Response to "CCHIT: the 800-Pound Gorilla"

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alborg Posted: 08-28-2008 3:47 AM

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The following was posted at http://histalk2.com/2008/08/27/readers-write-82708/ in response to the thread called "CCHIT: the 800-Pound Gorilla", where a number of incorrect statements on CCHIT were made:

Dear Art:

Like anything else in this world, there will always be believers of entities which are just plain wrong.

>>> I have found it to be an extremely transparent organization

CCHIT was established by software vendors FOR software vendors and it is anything but transparent, especially after I began highlighting the fact that this not-for-profit's incorporation papers stated that at the end of the year all profits would be given to those "big boy" EMR vendors that incorporated this entity. Later, in their 8/2006 minutes they were predicting a million dollar profit for the first 6 months of 2006. After 8/2006 all posting of minutes were stopped and when resumed on 11/2006 they were concise and scrubbed, without any detail, and continue as such to the day. On 12/2006 they reincorporated CCHIT.

URL where you can download these now hidden public documents: http://www.msofficeemrproject.com/Page3.htm

CCHIT is simply not necessary. I remember those times when in CMS had the "National Standard Format" for billing. All a vendor had to do to make it into the "gold list" of vendors was to call CMS and run a test to see if their software could communicate with the CMS servers. That was it- there was no cost, and the process was easy.

Now, to get the 1st year CCHIT certification it used to cost a total of $28000.00 with a cost of $4000 to keep the certification active on years 2 and 3; in many situations, s.a. to work in a Stark-relaxation-kickback environment the vendor has to recertify yearly at $28000.00 a year. For 2008, the application cost for CCHIT is now $29,000 application plus $6,000 for maintenance for a grand total of $35,000.  (http://www.emrupdate.com/forums/p/14875/84917.aspx#84917) This cost is simply outrageous and an unnecessary burden for both vendor and for the physician purchasers.

>>> I remember all too well when there were NO STANDARDS.

You haven’t done your homework- there have been numerous "standards" that have been forwarded over the years, all of which have failed to be universally accepted. Some of these “standards” date back more than twenty years. The number of these organizations and the failure of every single one of them to become the recognized standard attest to the reality that no electronic standard is possible in a dynamic and innovative field like medicine. Some of these organizations have sued other organizations, some of these standards have multiple variations of the same standard, there are many competing standards in the same discipline:

·        ASTM International Continuity of Care Record - a patient health summary standard based upon XM.

·        ANSI X12 (EDI) - A set of transaction protocols used for transmitting virtually any aspect of patient data. Has become popular in the United States for transmitting billing information, because several of the transactions became required by the Health Insurance Portability and Accountability Act (HIPAA) for transmitting data to Medicare.

·        CEN - CONTSYS (EN 13940), a system of concepts to support continuity of care.

·        CEN - EHRcom (EN 13606), the European standard for EHR systems.

·        CEN - HISA (EN 12967), a services standard for inter-system communication

·        DICOM - for representing and communicating radiology images and reporting

·        HL7 - HL7 messages are used for interchange between electronic systems and devices. There are two different versions in use.

·        ISO - ISO TC 215 has defined the EHR, and also produced a technical specification ISO 18308 describing the requirements for EHR Architectures.

·        openEHR - public specifications based on a complete separation of software and clinical models.

·        Current Procedural Terminology (CPT): A classification system for coding ambulatory care.

·        ELINCS - EHR-Lab Interoperability and Connectivity Standards: An standard for reporting laboratory test

·        IEEE 1073 - Institute of Electrical and Electronics Engineers: The 1073 standard is used for integrating a medical device to a clinical information system

·        ICD-9 - International Classification of Diseases: is used for diagnosis and procedure coding; many are pushing for adoption of ICD-10 (a good example of the need for verbosity to determine a common medical knowledge set)

·        LOINC - Logical Observation Identifiers, Names and Codes: A code set covering laboratory tests

·        Medcin - A terminology for clinical care.

