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.

I can’t remember when or where I saw it, but at some point I saw someone reference Jim Tate from EMR Advocate as the expert on EHR certification. I’d known Jim electronically for quite a while having followed his writings online and on Twitter. I even haphazardly bumped into Jim where we both looked at it each other and recognized our pictures from Twitter.

After Jim stopped by to comment on my previous EHR certification post, I emailed Jim to ask him if he wanted to do a guest blog post for EMR and HIPAA. He is busy with 3 stage 1 EHR certifications this week, but did send the following info which I found interesting and useful. I’m also looking forward to taking a look at his manual on meaningful use. I hear it’s highly targeted at doctors and clinical practices which fits in line with my style too.

The HHS/ONC Authorized Certification Program has really broken loose. We were in the eye of the storm, but the eye has passed and the windows are being blown out. Vendors are desperately trying to get a testing date in October and not Novemenber or later. The ability to get Stage 1 Certified and listed on the ONC website is now a giant business issue. A two month’s delay in being able to market and sell certified technology is a handicap. We will see the effect that decisions made over the past year by vendors will play out in the market. Those that applied for the CCHIT Preliminary IFR Stage 1 test are sitting pretty as their can choose test dates based on their application date. Those vendors that elected to wait may pay a price in delayed certifications. Of coursethere are presently 2 organizations authorized to test and certify and I expect maybe 2 more in coming weeks. That may help the crunch. The Drummond Group is charging $23,500 for all Stage 1 testing for EPs and has begun accepting applications for testing. Information about their program is available at: http://www.drummondgroup.com/pdfs/EHR_Testing_and_Certification_Guide_Rev_A.pdf (PDF). A number of my vendor clients have applied and have been given test dates in mid to late November. CCHIT will hold a Town Call next Monday at 1 PM ET: http://www.cchit.org/about/towncalls/CCHIT-Town-Call-Authorized-HHS-certification-program. The fees for their Stage 1 testing will be announced at that time and applications will begin to be accepted that date. Vendors who had already applied for CCHIT’s Preliminary Stage 1 Testing will begin testing against the CMS Final Rule next week. By the end of this month we will Certified Technology listed on the ONC website.

Due to the complexities of the CMS EHR Incentive Program for EPs I have written a manual, The Incentive Roadmap, to help guide medical practices through the process. It is being updated continually to reflect the changes in the incentive program. It is being sold at HITECHAnswers.

As I mentioned in my previous post about the race to be the first EHR certified (and the first ATCB to certify an EHR), there’s a lot more going on in the battle amongst the EHR certifying bodies.

The first interesting detail surrounds the previous CCHIT certified EHR vendors. This turns out to be a really great move by CCHIT. A quick look at CCHIT’s website has 49 EHR products (or modules of products) that have been certified for either the CCHIT 2011 certification or for the Preliminary ARRA certification. That’s 49 pieces of EMR software (a few less since some are different versions of the same product) have paid $22k+ in order to be certified by CCHIT.

I’ve talked to one of these EHR vendors and they said that CCHIT did a call with all current vendors and said that they will be honoring their previous commitment to provide the real ARRA certification at no additional cost to these providers. This turns out to be really smart if it means that many of the big EHR players like GE, Elipsys/Allscripts, NextGen, Epic, Athena, Pulse, Cerner, etc all decide to continue forward with CCHIT.

Many would ask why they would pay another $20k to someone like Drummond Group if they could get the EHR certification for free from CCHIT. Turns out their is a possibility if CCHIT isn’t able to deliver their certification in a timely manner and Drummond Group is able to do it much quicker.

Remember the list above are HUGE EHR vendors where $20k is basically a drop in the bucket. It’s kind of scary to consider that, but that’s the reality for most of the EHR vendors. Sure, it’s not what they’d like to spend if they don’t have to, but when did large corporations start worrying about wasteful spending? Ok, that might be a slight exaggeration, but you get the point.

The good thing for Drummond Group is that there are still 300+ EMR vendors that will need to be certified. In fact, many of the non CCHIT certified EHR companies are likely moving to Drummond Group for EHR certification since CCHIT is giving priority to their existing EHR vendors.

Yes, that’s right. Over the next month and half CCHIT will spend all its time doing a bunch of free EHR certifications while Drummond Group will be making just under $20k for each EHR certification that they do.

One final thought about the fun that is EHR certification. When I recently talked to an EHR vendor that is CCHIT certified and will likely be getting their now free EHR certification, I found it really interesting to learn who from their company was on the CCHIT call. In this case, the EHR vendor’s VP of Marketing was on the call with CCHIT.

Of course, this begs the question why the VP of Marketing would be on a call about EHR certification standards and compliance. Shouldn’t the clinical director be the one that wants to be on that call? I think it sends a compelling message that I’ve been preaching on EMR and HIPAA for a long time. EHR certification is not a benefit to the doctor. EHR certification is not a benefit to the patient. EHR certification is a means for EHR vendors to market their EHR software.

I have a lot more to say about EHR certification and the battle we’re about to see between Drummond Group and CCHIT for EMR vendors, but I’m about to leave for an interesting conference on meaningful use, EMR and HIE. Although, I did want to just start the conversation on becoming a certified EHR.

It seems like the battle is just beginning to try and secure EHR vendors under a certain certification. One of the competitive differences right now is about speed. Which EHR certification body will be the first to certify an EHR under the ARRA guidelines. It will be a big PR move for the first EHR vendor and should benefit Drummond Group or CCHIT to be first.

From the dates that I’ve heard, Drummond Group seems like they’ll be accepting applications for certification first (near the end of this month). CCHIT will be doing it at the beginning of October. It will be interesting to see how quickly Drummond Group will be able to turn around the EHR certification results.

Plus, one other wrinkle in this area is that CCHIT is giving priority to the EHR vendors that are already CCHIT Certified or Preliminary ARRA certified. This means the other 250+ EHR vendors are being treated as second class citizens. You can guess where that larger part of the EHR market is going for their certification: Drummond Group.

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?