Between the initial recommendations in July and the adopted recommendations in August, one critical word was added to the definition of “certification”. That one word is “minimum” — and this one word expresses the correct approach and philosophy for the government’s role in the certification process for EHRs.
In this post I’ll address why a “minimum” approach toward certification makes sense:
- Why “Minimum” Certification is Right: More Like UL
- Why Current CCHIT Certification Based on Functionality Risks Irrelevance or Lock-in to Outdated Technology
Why “Minimum” Certification is Right: More Like Underwriters Laboratories
Here’s the recommended definition of “Certification”:
Proposed Definition of HHS Certification
HHS Certification means that a system is able to achieve the minimum government requirements for security, privacy, and interoperability, and that the system is able to produce the Meaningful Use results that the government expects.
HHS Certification is not intended to be viewed as a “seal of approval” or an indication of the benefits of one system over another. (emphasis added)
Let’s parse the proposed Definition of Certification to see what’s right:
“a system” — a system is can be made up of many components, not just today’s monolithic version of EMR 1.0
“minimum government requirements” — more than minimum is likely to stifle innovation and protect incumbent vendors
“for security, privacy, and interoperability” — Certification of these (and only these) elements are the lubricants that will create data liquidity in our health system.
Note what’s NOT being certified — not EHR functionality (ala current CCHIT process), not vendor financial stability, not vendor support of customers, not EHR usability.
While these are important factors in a purchase decision, the Committee rightly noted that these elements should be provided by “advisory services” (e.g., KLAS, Consumer Reports) and should not be central to achieving certification.
“able to produce Meaningful Use results” — just as it should be…certification should not be an end in an of itself, but a means toward the end of achieving Meaningful Use.
“not intended to be viewed as a ‘seal of approval’” — correct…the market can work this out.
With a focus on security, privacy and interoperability, EHR certification becomes more comparable to a Underwriters Laboratories (UL) certification. When we see the UL certification, we understand that that it is geared toward assuring minimum safety requirements, not guaranteeing the ultimate in product quality or functionality.
Why Current CCHIT Certification Based on Functionality Risks Irrelevance or Lock-in to Outdated Technology
Current CCHIT (Certification Commission for Health Information Technology) certification of EMRs (electronic medical records) is based solely on functionality. Hundreds of EMR functionality elements are measured in the current pass/fail process, and vendors must meet 100% of requirements.
Consider a couple of examples to see why this approach teeters on irrelevance and/or customer lock in to outdated technology.
Suppose you had a list of a hundred numbers that you wanted to add up. While you’d be happy with a $5 calculator, a “CCHIT-like certification process” technology might specify that the software you used must have the functionality to do graphing, functions, pivot tables and macros, requiring you to purchase a PC and spreadsheet software to add up your numbers.
EMR implementation consultant and blogger Laura Miller provides two examples of how government specification of functionality (rather than desired outcomes) can perpetuate outdated technology:
As I sit in my living room, gazing at a dot matrix printer, I question my wonderful government’s choices in healthcare. You see, we created a template package that prints the CHDP PM160 Form that uses a dot matrix imprint printer. Why do you ask? Because it’s for the state of California of course! It needs to be on a 4 piece carbon copy piece of paper. Yes, I am serious.
I also reminded of sitting next to my favorite biller at my previous job, Cindy. Every morning she would dial into the Medicare Bulletin Board System using a Modem. Yes, that’s right, a modem. The only payer that she had to do this for.
Unless you happen to be a vendor of spreadsheets, dot-matrix printers, or modems, I trust you see the problems with certification based solely on functionality. (In fairness to CCHIT, they are modifying their future processes not to be based solely on functionality.)
We can not emphasize enough just how important these two terms (meaningful use & certified EHRs) are to the market. These terms will literally define the HIT market for the next decade. John Moore, Chilmark Research blog (emphasis added)
There are definitely reasons to be pleased.
HIT Committee Approves Certification Recommendations
Healthcare Informatics; August 14, 2009
CCHIT Has a Seat at Table — for Now
Chilmark Research blog; August 14, 2009
Certification Recommendations OK’d
HealthDataManagement; August 14, 2009
Table of contents for The Dog Manifesto: A Disruptive Innovator's Guide to Health IT
- Will HITECH Lead to Innovation? The Continuing Cat/Dog Dialogue
- Dogged Optimism: Five Innovative Aspects of HITECH
- Feline Foot-Dragging: Three Non-Innovative Aspects of HITECH
- Wait and See: What’s Unclear or To-Be-Determined (TBD) About HITECH.
- Can Cats Think Outside the Box? Here’s a Role Model.
- Stand for Quality Group: “Link HIT Investment to Quality Improvement”
- EHR 2.0: Thinking Outside the Cat Box
- Stunning Announcement: AMA Goes to the Dogs in Deal With Physician Web Portal Company
- Markle v. HIMSS: Differing Views of “Meaningful Use” and “Certification”
- Time for EHRs to Become Plug-and-Play
- Blueprint for Change: From EMR 1.0 to Clinical Groupware (EHR 2.0)
- Joe the Doctor: “…’scuse me, why do I want to bet-my-practice on an EMR?”
- RHIOs Emerging From Coma
- HIT Policy Committee Recommends “Minimum” Certification of EHRs
- PR Blunder of the Year: Federation of American Hospitals Says Meaningful Use Should Not Tie to Quality Improvement
- The Third Rail in HITECH Implementation: “Please Don’t Make Us All Speak Latin”
- Senator Grassley: You’re on Track About EMR Problems, But Here Are Some More Questions to Ask
- John Halamka’s Stunning 180: “Dogs and Cats Should Live in Harmony”
- Feedback Rolls in on Halamka’s New Stance on Standards: Cats Pissed, Dogs Thrilled