CCHIT - Must read info....

Well, I had the opportunity to participate in a ‘Town Hall’ meeting with Dr. Mark Leavitt, the headman at CCHIT, at the TEPR ’06 event.  It was an interesting couple of hours.  Dr. Leavitt laid out the mission of CCHIT (pretty much to serve as THE certification organization for EMRs and other medical related software further down the road).  He was kind enough to review the scripts that they had so far generated.  I, and others, were encouraged to see that test items that somewhat ‘skewed’ the script (such as the growth chart as a required feature) were either modified as provisional or removed.  It was also heartening to see that there was a serious push for the certification by various agencies such as the AAFP, MGMA etc.  That was the good news.

 

The bad news you ask?  Well, let me see.  The cost.  It is far worse than what we had even imagined on this board.  Put bluntly, Dr. Leavitt was extensively grilled about this issue by a plethora of small vendors (including yours truly) at this town hall meeting.  The upshot of all this is the proposed fee structure outlined below.

 

$28,000 up front to start the review process.  3 reviewers (1 doc and 1 security tech will be on each team) shall conduct the review for 8 hours.  If the review takes longer than 8 hours, then the vendor will be charged for the extra.  For the 8 hours, the Doc will be paid $1200 - $1600 and about $1200 each for the other 2 reviewers out of the $28,000 collected.

At the end of the review, there will be a PASS/FAIL grade.  The question of if you will have to pay extra if you failed to ‘retake’ the test was left kind of open.

If you pass, then you will receive a ‘CCHIT CERTIFIED 2006’ sticker (if 2006 is the year you get certified).  You will then have the right to put the ‘CCHIT CERTIFIED 2006’ on your EMR.  If you choose to continue using the same sticker ‘CCHIT CERTIFIED 2006’ for an additional 2 years, you could do so by paying an extra $4800 each year in 2007 and 2008.  After that, you will have to recertify by paying the then current fee (which Dr. Leavitt openly admitted he had no idea if it would go up or down – I am skeptical of it going down).

 

Now here comes the kicker……

There is a percentage of the revenue we may have to pay – this was not very clear, so we will give CCHIT the benefit of the doubt.

However, what was very clear was this.  You will have to re-pay the full fee and recertify under the following circumstances:

1. You release a new version of the software.  Talk about killing innovation.  Every time you have a new ‘significant’ release, you would end up paying $28,000 and going through the time and effort or recertifying.  CCHIT will independently call your customer to verify if any ‘significant’ upgrades had been done on the software recently – so freezing your version number and releasing new patches would not be a work around.
2. You wish to use the ‘CCHIT CERTIFIED 2007’ on your software, when your certification year was 2006.  So if you don’t mind having an outdated sticker, you only have to pay the yearly $4800.  But if you want to upgrade your certification, you will have to dig deep.

 

To put it bluntly, we are looking at a MINIMUM fee of $28,000 a year.  We currently have a new release every 3 months, so technically, our fee could be MUCH higher.  We could, of course, cut our own throats by restricting new releases to once a year and lose our pricing and customer service advantages.

 

The argument is that this certification is ‘Optional’ and we don’t have to do it.  And then the rep from the MGMA gets up and says that they are recommending that their members only buy CCHIT certified EMRs and so does the AAFP, AMA etc.  So how optional is it going to be?  I don’t buy that argument at all. 

 

One of our fellow EMRUpdate members at the meeting did mention the discussions here and essentially the response was ‘blogs never hurt me, so blog away!” 

 

I am seriously convinced that the alternative certification option is looking more and more attractive.  How many of the small vendors on this board want to pay a minimum of $28000 a year?  The MGMA rep was essentially quoting a ‘per doctor EMR cost of $33,000 and so this is less than one sale’.  How many of us charge less than a fraction of that per doctor?  This certification pricing model is seriously flawed.  If we used a model like this, our customers would leave a vapor trail out of our offices.

 

So bottom line?  We could toe the CCHIT line and raise prices, cut innovation and eventually go out of business as all our competitive advantages will have evaporated.  Or vigorously back an alternative standard.  I think I know where I would like to be.  All you thoughts and comments are welcome.

Naveen V.

http://www.emr-electronicmedicalrecords.com

I raised that question before about what happens if you improve your software - and as expected, you have to recertify.

The price of certification is clearly this high because many vendors choose to charge this pricing in selling their software.  If the software were free, or a reasonable price, there is no way that certification would dare to charge this sum.

And if you fail, what right of appeal do you have? 

Since this is certification by CCHIT I presume that the whole process will be totally transparent.  I therefore see an opportunity for a group of physicians to get together and apply the CCHIT process, and certificate as a separate entity as well .... in the spirit of capitalism for a much cheaper price.  That would put a damp squib on these modern day pirates.

