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?

After my last post, a meaningful use checklist, I couldn’t help but start thinking about how many people are going to soon be looking for a meaningful use checklist.

Certainly many practices are going to be interested in finding a meaningful use expert to help make sure that they get the EMR stimulus money. I’m guessing many EMR vendors are going to want to find a meaningful use expert that will help them navigate the hundreds of pages of regulations and wave of other meaningful use information which isn’t in the regulation cause let’s be honest. Despite a HUGE regulation, there are a still a ton of practical meaningful use details that you’re going to need to know to appropriately navigate the meaningful use world. The government doesn’t just hand out money (usually). You have to play the game.

The challenge is that who is a meaningful use expert. Just over a year ago, no one even used the term meaningful use. Over the past year we’ve learned a lot about meaningful use and each day we learn more, but it’s all one huge learning process for everyone.

Plus, it’s not like there’s some meaningful use expert certification. ONC and CMS have done some meaningful use conference calls and other training. I expect they’ll do more and more of these. Will those and other resources on the various HHS websites get us to the point that someone can say they’re a meaningful use expert? It seems like they’re going to have to do it, no?

Of course, we have the RECs also. No doubt, they should have the information you need to show meaningful use. Their meaningful use experts are free too. Not too bad. Are RECs getting extra meaningful use training that really will make them experts on meaningful use?

I’m interested to know how practices are planning to approach meaningful use. Will they be finding meaningful use consultants? Will they be using the RECs? Will they be navigating the meaningful use waters alone and build the expertise in house? Will they be relying on their EMR vendor to provide them the meaningful use expertise?

I guess it’s just hard for me to call anyone an “expert” on meaningful use. I think I’m pretty knowledgeable on meaningful use, but I’d definitely shy away from using that “E” word. Maybe other people see it differently than I do.

A recent comment from Jim Hook from The Fox Group had a nice checklist of items that doctors and practice managers could start doing to make sure that their EMR implementation is ready to meet the meaningful use standards. This isn’t an exhaustive list, but I thought was a good list for those providers wanting to being their preparation for showing meaningful use and obtaining the EMR stimulus money.

Everyone should keep in mind that there are no systems “Certified” at this point.

Here are some things to check as you get ready to claim your incentives for EHR Meaningful Use under the HITECH Act. This information is based on (EPs) qualifying for the Medicare incentives.

1) Start talking to your vendor about their plans to submit their EHR software for certification as “Certified EHR Technology”. The system does not have to be certified as of January 1, but it does need to be certified by the end of the 90-day period you are using to attest to your EHR Meaningful Use.

2) Keep in mind that if you are using a stand-alone EMR product with an existing legacy practice management (PM) system, the system needs to be Certified EHR Technology also. This is because some of the functions of a certified system, such as recording patient demographics electronically, are most likely functions of your PM system, not the EMR product. So talk to that vendor, too.

3) Verify that any eligible provider attesting to meeting EHR Meaningful Use objectives provides 10% or more of his/her Medicare services in an outpatient setting (not inpatient or in a hospital ED). CMS will look at the percent of services rendered in an outpatient setting for the fiscal year ending 09/30/2010 to determine the IP/OP percentages. Your EHR healthcare consultant must be qualified to do the analytical and reporting work in preparing the self-attestation report, based on the current fiscal year and the individual EHR Meaningful Use objectives in place, starting January 2011.

4) Make sure all eligible providers you are planning to certify for EHR Meaningful Use have an NPI number and are enrolled in PECOS.

5) For EPs in group practices, confirm the tax Id number – group or personal – of each provider for payment of the incentive amount. Payments can be made to either number.

6) CMS will be establishing an Internet-based enrollment process for EPs planning to apply for incentive payments. Keep checking this site for the Registration process, and enroll when it is available.

7) As soon as you start the clock on your 90-day period, make sure you are meeting all the EHR Meaningful Use objectives applicable to your practice, and, for objectives with numerical thresholds, that you are attaining the levels specified. If your EHR system is Certified EHR Technology, it should be capable of supporting all Stage 1 Meaningful Use objectives.

8) Monitor the CMS website on EHR Incentive Programs to determine the format of the attestation for 2011. And keep in mind that accuracy is paramount; attesting to EHR Meaningful Use is making a claim to a Federal program. And the penalties for false claims are significant!