·        SNOMED International - A terminology for clinical care.

·        NCPDP - National Council for Prescription Drug Programs: A suite of standards governing prescription transactions.

·        NDC – Federal drug agency standard drug identification system

·        Multum - standard drug identification system.

(list from: http://www.emrupdate.com/forums/p/8530/63273.aspx#63273)

Sure, CCHIT is now “THE” recognized standard, but only by political decree by HHS Leavitt. I hope that one day we can add CCHIT to this list…

>>> I remember physicians being completely at the mercy of salesmen with slick demos…

And you feel that CCHIT will change this? Although CCHIT promises “assurance”, they do not certify usability, they do not certify customer support, they do not promise increased income, and they do not certify that a vendor is financially sound. They have yet to standardize interoperability, although they continue to promise to do so. Finally, they will not change the character and integrity of a vendor and its salespeople.

>>> I have found it to be an extremely transparent organization that is helping level the playing field and make it safer for clinicians to take the plunge into electronic records.

Above, I have noted how not-so-transparent CCHIT is nowadays. How do you find it safer for clinicians? CCHIT certification essentially means that the EMR will cost on average twice as much. At www.emrupdate.com we have a listing of EMR systems and their associated costs for a 2-member group practice. All the CCHIT certified EMRs cost over $31000.00 while non-CCHIT certified EMRs average about $17000.00 (check out “What is Wrong With HIT in the USA?”, slide 44, here- http://www.msofficeemrproject.com/Page3.htm). This means that CCHIT will force clinicians to put more money at risk, with the odds against them of getting a decent return on their investments (“ROI”).

>>> The CCHIT is here and is becoming ingrained in the road that lies before us

Nobody will really know what is destined for the future. What we do know is that: physicians are NOT endorsing CCHIT. If you look at the 10/31/2007 Biennial CDC report, the uptake of “any EMR” has increased to a statistically significant 29% level. Unfortunately, the 2 year growth of CCHIT-certified EHR growth rate is up to a 12.4% level, up from 9.3% in their last study, a level which is NOT statistically significant. Unless physicians come on board with this, CCHIT is going to be a dead end. Go to any physician-only site, s.a. www.sermo.com or www.docsboard.com, and you will see the anger and negativity towards CCHIT first-hand.

>>> Only the giant dinosaurs will be left the divide up the swamp once the blood bath is over. We are doomed, the sky is falling, and the Mayan prophecies of the end of the world are coming true.

Ok- don’t just look at the fact that CCHIT-EHRs are twice as expensive. Look at other data, published in a document downloaded from CCHIT called “EHR Certification has Strong Acceptance in the Marketplace”: “…43 percent reported annual revenues greater than $10 million…” (URL: http://www.cchit.org/about/news/releases/2008/EHR-Certification-Strong-Acceptance-Marketplace.asp)

 Although I disagree with you, thank you for bringing up CCHIT so that we can clear the air.

Sincerely,

Al Borges MD

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CEOMike replied on 08-28-2008 2:09 PM

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Thanks for sourcing me doc, I go away for a while and still I am able to make a contribution.

Thanks for the original CCHIT incorporation docs, I tried to find these a while back on the original web sites and they had been scrubbed cleaner than the age of a Chinese gymnast

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alborg replied on 08-28-2008 4:10 PM

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>>> CCHIT incorporation docs

They were transparent enough that I realized that they would pull them from public view eventually, since at the least they are embarrassing, at the most, make their not-for-profit illegal.

Emrupdate is a treasure trove of information, and I remembered your post from way back. It was really well done; unfortunately, there are so many posts that it took me an hour to find it!!! BTW, I added this list to the latest version of the "What is Wrong with HIT in the USA?" slideshow. URL: http://www.msofficeemrproject.com/Page3.htm or http://www.box.net/shared/static/zl6r1owwgk.ppt .

URL for all the anti-CCHIT postings to the original article: http://histalk2.com/2008/08/27/readers-write-82708/#comment-2012