This is one reason why I cut out my AMA membership in 2002. They always seem to make the wrong choices, and I don't see paying them $450 a year to back them up with these poor choices.

Dr. Leavitt never did respond to our letter; they basically feel that they have it in the bag. Unfortunately, CCHIT will hurt all EMR vendors, even before they choose to participate or not. What will occur in the next 2 years is that practitioner offices will delay purchasing EMRs, waiting for the chips to settle. There are many questions to be answered, especially how HMOs and Medicare will use/abuse CCHIT. It is amazing that CCHIT has continued to evolve to this stage. The vendors that have decided to go with this albatross will eventually realize how bad it is, but it may be too late to have the EMR industry and medical practice in general rebound.

Lowell- can you discuss CCHIT with the AAFP? It would be nice to see how they see the gouging fee structure as it stands now.

Brendon- are you still enamoured with the CCHIT process?

Naveen, thanks for the post.

Al

 

I was that other EMRUpdate compadre at the show.

I will give my 1000 post on this very important subject and hope to clarify some of the issues as this town hall will hopefully prove effective in the future development of the cost structure of CCHIT.

Pricing:

1.  24K for Certificatoin 4.5K for Use of Certification for the year in question.  I.E. 2006 Certified.

They did discontinue the concept of a % of revenue as Mark noted as it was met with very bad response even from the early participants.

2.  Year 2 - 4.5K if you wish to simply use the 2006 Certification.  28.5K if you want a new 2006 Certification.  This was a subject that I was very adament about with Mark on and as a result reporters have quoted me on the subject.  I spent with Naveen really good arguments on this point even though our views are not exactly the same on this but very similar.

Mark noted that they were going to look into a different fee structure whereby they could only test on the 2007 Items if the vendor was already certified in 2006.  To be specific only test on say 15 items instead of 300+ once again from scratch.

3.  Year 3 - Same as year 2

4.  Year 4 - Alledgedly will require recertification.  But this is far in the future and I am not willing to bet this will be the end result as many changes in funding of CCHIT and other issues could take place as the new organization grows. 

Note:  Year 4 would only occur after the final certification has taken place, i.e. Year 2 would be good till year 5.

I agree with the recertificaton process but hope for reform on the pricing structure.  Also, I see Mark's direction in regard to limiting it to new features at least for a few years a more reasonable approach.  I recommended this in the town meeting and he seemed receptive of this concept.  I was a bit surprised to see it did not work in this way.

Special Note of Interest that I agree with.

MGMA and Mark Leavitt stated:  I would be weary of the financial wherewithal of a company that has difficulty with paying $28,000 a year for certification.

Allbeit I disagree that I should give them my hard earned money this is a substantial argument given the large number of failed companies with limited financial resources that leave physicians hanging.  Naveen used the old Jewish argument that has stood the test of time, it is my $10,000 or yours I would prefer to it be mine.  It is a great point, but at the same time from the same group of arguments comes You have to pay the fiddler.

Pass/Fail and Testing Process:

Extreme and left vague as metioned by Naveen.  It has no good plan for failure in the case of cost and if you invest this much in certification the industry norm is to help that company in any way to meet certification.  This did not seem to be the objective in this case.

Interoperability:

This was my pet peave in the industry and is a core objective of CCHIT.  Mark and I had a serious debate on this for over 15 minutes.  My point is simple.  The healtchare does not suffer from a standardization issue on this, but more a inability to include this functionality in the product.  I suggested a HL7 Mapper and CCR be a core requirement in this certification and that it be required to be provided for free in the products to meet the governments and CCHIT objective of better healthcare via outcomes and certification that ends in interoperability.

Truth be told the problem with interoperability is not technical, mappers are easy to make, the problem is not cost, mappers are not expensive to develop.  The problem is that it is a great revenue stream with interfaces charged over and over again even with two systems that are already interfaced. This practice has to stop for healthcare to reach its objective. 

Mark Leavitt and CCHIT is in a unique position to require this and the big vendors and small vendors would begrudgingly get rid of this revenue stream to get certification. 

If he could solve this delima I would gladly pay him $50,000 a year as a leading cause of business loss is the cost just interface another product that prohibits the deal from going forward.  In addition the benefit to the healthcare IT industry and healtcare community would far outweigh anything else CCHIT could accomplish.

One thing is for sure, this CCHIT is not going to guarantee the Doctor of a successful EMR purchase or protect them against a failed investment.  The physician/consumer will at least know that it meets a core set of requirements.

