I’ve been meaning to post about the HIT Policy Committee meeting for a month or so now. The reason I didn’t is that when I post about things like this, I like to make sure that I’ve had a chance to digest the information and provide some thoughtful analysis and commentary on what’s happening. Of course, thoughtful analysis and commentary takes a lot more work and time and so thus the delay. Enough about me…
Yes, on August 14th the HIT Policy Committee met to mostly talk about what certified EHR will mean under ARRA. You can see the full powerpoint from the presentation here. Luckily, CCHIT (I guess they have an interest in the topic) wrote a pretty good summary of what was said about EHR certification at the meeting (with a few of my own modifications):
- There will be a new form of certification. The Policy Committee recommended the term HHS Certified. (The labeling could change if there are issues.)
- The criteria for HHS Certification are recommended by the Standards Committee to ONC, then submitted for a formal approval process at HHS. As an experienced certifying body, CCHIT is offering suggestions and advice during the comment process, just as other stakeholders are.
- The Policy Committee recommended that ONC work with NIST to develop an accreditation process for certifying bodies and not place a formal limit on the number of entities that can be accredited.
- The Committee recognized the importance of leveraging work to date and maintaining momentum. For the near future—until the accreditation process is developed and operational — the Policy Committee recommended that CCHIT certification should be leveraged and that granting Preliminary HHS Certified status for EHR technologies should be done so as not to slow EHR adoption as the final HHS Certification criteria is approved.
- The Policy Committee recommended that HHS Certification be offered to modular products and that there be flexible approaches for non-vendor software.
- The Policy Committee recommended that HHS certification requirements focus on meaningful use.
While I still think that CCHIT has been marginalized to some extent, there’s no doubt that this meeting brought CCHIT and their criteria back into the fold to some degree. What will be interesting is to watch how much of the CCHIT certification criteria is accepted and used by HHS in developing the HHS EHR Certification.
In response to this, CCHIT sent the following materials (zip file) to HHS. I believe the excel file included in that zip file will turn out to be a crucial document in HHS’s development of the HHS EHR certification. I expect they’ll make some changes (it’s government after all), but I also expect it will form the basis of the HHS certification to at least some extent. I’m planning to do a full analysis of the document in a future blog post.
The question is when will we know what HHS has determined as an HHS Certified EHR and which bodies will become the certifying bodies for that HHS Certification? Here’s the timeline as best I can make of it:
- ONC Interim Final Rule by 12/31/09 – 60 day public comment period might not be required for EHR Certification. Don’t ask my why they wouldn’t do it since they’re doing it for meaningful use.
- Spring 2010? – ONC/NIST Definition of new accreditation Process for certifying bodies
- Fall 2010? – Completed accreditation of EHR certification bodies
The x factor in the schedule is how HHS plans to deal with preliminary ARRA certification. The HIT Policy committee recommended that HHS do a preliminary certification so that certification bodies wouldn’t have to wait to get started on EHR certification. CCHIT is moving forward full bore on doing preliminary ARRA certification. Maybe I don’t understand the process completely, but I haven’t seen where HHS/ONC has acknowledge that they’re going to go forward with this recommendation from the HIT Policy Committee. If they do, then we’ll start seeing some preliminary EHR certifications this year. If they don’t it looks like we’ll be waiting until next Fall to know for sure.
For those that attended the meeting, was there anything else important that I missed?