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CCHIT EHR Certification Criteria Problem

Posted on October 16, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

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.

My EHR Certification Recommendations – For EMR Vendors

Posted on October 12, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

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?

Cost of New CCHIT EHR Certifications

Posted on September 14, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Time to take a look at the costs associated with the 2011 CCHIT Certification programs. If you’re not sure which programs I’m talking about, you need to go read my post about Preliminary ARRA Certified 2011 and CCHIT Certified 2011.

The following are the costs that CCHIT plans to charge for their 2011 EHR certifications:
CCHIT Certified 2011 Ambulatory EHR – $37,000 with a $9,000 annual renewal
CCHIT Certified 2011 Inpatient EHR – $49,000 with a $9,000 annual renewal
CCHIT Certified 2011 Emergency Department – $37,000 with a $9,000 annual renewal
CCHIT Certified 2011 ePrescribing – $18,000 with a $9,000 annual renewal

Preliminary ARRA Certified 2011 1-2 modules – $6,000 with a $1,000 annual renewal
Preliminary ARRA Certified 2011 3-5 modules – $10,000 with a $2,000 annual renewal
Preliminary ARRA Certified 2011 6-10 modules – $15,000 with a $3,000 annual renewal
Preliminary ARRA Certified 2011 11-20 modules – $24,000 with a $4,000 annual renewal
Preliminary ARRA Certified 2011 >20 modules – $33,000 with a $5,000 annual renewal
*These are estimates subject to final approval

Of course, the ones that matter most are the CCHIT Certified 2011 Ambulatory EHR for $37,000 and the Preliminary ARRA Certified 2011 >20 modules for $33,000. Why? These are the two certifications that most people care about. If you’re an EHR vendor, then you’re going to want to do one of these two options (Assuming you’re going to go with CCHIT certification. More on that later.). These are the two options which should eventually be recognized as the certified EHR requirement for the ARRA EHR stimulus money.

Which CCHIT Certification Should I Do?
The question an EHR vendor has to make is which of these two certifications make sense. Will having CCHIT Certified 2011 help you to sell more EHR software than just being Preliminary ARRA Certified? I’m guessing that it probably won’t. Most people I’ve seen really just want to make sure they get the ARRA stimulus money to pay for their EHR. Plus, with either certification you’ll be able to honestly tell a clinic that you have a “certified EHR.” Most doctors won’t know or care about the difference in the certification types.

Many might think that it’s only a $4,000 difference between the Preliminary ARRA 2011 certification and the CCHIT Certified 2011 so why not just get the later. It is interesting that the costs are so close to each other. However, remember that this isn’t the only cost associated with becoming certified. One EMR vendor I talked to put the software development costs to become CCHIT Certified in the six figures. We won’t know for sure until CCHIT publishes the final certification criteria, but I project that the CCHIT Certified requirements will number close to 300 while the Preliminary ARRA requirements will be close to 100. That’s a huge difference in development costs to meet 200 more requirements which your customers may or may not find useful.

Some might use the CCHIT Certified 2011 to try and assure potential buyers that they’ll have a more successful EMR implementation because of this certification. Many might actually believe it, but unfortunately there’s no evidence to prove this is actually the case.

EHR vendors should also be aware that CCHIT is looking at doing a site certification as well. This might be a better option for some EHR vendors who work with people who have few people actually interested in the EHR stimulus money.

Other EHR Certification Options Beyond CCHIT
It’s still too early to know for sure if other EHR certifying bodies are going to be created to handle the HHS certification requirements for EHR. However, I’m willing to bet that at least a couple will be created.

Basically, CCHIT has set the price for EHR ARRA certification at $33,000 with a $5,000 annual renewal. I could be wrong, but that seems like a lot of money to certify a piece of software. I’m guessing that some entrepreneurial folks will find a way to do it for cheaper. Could you certify 100 EMR vendors for less than $3.3 million? We’ll see what ONC/NIST requires from a certification organization, but seems like a pretty nice business model to me.

For EMR vendors, this is important because competition amongst certifying bodies will most certainly drive the cost of EMR certification down. Then, the PR battle between CCHIT and the new certifying bodies will begin. Basically, this could be really interesting to watch if someone else decides to join the EHR certifying fray.

Preliminary ARRA Certified and CCHIT Certified

Posted on September 12, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

As promised, here’s my look into the two certifications that CCHIT is currently pursuing. I got most of the details of what they’re talking about from this CCHIT presentation. Basically, CCHIT plans to offer two forms of EHR certification starting October 7, 2009: CCHIT Certified 2011 and Preliminary ARRA 2011.