Attestations can be completed as early as April, 2011, and CMS has stated payments will be made in May. For EPs seeking incentive payments under the Medicaid / Medical program, visit the CMS website for further information.

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.

Question: My EMR claims to have all of the capabilities they will need to demonstrate meaningful use and qualify for ARRA incentives. Does that mean I will get the EMR stimulus money?

First of all, you might want to consider another EMR vendor. If they are saying this, then they are trying to mislead you and make more sales. No EMR vendor can claim that they have “all of the capabilities” for you to show meaningful use and qualify for the EMR stimulus money.

Why can I say this? Because the details for Meaningful Use are still not final. We don’t know what you’re going to have to do to show meaningful use and so how can an EMR vendor claim to have all of the capabilities? Short answer is that they can’t. So, go and read their press release again and see if they’re just telling lies or if there was a disclaimer of some sort (ie. according to the interim final rule).

On to the other point of you getting EMR stimulus money. Certainly your EMR will have to be a certified EHR (that’s still not defined either). Your EMR will also have to have the capabilities to show meaningful use. However, at the end of the day, YOU’re the one that’s going to have to see patients and Use the EMR in a way that all of the meaningful use criteria are met. If you do this to the satisfaction of CMS, then you’ll get the stimulus money.

Certainly you can’t meet meaningful use without the EMR vendor. However, the EMR vendor alone can’t qualify you for meaningful use either. It takes 2 to tango. Just remember that it’s much easier to tango when you have a great partner. A lousy partner makes it no fun for anyone.

Check out previous EMR stimulus Questions and Answers.

One of the challenges of this blog is writing content that will be interesting and useful to a wide variety of readers. At times I think I assume that those visiting EMR and HIPAA have read my 770 previous posts and should have a good understanding about the EMR world.

Of course, the reality is that many of the people visiting this site might only read a couple different posts. Even more significant is that they might only have a remedial understanding of EMR and in particular the EMR stimulus money. This leaves me with the challenge of keeping the long time readers interested and benefiting from the content I create while still helping the EMR newbies understand what they need to know.

In that vein, here’s some questions that I got in an email about meaningful use and the EMR stimulus. Those of you well versed in the EMR stimulus can go and enjoy EMR and EHR or add some content to the EMR wiki while I do what I can to answer.

Are there governing bodies that have been set up to “certify” EMR/EHR software vendors?
Not yet. The government hasn’t recognized any bodies that will certify EMR/EHR per the ARRA requirements. They’ve published some guidelines and rules for those bodies, but HHS has yet to recognize any of them as official ARRA EMR Stimulus certifying bodies. I expect by end of summer we’ll have a couple to choose from. The Drummond Group and CCHIT are both planning to be EHR certifying bodies, but neither has been officially recognized yet.

Do EMR/EHR software vendors have to be “certified”? If they are not “certified”, does this prevent their customers from receiving federal money?
In most cases the EMR/EHR software vendor is the one that will be certified. There has been some provisions and discussions about allowing for 2 other EHR certification options beyond just using a “fully certified EHR” software.

The first is that you could use a combination of certified software vendors. For example, you might use one certified EMR vendor for everything but ePrescribing and then you’ll choose another software vendor who is only certified for the ePrescribing portion. It seems that this type of combo certification will be allowed.

The second is what’s been called a site certification. This would essentially be where a specific site (or location) would be certified against the EHR certification criteria. This is best illustrated by a hospital or clinic which has their own home grown EMR software. This EHR site certification would allow them to certify their site and give them access to the EMR stimulus money. It’s possible that an option like this won’t be available, but from what I can tell it’s looking like it will happen.

Do you think that it is possible to satisfy the Stage 1 objectives?
This is a loaded question. The short answer is that everything is possible. Whether it’s possible or not is not as important as whether doctors will do it or not. This question is hard to answer right now. Mostly because we’re missing a lot of the practical meaningful use details which doctors need to know in order to make a decision.

My gut feeling tells me that it will go about like PQRI stimulus money. Some will get the EMR stimulus and be happy. The same number will try for it and be really disappointed by the whole process. More will say it’s just not worth my time right now. That’s not to say that many of these doctors won’t (or shouldn’t) implement an EMR. I think many of them will, but they’ll do it for the inherent benefits of EMR software and not for the EMR stimulus money.