I am in favor of this and alternative certification processes if they can give the end consumer a laundry list of expected feature/functions.  I am sure the AAFP and AMA would back such certification if it was truly a properly managed certification, objective in nature, and provided all of the feature/functions looked for by the CCHIT.  AAFP and AMA are not in the business of working for CCHIT, they work for there members.

Sincerely,

Brendon

 

 

Congratulations to Brendon. A worthy topic for your celebreated 1,000 post. Your Presidents badge is just being printed now and will be up in a jiffy.

On to the point of this thread!!
So, shall we stop *** footing around and take some action? (*** cute name for a kitten)

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"CCHIT with emrupdate.com"

If you are an EMR Vendor providing EMR applications and services to Doctors in the USA you're probably worried about the certain high cost of yearly CCHIT Certification and re-certification for every update you release through any calendar year. Your year-1 CCHIT Certification costs are likely to exceed $28,000 with $4,800 each subsequent year, or another $28,000 if you really want a CCHIT Certified 2007 sticker.

emrupdate.com offer our EMR Vendor members CCHIT Certification at realistic non-profit rates:

1. EMR products (1 Doctor, 2 Assists) with purchase cost higher than $10,000.00 (excluding maintenance) CCHIT Certification by emrupdate.com costs $700.00
2. EMR products with purchase cost between $1.00 and $9,999,99 CCHIT Certification by emrupdate.com cost $450.00
3. emrupdate.com will maintain a public register and database of each certification and the date of certification.
4. Re-certification is at the same price as initial certification.
5. Free EMR products (including s/w maintenance) free certification.

"CCHIT Certication with emrupdate.com" utilizes the identical scripts, tests and measurements required by the CCHIT organization providing your customers with the guarantee of CCHIT compliance without increasing your product price to fund another government agency.

emrupdate.com operates its CCHIT Certification process as a not-for-profit operation. Our fee structure allows us to offer certification to large and small EMR vendors while providing free certification for genuinely free EMR products. This is an important service for all vendors ensuring the continued innovation of all types of EMR product in our market.

Our CCHIT Certification process will pay established and recognized (emrupdate.com selected) Doctors a consultation fee to cover time and expenses in performing EMR Certification. Each Certification is conducted by two Doctors who's finding are presented to emrupdate.com for approval and CCHIT Certificate Issue.

emrupdate.com

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I'm sure there is plenty more detail required, but I do have a serious point to make. We have a sufficient body of qualified, altruistic and experienced Doctors and Industry Professionals to be able to offer a truly customer-valued "CCHIT Certification by emrupdate.com". This could really work if we want it to.

Nick.

There are some things that should be learned from other parts of the world.

Ontario, in Canada, wanted to have "certified" EMRs - they set up a "standards" document - and even said all EMRs that want to sell to some government clinics had to be certified. The EMR vendors had to pay for testing (total cost about $10,000)

Basically, most vendors ignored the ceritification, those that did built to the "standard" instead of meeting market niches.

The result, only about 10 vendors bothered with the process, doctors waited for EMRs to be "certified", after waiting they demoed them and most decided the non-certified were better. Only one or two government clinics use a "certified" solution - most of the docs said "I'm not using this"

All this did was delay adoption, confuse the issue, stunt innovation and waste money. No one cares now whether an EMR is certified in Ontario. So there are a lot of government people getting paid for "busy work"

This has been the example and result in many other jurisdictions. You would think at least a little research would be done to see how viable this initiative would be.

My advice: ignore this - only vendors without direction and who need something to hang their hat on will bite, the rest of us will keep building and tweaking to meet the demands of the marketplace and needs of doctors.

Certification is not going to make doctors buy crap! Forcing doctors to buy EMR certified crap will result in the revolution being fought all over from within.

Nick Harrington:

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"CCHIT with emrupdate.com"

Nick.

Nick:

CCHIT (and by the way, they want you to say C-C-H-I-T instead of C-Chit - kinda touchy about that, I wonder why ) is going to 'Branded' and they will not allow anyone to use that word unless they are certified.  And I am sure their work products are also copyrighted.  So we will have to have a different name and develop our own 'core' requirements.  This should not be that difficult, but again, let us make sure that we do this in stages and not say 'All EMR's have to be DOQ-IT compatible on day one'.

Again, this has to be a collaborative, inclusive process with a gradual ramp-up of requirements.  Let us not repeat the mistakes that CCHIT did.

It would be good for emrupdate to spearhead a certification intiative but there are a few details that should be done in a certification process that not even CCHIT is doing.

The big one is software stability. Medscribbler and others that are in the Microsoft Tablet catalog have been tested for stability and good operating system practices. This is done by Quality Logic.

