to enter a new industry. Now, just imagine trying to create a criteria for software that applies across all these industries. No wonder it’s a major challenge.

Next up, ONS should place much less emphasis on the certification criteria and let many of those criteria be shown in the meaningful use guidelines. Let EHR vendors innovate in how they are to accomplish the meaningful use criteria. It’s simple for an EHR vendor to create new features. That’s just a matter of time and cost. However, it’s much different for an EHR vendor to focus its energy on creating a usable system.

If the “certified EHR” component of the stimulus requires EHR vendors to build too many features, then we’re going to end up with a number of poorly designed and unusable EHR systems in clinical practices. Implementing these unusable EHR systems will do nothing but hinder the adoption of EHR systems.

Not to mention, if the EHR vendor shoddily implements a feature to become a “certified EHR” and then the feature is too cumbersome to actually be used, the doctor will be the one left holding the cost of the EHR with no access to the stimulus money. This will also help to hinder EHR adoption.

ONC should focus less on features (EHR Certification) and more on results (meaningful use) and allow the various EHR vendors to innovate on how they will provide the results.

Finally, ONC should focus the certification efforts around establishing standards where EMR vendors are unwilling to standardize. This type of focus will provide a real an actual benefit to doctors who can benefit from this sort of interoperability. Stop focusing on features and functions that will provide little value to doctors.

At the end of the day, the criteria need to be simplified to apply more broadly and to not stifle innovative EMR software companies. Too strict criteria will hinder EHR innovation and more importantly, long term adoption of EHR software.