Friday, March 5, 2010

EHR Certification - Should CCHIT be "it"?

I posted this comment a couple of days ago on the ONC blog here. They finally moderated the comment and posted it this morning, so here it is again. I will have more on the ONC NPRM later....
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OK, I can’t believe I’m typing this, but I am.
As anybody that reads things I write, or listens to things I say, knows, I had lots of issues with the way CCHIT operated in the past and the effects it had on the EHR industry. However, currently CCHIT has a complete certification infrastructure in place ready to service both comprehensive EHRs and EHR modules immediately. No other organization is even remotely close to such capabilities.
I do believe your long term accreditation plan is good and much needed.
However, I would like to suggest that the entire temporary certification program needs to be scratched and that CCHIT be awarded ONC-ATCB status so certification processes can begin now. I don’t really see the value of engaging in a formal lengthy process just to create temporary bodies of certification. I also don’t see how submitting a bunch of forms and documentation to ONC and taking a quiz can provide assurance to both vendors and physicians that these newly accredited temporary bodies really know what they are doing, considering they have never tested an EHR before.
I believe ONC is underestimating the complexity of certification and the infrastructure required for a successful program, even a temporary one. Please remember that if all goes well, there will be a tremendous wave of adoption in the coming year and it will all be done under temporary certification bodies. In order to sustain future expansion of HIT, it is imperative that physicians have a good experience in 2010-2011.
I can easily envision horror stories, particularly regarding EHR modules, created by small underfunded vendors, getting temporary certification and providing nothing but disappointment and financial loss to customers.
In the engineering world, reinventing the wheel is not considered a worthy endeavor. CCHIT is there. It is experienced. It is up to date in it’s infrastructure and readiness. It has created a pared down ARRA certification and kept up with all ONC/CMS changes.
So why not let CCHIT start working on a temporary basis, while ONC begins the long term accreditation process for all applicants? Wouldn’t it serve the market and all our goals better?
It’s the simplest, cheapest, fastest and least risky solution and it’s the right thing to do.

5 comments:

  1. "I can easily envision horror stories, particularly regarding EHR modules, created by small underfunded vendors, getting temporary certification and providing nothing but disappointment and financial loss to customers."

    Unfortunately, CCHIT hasn't provided any sort of assurance in this regard in the years that it's been certifying either. CCHIT has control of the EHR certification cart and did very little to ensure successful EMR adoptions. Mark Leavitt even said that they can't make those assurances at the CCHIT town hall at HIMSS. So, I don't see how adding more organizations to the EHR certification group is going to cause any more trouble.

    In fact, new organizations will keep CCHIT more accountable as competition almost always brings out the best in organizations.

    Glad to see you started blogging!

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  2. Hi John,
    Welcome to my humble abode :-)

    I agree that CCHIT cannot guarantee integration, but nobody else will either and the ONC IFR specifically says that integration is the physician or hospital responsibility, hence my difficulty with this EHR module concept.

    I also agree that we need competition for CCHIT and for the permanent certification bodies there will be. I was just referring to the temporary (12-18 months) fix.

    I am writing about platforms and modules issues right now and I hope to get it posted later today. There are many challenges with this approach and we must be careful.

    Drop by later to read if you would like. I would be very interested in your opinion....

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  3. You are right Margalti that nobody else will guarantee integration if CCHIt cannot Also you wrote that you are writing about platforms and modules issues and get it posted later today.Can you please share that link on this post.

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  4. I too agree with Margalit that CCHIT cannot guarantee integration, but nobody else will either
    Margalit you said that you are writing about platforms and modules issues and will share it with us.Can you please give of that specific blog that you mentioned.I am really eager to read about that

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  5. My first ever blog post was dedicated to modules
    http://onhealthtech.blogspot.com/2010/03/advent-of-ehr-modules.html

    I often referred to this construct in other writings, but I think I should probably revisit the subject, since much has changed in the last year.

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