Many of us have enjoyed a few good minutes of fun having our fortunes told by soothsayers who claim they can predict our future based on patterns of tea leaves in a cup or the playing cards we’ve pulled from a deck.
We pay a few dollars for the entertainment and if the fortune teller is skilled, we are temporarily impressed by his “insight.” But once we leave the carnival, we come back to our senses. Fortune-tellers can’t predict the future.
With its latest announcement, the Certification Commission for Healthcare Information Technology (CCHIT) appears to have entered the fortune telling business.
And if information provided on blogs published by its founders is to be believed, some EHR vendors plan to have their fortunes told by the former EHR certification monopolist.
In June, ONC’s HIT Policy Committee released a Meaningful Use Matrix and proposed that it should serve as the basis for EHR certification as mandated by ARRA, the economic stimulus program signed into law last winter.
The Matrix consisted of five “Health Outcomes Policy Priorities” and associated Care Goals, Objectives and Measures. The Committee anticipated that the latter would be transformed into EHR certification criteria.
After a 2-month public comment period, the Committee tweaked the Matrix, essentially pushing back time-frames for implementing computerized order entry, and accelerating time-frames for implementing personal health records.
By mid-August, the Committee had approved a final version of the Matrix.
This document includes the very latest information on ARRA-mandated EHR certification criteria. It is in the public domain, there for all to see. ONC is expected to finalize these criteria next spring.
The criteria are not consistent with those used by CCHIT to certify EHRs. They are outcomes-oriented (CCHIT’s are feature, structure and process-oriented), and they do not require that any particular technology (such as the client-server applications used by the legacy vendors who sit on the board of CCHIT) be used to achieve the results.
Subsequently, HHS announced that it planned to assume responsibility for deciding which EHR systems qualified for bonus payouts under Medicare, and shortly thereafter, ONC’s HIT Policy Committee said that it planned to recommend that several entities should certify EHR systems.
In its announcement, the Committee envisioned the establishment of 10 to 12 such agencies.
The upshot of these moves by the Federal government are that (1)CCHIT no longer decides what criteria will be used to certify EHRs, and (2)its days as the exclusive provider of EHR certification services are numbered.
What has CCHIT decided to do in response to these setbacks?
It’s decided to become a fortune-teller!
New Role for CCHIT
Last week, CCHIT announced it will begin offering “streamlined,” or “modular” certification options, in which EHR vendors can apply to the agency for approval of distinct EHR modules like e-prescribing or electronic patient registries.
But as mentioned above, ONC won’t sign-off on its “meaningful use” criteria until the spring of 2010. In effect, CCHIT is asking EHR vendors to gamble that CCHIT can, like a fortune teller at a carnival, predict what those final recommendations will be.
“Choose the risk you want to take,” CCHIT Chairman Mark Leavitt recently challenged vendors. “Go ahead now (with a CCHIT review) and have an extra year to implement, with a small risk that there will be some gap in which EHR systems would have to be updated to receive final certification…” or risk the consequences of sitting on your hands, he presumably would add.
Never mind that the latest information is in the public domain, and that any vendor can compare it against their current capabilities and development plans! Disregard the fact that CCHIT has no track-record in promulgating outcomes-oriented certification criteria or in certifying against them!
What is CCHIT charging for its fortune-telling expertise? According to Government HealthIT, a HIMSS sponsored publication, prices for modular certification begin at $6,000 for up to 2 modules. They rise to $24,000 for up to 20 modules and to $33,000 for more than 20.
As always, fees for CCHIT’s comprehensive certification are $37,000 for ambulatory systems and $49,000 for hospital systems. Annual renewal costs are $9,000 for each.
That’s chump-change for the legacy vendors whose top executives sit on the board of CCHIT, but it guarantees nothing.
Conclusions and Recommendations
EHR vendors should perform their own analyses against the published HIT Policy Committee criteria and follow the HHS Web site for announcements regarding meaningful use criteria and the process by which EHRs will be certified.
If a vendor insists on having its fortunes told, it should consult with a reader of tea leaves next time the carnival is in town.
Glenn Laffel is a physician with a PhD in Health Policy from MIT and serves as Practice Fusion’s Senior VP, Clinical Affairs. He is a frequent writer for EHR Bloggers, where this post first appeared.