HITECH Answers recently posted a great post that gives a run down of the EHR Incentive program’s progress in 2011. Here’s their list with my own analysis and commentary of each point.

123,921 Eligible Professionals have registered for EHR Incentives, 15,255 have successfully attested to meaningful use in the Medicare program.
This seems like such a HUGE difference in numbers. That’s just over 12% of Eligible Professionals that registered attested to meaningful use. Does this mean that we’re going to see a tidal wave of meaningful use attestation in 2012? Possibly.

I believe that we’ll see more eligible professionals attesting to meaningful use in 2012. However, the question is how many of those other 108,666 will attest to meaningful use in 2012 and how many are like the Happy EMR Doctor who just registered to see the MU process. I wonder how many first hand meaningful use experiences by doctors will scare doctors away from MU attestation.

3.077 Eligible Hospitals have registered EHR Incentives and 604 of those have successfully attested to meaningful use.
This is almost 20% of hospitals that have registered that have attested to meaningful use. It’s not surprising that this number is a lot higher than eligible professionals. I still believe that the wave of meaningful use attestation will come from these other 2473 hospitals and probably many more that still haven’t registered. I haven’t seen a good number of how many hospitals are in the US. Does anyone know that number? The EHR incentive money that goes to hospitals will dwarf those of eligible professionals.

$2,533,689,145 has been paid out in Medicare and Medicaid Incentives.
$2.5 billion sent out in 2011. I just went back to the first time I tagged meaningful use on this site on April 3, 2009 (coincidentally I have 19 pages of 10 posts each tagged with Meaningful Use). Amazing to think that it’s taken basically 3 years to spend $2.5 billion on EHR.

277 hospitals have received payments under both Medicare and Medicaid and of those 12 were CAHs.
That’s about half of the hospitals that have attested to meaningful use under Medicare are also getting the Medicaid EHR incentive money as well.

22% of eligible professionals that have been paid EHR incentives are Family Practitioners and 20% are Internal Medicine.
I must admit that I would have thought that the percentage of family doctors that got paid EHR incentive money would have been a lot higher. I guess when you have so many other specialty areas I shouldn’t be that surprised. I also wonder why the internal medicine number is so high. These numbers actually make me believe that a lot of family practice doctors are sitting out when it comes to meaningful use.

41 States Medicaid programs were open for registration. Two additional States launched in January of 2012.
I wonder what’s holding back the other 7 states. From what I’ve seen all the states will eventually get there.

More than 1500 EHR products have been certified by ONC-ATCBs.
That’s a lot of EHR software. I still put the EHR company list at about 300 EHR vendors. 1500 includes multiple versions of the same software, partial EHR certification for products like data warehouses, ePrescribing, etc. The best thing that’s come from the ONC-ATCB program is that it has made EHR certification basically irrelevant in the EHR selection process. Every EHR vendor is certified now. This is much better than the false assurances that EHR certification provided before. I still dislike what EHR certification has done to the industry, but at least it’s not misleading doctors the same way it was before.

You’ve undoubtedly heard the argument before: EHR certification is about assuring that systems meet minimum requirements for functionality and interoperability, but the certification process falls way short in terms of usability, privacy and security. But have you heard the argument from one of the ONC-authorized certification bodies?

This is an excerpt from an e-mail I received today:

Meaningful Use criteria have become a massive EHR certification driver for healthcare organizations. Hospitals and other providers rely on the criteria to ensure that their health IT systems meet minimum government-specified functionality and interoperability requirements to support Stage 1 of Meaningful Use.  Achieving Meaningful Use also ensures a health care organization qualifies for reimbursement under the American Recovery and Reinvestment Act as a way to incent adoption of e-health processes among health organizations. The ultimate goal is to improve our nation’s healthcare system by leveraging technology to allow greater access to important health information and empower patients to securely access their own health information.

