HIT Policy Committee Recommends “Minimum” Certification of EHRs

At last Friday’s meeting, the HIT Policy Committee adopted the recommendations of the Certification and Adoption Workgroup.

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• Why Current CCHIT Certification Based on Functionality Risks Irrelevance or Lock-in to Outdated Technology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.)

Conclusion

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. 

Additional References:

PowerPoint Summary, Certification and Adoption Workgroup Recommendations

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