Any certification should include not just features but does it install correctly without harming the operating system and does it also uninstall by removing itself correctly?

Quality Logic charges about $500 for this. This is a bargain because they have the variuos tools and various hardware to make sure the software will not crash your system or cause other havoc.

In Alberta they wrote specs for certification that included networkable but did not include any stability criteria - as a result clinics with over 8 doctors are trying to make EMRs written in VB and using Access DB work - NOT.

A lot of Alberta docs have also given up on their "certified" government financial assistance EMR.

Medicine is too dynamic and detailed "standards" too slow to write for the two to meet successfully.

CEOMike,

That is the goal-- stunt innovation and certainly prevent niche market EMRs.  You reviewed the standards-- every EMR must be pediatric and OB-GYN capable, for example. Obviously, that is not what every specialist needs.

Good input Naveen.

Mike, thanks for a very good observation which should apply to more software, while perhaps allowing the smaller but no less effective MS-Access EMRs certification with the right operating caveats. Caveats is the wrong word, more sense using "certified use".

I am serious and committed in offering emrupdate.com to lead a real-world certification initiative.

Three, Four and Five letter acronyms can become a debate in themselves.

Al Borges' excellent start with SHOVEL (Software for Healthcare Organizations EMR Voluntary Legitimacy) didn't quite trip off the tongue - no disrespect intended - but I think the description was coined to match the acronym, not vice versa.

I of course accept that we cannot trade-upon their "CCHIT" but suggest we're good and safe with eCHIT meaning emrupdate Certification for Healthcare Information Technology. I think it important that we do set out our Certification Program as competitive and alternate to the CCHIT 'certificate'.

Moreover I expect our debate about eCHIT Certification will prove more relevant, respected and reliable than those boys up in Washington.

What do we do collectively next?
What do I do next?
Can I request a "working party" to contribute some groundrules, start the functional discussions, comment on process and charges?
Shall I create a new... wait for it ... "forum section" called "eCHIT" or "SHOVEL"?

Heated debate...

Some vendors call testing fees unfair (copied from Healthcare IT News)

(BALTIMORE) Testing fees for certification of healthcare IT products are too high and could drive small electronic health records vendors out of business, several audience members said Tuesday at a Certification Commission for Health Information Technology town hall meeting.

The meeting, held during the Toward the Electronic Patient Record conference, turned contentious at times, with some audience members saying the $28,000 certification fee was a de facto mandate.

CCHIT Chair Mark Leavitt reminded the group that certification of EHRs is voluntary. However, several vendors and audience members said that they would lose market share if they weren’t certified.

“It’s about as voluntary as income taxes,” said William Sivill of Seiei LLC, a consultant for smaller vendors.

Sivill predicted that if the government tied Stark exceptions to certification, it would in effect become federal law. The federal government this summer is expected to release exceptions to Stark and anti-kickback rules that would allow hospitals and others to share IT tools with physicians as long as the products meet certain standards.

“You are the tail wagging the dog,” Sivill said of CCHIT.

Leavitt called earlier proposals to make the certification fee based on a sliding scale according to vendor revenue a “nightmare” that was quickly shot down by the healthcare IT vendor community.

A few participants said vendors would pass certification costs along to their customers. “We’re gonna raise our prices,” one audience member shouted.

Leavitt maintained that the $28,000 certification fee is less than the cost to physicians and the larger healthcare system of faulty EMR products.

“It’s known to destroy practices (if an EMR system fails),” Leavitt said.

Robert Tennant, senior policy advisory for health informatics to the Medical Group Management Association and a member of the CCHIT certification process workgroup, said while the testing fee may seem excessive, it would only take one additional sale to one physician group for vendors to recoup the investment. The MGMA plans to urge its members to only select EHR products that have been certified, he said.

Other audience members, including Joe Byers, vice president of sales and marketing for DSS Inc., suggested that all stakeholders, including payers and employers, should pay certification-testing fees. DSS provides services for the department of Veterans Affairs’ EMR system for its beneficiaries.

Leavitt said CCHIT would continue to seek the right balance in the coming years for who pays what for certification. He said the group, which holds a federal contract to certify healthcare IT products and the networks that connect them, was in talks with employers about pitching in to pay for tests. Leavitt said he did not know whether certification fees in subsequent years would go up, down or stay the same.

“We’re ready to let the market sort it out,” he said.

Meanwhile, at least two dozen vendors have applied for certification of ambulatory EHR products. The inspection process is now under way. CCHIT plans to announce which products are certified by mid-July.