However, as one of only five organizations authorized to test both complete and modular EHRs by the Office of the National Coordinator (ONC) for Health IT, ICSA Labs questions whether EHR certifications are enough as the criteria represents only minimum requirements. Amit Trivedi, healthcare program manager at ICSA Labs, believes providers should take further steps to heighten the security and privacy of their health IT systems. He also suggests vendors should look beyond the current regulations to address and improve usability, data portability, and information exchange in their products.

That’s right, ICSA Labs, one of five organizations currently authorized to test and certify complete EHRs on behalf of the Office of the National Coordinator for Health Information Technology, seems to think that the standards it tests EHRs against are inadequate, which is something that critics of certification—particularly critics of the Certification Commission for Healthcare Information Technology—have been saying for years. Critics of many of the larger vendors have been saying that, too. But it’s shockingly refreshing to hear this from an actual certification body.

In fact, the publicist for ICSA, a unit of Verizon Business, has offered interviews with executives of two lesser-known vendors,  Health System Technology and Design Clinicals, to talk about how they are going beyond the minimum certification requirements. Deadlines beckon, so I didn’t really have time to wait for the publicist to try to find me an schedule opening for one of the executives, but here’s a statement from a March 30 ICSA press release that is somewhat telling:

“This year we are expanding our certification programs into health IT, a much-needed area of focus to help modernize today’s health care system,” said George Japak, managing director for ICSA Labs. “With our new focus on safeguarding patient information within electronic health records, we are committed to helping accelerate the adoption of health IT.”

We don’t hear too much about security in the context of certification from too many other camps, so it’s nice to hear that at least one certification organization is critical of the rules it is under contract to follow. Perhaps we’ll see tougher usability, privacy and security standards in the permanent certification program ONC needs to have in place by the beginning of 2012 to support the forthcoming Stage 2 “meaningful use” requirements from CMS.

Wishful thinking?

For those of you that are relatively new to EMR and HIPAA, you might not appreciate this post as much as long time readers of EMR and HIPAA. A few years back, I admit that I was pretty harsh on CCHIT and their EHR certification. I remember one guy stopping me at a conference and after realizing who I was asked, “so what’s your issue with CCHIT?” I was happy to answer that I thought they misled the industry (doctors in particular) by saying that the CCHIT certification provided an assurance that the EHR was a good EHR. They never came outright and said this, but that’s what EMR sales people would communicate during the sales process.

In fact, EHR certification was incorrectly seen by many doctors and practice managers as the stamp of approval on an EHR being of higher quality, more effective, easier to use, and was more likely to lead to a successful EHR implementation. EHR certification today still has some of these issues. However, the fact is that the EHR certification doesn’t certify any of the great list above. If EHR certification of any kind (CCHIT or otherwise) could somehow assure: a higher implementation success rate, a better level of patient care, a higher quality user experience, a financial benefit, or any other number of quality benefits, then I’d support it wholeheartedly. The problem is that it doesn’t, and so they can’t make that assurance.

So, yes, I do take issue with an EHR certification which misleads doctors. Even if it’s the EHR salespeople that do the misleading.

I still remember the kickback I got on this post I did where I said CCHIT Was Marginalized and the post a bit later where I said that the CCHIT process was irrelevant. Today, I came across an article on CMIO with some interesting quotes from CCHIT Chair, Karen Bell. Here’s a quote from that article.

In addition, the Office of the National Coordinator for Health IT’s (ONC) new program has provided two new reasons for certification: proof that an EHR can do the things that the government wants it to do, and to enable eligible providers and hospitals to get EHR incentive money.

“The idea is not to assure the product will do all things that are desired for patient care, instead, the idea is to stimulate innovation,” said Bell. As a result, the program is considered a major success because more than 700 certified health IT products are now on the ONC website. “The idea was to get a lot of new products started. This is a very different reason for certification than what we began doing several years ago,” she said.

