The Drummond Group has just officially announced on their blog their intent to apply for and test EHR software to provide an alternative EHR certification to CCHIT. Here’s a few portions of their announcement:

After a thorough review of the recent NPRM along with months of consideration, DGI is excited to announce that we will be applying to be an ONC-ATCB this year.

As mentioned before, receiving the HHS requirements to become an authorized EHR testing and certification body was the missing piece in our decision to move forward. Now that we have that piece, we feel confident in announcing our intention to formally apply.

In our review of the NPRM, we found it sound, reasonable and a big step forward for formal testing and certification criteria to support Health IT. We will offer our comments as requested, but overall it was an excellent effort.

And this point about Drummond Group’s long term plans for EHR certification:

Last point. We won’t spend too much time here on this blog talking about the Permanent Certification program given the more immediate concerns of the Temporary Certification program. We will say we plan on being part of the Permanent Certification program. More importantly, we want to convey that since our initial press release last November, we have known that we are not in EHR testing for the short haul, but rather, the long term.

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.

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.

I’ve had real problems with the idea of there only being one EHR certifying body for a while now. I think competition usually brings the best out of organizations and forces them to be better than they would have been had there been no competition. Plus, it usually brings the price of things down also.

With that background, I was very happy to see that Drummond Group Plans to Certify EHR software as well. One of the comments on this blog pointed this group out to me and I’m very happy to see that they’re planning to enter the EHR Certification fray. Here’s a short quote from their press release:

Drummond Group has been approached recently by numerous EHR software and services companies that need to be certified.

“Clearly there is a growing demand for EHR certifications, says Rik Drummond, CEO of Drummond Group. “Drummond Group has been supporting Fortune 500 industries and government by certifying the transfer, identity and cybersecurity of their internet information flow over the last ten years. We have also done testing for the CDC, DEA and GSA. Certification of EHR is a natural extension of our testing program, and we believe we can provide great value for the medical community. We look forward to the publishing of the ONC requirements in the days ahead so we can get started.”

This is very good news!

I contacted Drummond Group to try and get an idea of how much the Drummond Group EHR certification might cost. As expected, there answer was that they’d be waiting for the ONC certification criteria before determining the cost and “what” to certify. So, we’ll have to wait to compare Drummond’s EHR certification costs with CCHIT’s EHR certification costs.

I also asked them whether they thought they would continue EHR certification after the EHR stimulus money runs out. Here was their quick response:

We would plan to continue if the users were happy with the certification after the stimulus money is gone…we have tested one standard for over 9 years without stimulus funds. In that case, the users still find great value in certified interoperable products and the numbers continue to grow in adoption. The vendors view Interoperability Certification as two things:
The certification seal adds marketing recognition and the testing is considered an extension of their
own Quality Assurance testing that they could not create internally on their own. It’s a win-win.

If they do decide to continue certifying EHR, I hope they will focus on interoperability certification. That could be beneficial and what I think the EHR stimulus money should have been spent on in the first place.

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 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.

I’ve discussed a lot of problems (there are many) with the CCHIT EHR Certification in the past. 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 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.

The problem of having a criteria that only applies to a client server based EMR is a pretty serious problem since so many EMR these days are web based and wouldn’t need or want to use Kerberos. CCHIT should really find a way to deal with this problem. Issues like this could also be a problem for the HHS criteria, so it will be interesting to see if HHS can do a better job than CCHIT has done.

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?

If you’ve had enough of my posts from a talk Marc Probst gave, then you’ll be glad to know this is the last one. There’s no hiding my respect for Marc and hearing him in person did nothing but elevate that respect for him. Some of the comments below will feel a bit random, but I thought they were interesting enough to share with you all.

Meaningful Use and Certified EHR Overlap
I asked Marc about the challenge of reconciling the overlap between the certified EHR criteria modeled after the meaningful use matrix and meaningful use itself. It seemed that they were measuring basically the same thing. Marc’s response was, “That’s a battle I lost.” Then, Marc muttered under his breathe something about certifying the software versus the users. Basically, he was in agreement and under the same confusion I’ve had in regards to the value of certifying the software related to MU versus you actually meaningful using your EMR.

Challenge for Hospital Systems
At one point Marc talked about the challenge of a hospital to adopt an EHR if they haven’t started this already. He started listing off things like a data center and encryption. The data center for a hospital is a significant challenge that takes time. I’ve been a part of the design, creation and building of a couple of data centers and infrastructure like this takes time to implement. I still believe it’s premature to purchase an EHR, but I don’t think it’s premature to plan for things like network infrastructure, data centers, etc.

Certification and Procurring the Right EMR
I had to smile when Marc, co-chair of the EHR certification workgroup, said point blank, “EHR certification is not about procuring the right EHR system.” If you’ve read this blog for any length of time you know how I feel about this subject. Glad to hear Marc say it too.

Funding and EHR Adoption
Marc was really honest when he described that IHC had 0 doctors doing CPOE. I was surprised by this since my childhood doctor was from IHC and had an EHR back then. That said, Marc made an interesting point after saying that IHC had 0 doctors doing CPOE. He proceeded to say he didn’t think the reason they hadn’t adopted CPOE yet was because of a lack of funding. It was all the other things that took time to figure out which has delayed adoption.

On my twitter stream I was getting a number of skeptics around my previous post about meaningful use and EHR certification being simplified by CMS (Medicare & Medicaid Services). They seemed a bit surprised that CMS would simplify meaningful EHR use.

Let me add a little more content and context to why Marc Probst thinks the way he does about this subject and why I wholeheartedly agree with him that MU and certified EHR’s final rules will be simpler than they are in their current form.

One of the most compelling reasons Marc gave was when he talked about a meeting he had with David Brailer. In their meeting David Brailler told Marc Probst that “Meaningful use will be a small bump in the road.” Marc then described David Brailler’s reasoning. Basically, the EHR stimulus package is only $20 billion (yes, I rounded to make the math nicer) of spending by the government after you take into account the penalties and other savings they should achieve. If you look at that spending over the number of years it will be given out we’re looking at somewhere in the neighborhood of $3 billion per year (another round number) of spending by the government. Then, the all important question:

Is CMS going to put a bunch of major roadblocks in the way of the government spending $3 billion per year on EHR?

Of course the answer could be discussed, but the point is that $3 billion in the government’s budget is nothing. Yes, I’m cringing while typing that, but it’s true. That’s why David Brailer is dead on when he says that meaningful EHR use will be a small bump in the road.

Personally, I think this is a great thing. I’ve been arguing that the barriers to this money are too high that it would be a mistake for doctors and clinics to focus too much of their energy on getting the EHR stimulus money. Now if those barriers were to lower, we’d not only see the increase in interest in EHR software, but we’d also see a significant and meaningful increase in adoption and purchase of EHR software. Then, the fun really begins.