CCHIT Certified 2011 is basically just a continuation of the certification that they’ve been doing for a number of years now. I won’t go into all the details about why this is a waste of money, development time and provides no improvement an EMR implementation success rates, but a quick search through my posts on CCHIT will be good place to start if you’re interested. Of course, the one difference between the 2011 CCHIT EHR certification is that they’ve tried to add all the other necessary requirements to meet ARRA’s certified EHR requirements.

Preliminary ARRA 2011 – Basically, this is CCHIT’s attempt to certify just the meaningful use requirements. They’ve broken it down into 21 meaningful use components with about 100 requirements (as best I can tell). CCHIT’s plan is for this certification will become the ARRA EHR certification program that will be eventually recognized by HHS.

Now let’s take a look at the timeline for each of these EHR certifications:

September 24, 2009 – CCHIT publishes certification criteria and test scripts for both CCHIT Certified 2011 and Preliminary ARRA 2011

October 7, 2009 – CCHIT starts accepting applications for both certifications

Spring 2010 – CMS publishes final rule

Spring 2010 (after CMS rule published) – CCHIT offers incremental testing for both EHR certifications to cover any gaps between the certification criteria published on September 24, 2009 and the final rule published by CMS. At this time CCHIT will also introduce the site certification option (this could be really interesting).

Now the question is which of the two EHR certifications you should consider or should you not worry about any of the above certifications? Unfortunately, I can’t really answer that question properly until we talk about the money involved in getting the above EHR certifications. I’ll cover that in a post on Monday.

CCHIT Town Hall Meeting on Preliminary ARRA Certified EHR

Posted on September 11, 2009 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ll be honest with you. For my own health I took off the last month from reading about CCHIT. I guess the birth of my third child made a difference as well. However, I’d been getting some comments and emails lately about CCHIT’s new certification programs and so I had to go and take a look at what was going on. Well, let’s just say that CCHIT has yet to disappoint me. They are so full of CCHIT that it’s not even funny. The conclusions they come to are crazy. Ok, now that I’ve made my bias clear, take a look at some of the things they’re saying.

One of CCHIT’s first conclusions made (in this blog post) after doing some polling at a CCHIT town hall meeting of vendors (mostly) is as follows:

Only a small fraction intend to wait until final ARRA certification is available. This appears to support our contention that we can’t afford to wait – products must be available, and providers must get started right away in order to have a chance of achieving meaningful use in 2011-2012.

I love how they switch the vendors desire to get the preliminary ARRA certification with a providers desire to have the same. Of course, EMR vendors want to be able to say that they are ARRA certified. EMR vendors (most) aren’t selling product right now and so they want anything they can get that will help convince providers to actually buy product instead of waiting for all the ARRA certification details. This is a vendor desire. It’s not a provider desire. Providers want HHS to move faster with their HHS Certification details.

Now on to what Mark Leavitt calls the “bottom line:”

What’s the bottom line? Well, it looks like these new programs have a good chance of delivering what is needed from certification to support an accelerated adoption of health IT in the ARRA environment.

I really don’t get how they draw these conclusions. The town hall meeting showed that EHR vendors have an interest in becoming certified. I didn’t need to have a meeting for that. I just needed to dangle $36 billion of stimulus money and say you have to be EHR certified to know that many EHR vendors will want to get certified.

It also might be probably is true that $36 billion of stimulus money will accelerate EHR adoption. However, there’s no proof that CCHIT certification or HHS certification or any EHR certification for that matter will actually accelerate adoption or the more important goal of successful adoption of EMR software.

Here’s a link to the best chart from the CCHIT town hall meeting with vendors. What that chart tells me is that 60% of those attending only really want certification to get the ARRA stimulus money. 24% of the EMR vendors don’t know the difference between the CCHIT Certified and the Preliminary ARRA Certified and so they don’t know what they want. That leaves about 16% (probably those who are already CCHIT Certified) that want the full CCHIT Certified. Sounds right. Most EHR vendors just want to find a way to sell more product and get access to the EHR stimulus money, right?

Point being. Let’s not kid ourselves about what CCHIT is really trying to accomplish. The results from the polls on the CCHIT blog post describe well that CCHIT is about the EHR vendor and not the doctors, clinical practices, or improving the quality of healthcare.

That feels better. Now I better write my post about the difference between CCHIT Certified and Preliminary ARRA Certified and the road map ahead for CCHIT. I’ll post that tomorrow.