However, just because CCHIT or another ONC-Authorized Testing and Certification Body (ONC-ATCB) doesn’t test and certify for a particular ability, that doesn’t mean the EHRs don’t have it. “It’s just up to [the provider] to make sure the vendors have it,” said Bell.

I first want to applaud Karen Bell and CCHIT for finally describing the true description of what EHR provides a clinic assurance that:
1. The EHR does what the government wants
2. You are eligible for the EHR incentive money
Then, she even goes on to say that it’s up to the providers to make sure the vendors have the right capabilities for their clinic.

I imagine Karen and CCHIT would still probably say that the CCHIT “complete” EHR certification provides assurance that…< fill in the blank >, which the ONC-ATCB EHR certification doesn’t provide. The happy part for me is that even if CCHIT says this, no one is really listening to that message anymore.

Yes, CCHIT has essentially become irrelevant.

I can’t remember anyone in the past year asking me about CCHIT certification. From my experience, many people care about ONC-ATCB EHR certification, but they really couldn’t care less if it comes from CCHIT, Drummond Group, ICSA Labs, SLI Global, or InfoGuard (That’s all of them right?). Have any of you had other experiences?

I also do enjoy the irony of this post coming right after my post about differentiation of EMR companies (Jabba vs Han Solo). CCHIT is the reason that I know so much about the challenge of EHR differentiation. CCHIT’s efforts provided some very valuable (and lengthy) discussions over the past 5 years about ways to help doctors differentiate between the 300+ EHR vendors. As you can see from my comments above, I was just never satisfied with CCHIT being the differentiating factor. As you can see from my post yesterday, I’m still searching for a satisfactory alternative for differentiating EHRs. Until then, we’ll keep providing an independent voice a midst all the noise.

Looks like the people at HHS and ONC have been working hard. On Monday this week they published the Permanent EHR Certification Program Final rule. You can find the press release about the Permanent EHR Certification final rule on my new EMR News website (if you have other EMR news, please let me know).

You can download the full Permanent EHR Certification final rule here (Warning: PDF). Although, I must admit that I found the permanent certification fact sheet very interesting. Here’s my summary:
*Testing and certification is expected to begin under the permanent certification program on January 1, 2012 (with an exception if it’s not ready)
*NIST (through its NVLAP) will continue with accrediting organization to test EHR and to work with ONC to create test tools and procedures
*A new ONC-Approved Accreditor of ONC-AA will be chosen every 3 years
*All ONC-ATCB (those bodies certified under the temporary) must apply to be ONC-ATB (permanent certification bodies)
*ONC-ACB have to renew every 3 years
*Gap Certification will be available for future EHR certification criteria.

The most interesting part to me was that ONC will be selecting an ONC-AA (Approved Accreditor) through a competitive bid process. So, they’re going to accredit an accreditor to accredit the certifiers? I think you get the gist. I can see how ONC saves so much by only having to have to deal with one ONC-AA and not the 6 ONC-ATCB (that was in the sarcasm font if you couldn’t tell).

It does make sense to have a gap certification so that EMR vendors that are already certified don’t have to certify against all the criteria every time. I guess in theory changes an EHR vendor has made could have caused issues with their previous functions, but that’s pretty rare. Especially since their users will need it to be able to show meaningful use (which is why EHR certification has little meaning beyond it being required for EHR incentive money).

Whether you agree or disagree with EHR certification (I think you know where I stand), you have to give ONC credit for pushing out the EHR certification program so that there are plenty of certified EHR software out there to choose from. Looks like they’re well on their way to implementing the permanent EHR certification as well.

In the weirdest news I’ve seen in a while, SureScripts has become an ONC-ATCB. Here’s the details from Health Data Management:

In a Dec. 23 announcement, the Office for the National Coordinator for Health IT said that Arlington, Va.-based Surescripts can verify that e-prescribing, privacy and security modules meet the standards laid out in the meaningful use requirements. Surescripts is the sixth authorizer to be approved by ONCHIT, but it’s the only one with limited certification abilities—the five others have ONCHIT’s blessing to certify Complete EHRs and EHR modules.