Nick Harrington:

emrupdate.com offer our EMR Vendor members CCHIT Certification at realistic non-profit rates:

1. EMR products (1 Doctor, 2 Assists) with purchase cost higher than $10,000.00 (excluding maintenance) CCHIT Certification by emrupdate.com costs $700.00
2. EMR products with purchase cost between $1.00 and $9,999,99 CCHIT Certification by emrupdate.com cost $450.00
3. emrupdate.com will maintain a public register and database of each certification and the date of certification.
4. Re-certification is at the same price as initial certification.
5. Free EMR products (including s/w maintenance) free certification.

Nick,

The abletFactory, would in principle, be willing to sign-up as a Category #2 participant for the EMRUpdate Certification alternative.

Without reviewing the certification requirements it may be premature, but by following the general discussions and given the intent of the participants on this forum, your described process at least passes the "smell test".  And I do think providing an alternative to CCHIT cert will prove to be valuable to both vendors and consumers. 

Providing a general outline of the requirements would be a great first-step. I'd be willing to participate, and volunteer as sub-chairmain on working with the "inking" requirements.  

Fritz

ps -  Congrats Brendon on Post 1K.

 

 

 

Remember the dream I had ?

http://www.emrupdate.com/forums/thread/46942.aspx

 

Roger gave a great interpretation...

Is there anyone who would like to interpret my dream?  

Maybe I should take a shot at this. My credibility? First, I dreamt of the exact age my grandfather would die.  A year before he died, Second, I dreamt of my dog " src="/emoticons/emotion-54.gif">drowning in front of me and despite my attempts to pull her up she refused to staring at me as if to say this is where I should be. She died of ALL is 2 months" src="/emoticons/emotion-9.gif">. " src="/emoticons/emotion-6.gif">. Weird huh!

1) We're all enjoying and celebrating on the same trail. 

The status quo. We do not want to think outside of the box. Why bother thinking of our worries.

2) What is the dinosaur?

The Dinosaur in your dream represents a powerful entity. In our case Government, Regulators, Insurances, i.e. 3rd party payors that can decide our individual faith. Well maybe CCHIT. Somebody that can compromise our original intent to become a Physician. Somebody " src="/emoticons/emotion-14.gif">that is devouring us quickly!" src="/emoticons/emotion-12.gif">

 

May also represent inability to look back on past mistakes to correct the future. As the saying goes, History repeat itself. We were unprepared in that dream. Hiding behind a Tarp? Why not in a cave like our Ancestors did? Why did we not try to use force in that dream? Would "closing our eyes" make the problme go away? Or we close our eyes to what is obviously wrong!

3) How accepting are we of new alien ideas that come from out of nowhere ?

What strucks me in that dream, was the Sky was clear. It is obvious - Al and Praxis were the Aliens! Fear them not. ROFL. " src="/emoticons/emotion-2.gif">" src="/emoticons/emotion-10.gif">.

The sky is clear, EMR's have to be the answer. Patients have to fill out their histories. As Physician shortage is in the horizon.

4) WE ALL STOOK TOGETHER

Well that is how we should. Working together. But unfortunately each one have their own agenda. The Proprietary nature of EMR's make me wonder if there truly is a benevolent one where money is no object.

However I also wonder if all these Dinosaurs would disappear and cause us no fear just like in the dream if we can foresee the future by basing it on a benevolent goal.

Did the best Inventors and Innovators thought of money and power first before they came up with their important inventions? Did Bill Gates et. al. foresee domination and control  first or started with a true bonafide desire to make life easier?

 

Roger T,

 

Leavitt maintained that the $28,000 certification fee is less than the cost to physicians and the larger healthcare system of faulty EMR products.

“It’s known to destroy practices (if an EMR system fails),” Leavitt said.

Interesting statement by Leavitt-- he is insinuating that should a vendor pony up the 28K, that vendor will be vaccinated against failed implementations.  Yea, sure. 

Certification only certifies features, not usability. Lack of usability leads to failed implementations.   High costs that bankrupt a practice leads to destroyed practices.  You've heard of several here on EMRUpdate. Furthermore, several practices using NextGen had enough with high costs and hobbled usability, so they installed MedtuityEMR.  I am sure NextGen will be certifiable by C-CHIT.  Does that really guarantee usability?

C-CHIT is not some altruistic organization looking to better the practice of medicine. It's all about the money.

And by the way, we have employees who are far more deserving of a 28K bonus than C-CHIT.

 

You have to register at Modern Healthcare for this story about Leavitt taking a verbal pounding from the likes of Brendon Holt at TEPR.

GUYS & GALS - hit the next page for Nick's response (please)

http://www.modernhealthcare.com/article.cms?articleId=39980