Doesn’t this scream conflict of interest? They run a nationwide e-Prescribing network, and yet they can certify ePrescribing for ONC. I guess you could make the argument that they know ePrescribing well and so they are qualified to do it. Although, it is just weird and awkward to consider them as an ATCB. I wonder which ePrescribing companies will actually use them. Why did SureScripts even go to the effort to become an ATCB?

I must admit that the following question is one that I don’t have a very good answer to. However, I’ll offer what I know and hopefully the readers of the site can also chime in with their thoughts in the comments of this post. This question was posted in the comments of my previous EMR Stimulus question and answer post.

Can you help out another reader with a pressing question? Where can I find a good listing of EHRs for dentists? I’m looking specifically for ONC certified products that cater to dental practices and I’m coming up short so far. I know that DDS/DMDs can qualify for incentives under ARRA and they’ll be dinged on the Medicare side if they don’t use EHRs, but how are they supposed to comply if the software’s not out there for them? I’ve talked to several vendors with ONC certification who basically said they’re ignoring dentists in their outreach/software development (due to the larger potential market for internal medicine/general practice, the specialization required for dental systems, etc). A lot of dentists have PMS that they mistakenly believe are full EHRs, but it seems like there is a huge market out there for dental EHRs that is being ignored.

There was some discussion in the comments of the post where the above questions and comments were posted about whether Dentists do in fact qualify for EMR stimulus incentives. My understanding was that they could qualify. This of course assumes that they have enough Medicare and they were meaningful users of a certified EHR (as with everyone else). Although, I believe dentists are considered eligible providers (I’m sure someone will correct me in the comments if I’m wrong).

Unfortunately, I haven’t seen any EHR list by ONC or anyone else for that matter that has EHR software for dentists. Of course, I posted a link to the official ONC-ATCB certified EHR list before. So, watching that list might be the place to start. Although, that list is going to grow between now and the end of the year quite quickly. I won’t be surprised if that list is at least double or triple the size that it is now.

I must admit that I don’t know many of the dentist specific EHR, so I couldn’t go through the list to find the EHR software that is a certified EHR for dentists. If someone else does and wants to share it in the comments, I’ll post that list for others to see too.

I have heard of one dentistry software called Dentrix. I asked my friend who does some work with them about their take on the EHR stimulus money for dentists. He said that he’s asked for more info himself and the only answer he gets is that they need to talk to Dentrix Enterprise. I guess they have multiple versions of their software. Sounds like they are a bit like Allscripts with a ton of different EHR packages depending on size of the office. Unfortunately, Dentrix didn’t answer mine (and others) request on Twitter for information about the EHR stimulus for dentists.

One thing is certain. Dentists that try for the EHR stimulus money will likely be happy to evoke the exception clause for some of the meaningful use requirements that don’t apply to them.

One of my more interesting meetings at AAFP was with a company called SLI Global Solutions. The meeting was so interesting, because SLI Global Solutions plans to apply to become an ONC-ATCB organization very soon. This coming after the announcement of the first ONC-ATCB certified EHR from Drummond Group and CCHIT along with the announcement of InfoGard as an ONC-ATCB and Weno Healthcare’s plans to become an ONC-ATCB.

We obviously had a long conversation about the EHR certification, but suffice it to say that SLI Global Solutions is going full steam ahead to become an ONC-ATCB. It sounds like they’ve been doing a number of other certifications previously. They’ve even done some consulting work in healthcare.

When I asked SLI Global Solutions what they thought would help them to differentiate themselves from the other ONC-ATCB, one response was that they were really good at providing feedback and helping organizations through the certification process. I personally think that many EHR vendors and other healthcare organizations that need to certify for the EMR stimulus money are nervous about the unknown issues related to certification. If SLI Global Solutions can provide them a feedback loop then it could go a long way to relieving the nerves. This is the main suggestion Jim Tate makes in his post about selecting an ATCB.

I asked SLI Global Solutions how much they planned to charge for the EHR certification. Here was their response, “We have not finalized the pricing yet because we are contemplating ancillary services pre and post certification but we will likely be in the $20,000 USD ballpark.”

With SLI Global Solutions, that would make 5 ONC-ATCB and I’m guessing there are other companies like this that will become certifying bodies as well. I’m all about competition and so the more ONC-ATCB the merrier.

It does make me wonder how many ONC-ATCB the market can support. Not to mention, there’s the interesting question of whether they’re a bit late to the party. I guess time will tell.

Today, CCHIT announced their first ONC-ATCB certified EHR a day later than Drummond Group’s ONC-ATCB announcement. Although, CCHIT is announcing 33 EHR vendors (21 complete ONC-ATCB certified EHR and 12 module certified). No real surprises on this list. They were the previously CCHIT certified EHR companies. That gives us 36 total ONC-ATCB EHR right now (or 24 if we’re talking complete EHR certification).

Here’s the list of Complete ONC-ATCB certified EHR:
ABEL Medical Software Inc.
ABELMed EHR – EMR / PM

Allscripts
Allscripts Professional EHR

Aprima Medical Software, Inc
Aprima

athenahealth, Inc
athenaClinicals

CureMD Corporation
CureMD EHR

The DocPatientNetwork.com
Doctations

eClinicalWorks LLC
eClinicalWorks

Epic Systems Corporation
EpicCare Inpatient – Core EMR

Epic Systems Corporation
EpicCare Ambulatory – Core EMR

GE Healthcare
Centricity Advance

gloStream, Inc.
gloEMR

Intuitive Medical Software
UroChartEHR

MCS – Medical Communication Systems, Inc.
iPatientCare

Medical Informatics Engineering
WebChart EHR

Meditab Software, Inc.
IMS

NeoDeck Software
NeoMed EHR

NextGen Healthcare
NextGen Ambulatory EHR

Nortec Software Inc
Nortec EHR

Prognosis Health Information Systems
ChartAccess

Pulse Systems
2011 Pulse Complete EHR

SuccessEHS
SuccessEHS

Here’s the list of module ONC-ATCB EHR Certifications:
NOTE: CCHIT does make a comment that some of these may become complete EHR certifications later.
Allscripts
Allscripts ED

Allscripts
Allscripts PeakPractice

Health Care Systems, Inc.
HCS eMR

NexTech Systems Inc.
NexTech Practice 2011

nextEMR, LLC
nextEMR, LLC

PeriGen
PeriBirth

Sammy Systems
SammyEHR

T-System Technologies, Ltd.
T SystemEV

Universal EMR Solutions
Physician’s Solution

Vision Infonet Inc.,
MDCare EMR

WellCentive
WellCentive Registry

Wellsoft Corporation
Wellsoft EDIS

Drummond Group just posted the news of the first 3 EHR vendors which have been officially certified EHR for the ARRA EHR stimulus money. Looks like Drummond Group won the race to be the first to certify an EHR.

The interesting thing for me is the list of 3 EHR vendors that became the first certified EHR:
PARADIGM (QRS Inc.)
ifa EMR (ifa united i-tech Inc.)
ChartLogic EMR (ChartLogic, Inc.)

I consider myself pretty well informed about EMR vendors, but I only realy knew 1 of the 3 and I’d maybe heard of one other, but just by name. As all the ONC-ATCB certified vendors start completing their EHR certification, I think we’re going to learn about a WHOLE lot of EMR vendors that very few people knew about previously.

I also find it interesting that all 3 EHR vendors have already updated their website in some way to represent the new ONC-ATCB EHR certification.

Note: We need a new way to identify the certified EHR. ONC-ATCB just doesn’t have the right ring to it. I might work on this problem.

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.