Proposal: Why not challenge CCHIT with an alternative certification?

Exerpts from another CCHIT post:

Terry >>> "Guys, I don't mind standards. I appreciate the need to work together. However, I am against more government (or private) interference in my life. I pay enough taxes to choke a dang goat as it is."

Brendon >>> "In several years this will change, like all initial RFP's. It looks like the QIO imitative and P4P may be more viable with CCR in the short term. Maybe we should focus more on these and see how the whole CCHIT thing shakes out."

Naveen >>> "We are prepared to do this, if this initiative really takes off. However, I don't think we are going to lead the charge on this one."

Lowell >>> "There is widespread concern that the CCHIT certification requirements is presently too onerous."

David >>> "The big company name is a false sense of security. CCHIT certification is a false sense of security. One can argue that these things help - and they probably do, but CCR is where the action really is (and should be)."

Hi guys/gals:

      I feel your pain, depression, and anxiety over this issue. There seems to be a lot of pessimism, frustration, and overall feeling of being railroaded by this private initiative funded by big government. Now is not a time for apathy, though. Some may opt to simply ignore it, others will follow along like castrated pigs, but nobody has yet proposed any alternatives to CCHIT- until now.

      I suggest that we seriously entertain the possibility of using an international forum like emrupdate.com that is focused on EMRs, that is visited by hundreds of dedicated brilliant yet diverse minds daily, and that has almost 5000 registered users as a possible staging area for a CCHIT certification alternative to be used by small to medium sized EMR vendors interested in keeping their EMRs affordable. I would suggest a simple pathway for "certification" that would encompass possibly a dozen areas which should be integral aspects of a typical EMR for this setting, but with a focus on interoperability (think "CCR" and other things like "ODBC" links). The certification should be easy, and the cost should be a small annual pittance of a fee, say $300 (vs. $30000.00 + royalties "cc" ["CCHIT charge"]). This forum, of course, would have to yield at least 20, and preferably 30 or more leaders in the EMR arena to come together to form these standards, half of which would represent small to medium sized EMR vendors. This certification could be used by these vendors in lieu of the onerous, costly CCHIT initiative certification. At the very minimum, such an initiative will bring about competition in the certification arena and force CCHIT to take a second look at how they do things. I personally would expect such a group to run CCHIT into the ground.

      I would first like to get feedback on this idea (crazy vs. brilliant, or anywhere in between), and later I would like Lowell to run one of his famous polls if there is enough interest. Write away, folks. This may be your only chance.

      BTW, I would like to call it the "ERCSMO" (The EMR Certification Group for Small to Medium Sized Offices). Other naming ideas would be appreciated.

Cheers,

Al

Al, actually I like the idea.   Standards have to start by being inclusive and gradually evolve to something stronger.  I can not buy into the CCHIT philosophy of making this an arbitrary hurdle with no clear rationale behind it (other than to try and bury a lot of the smaller players).  Make no mistake, even though the actual CCHIT fee and the associated effort are not insurmountable for us, our prices will go up a bit if we end up toeing the CCHIT line.  Our program will also possibly be less intuitive trying to follow the 'only our thinking is right' CCHIT logic.  Neither of this is going to add anything positive to the end user experience.

I realize the term 'physician advocate' gets bandied about mercilessly with little regard to the implications.  Personally, I have striven to be one and I honestly believe that CCHIT certifications will make things worse, not better.

If a group of vendors, say 20-30 as you say, can come up and meet an alternative standard that is validated by the physician users on this forum, this will pose a legitimate challenge to CCHIT to rethink their direction.

Lead the way Al, I will help in any way possible.

>>>>>>  Al writes:

I agree with David that the only real focus now should be interoperability and in that realm, the CCR initiative should be the "holy grail" which in itself still will be difficult to achieve.

<<<<<<

Actually, 98% of the effort would most likely be devoted to interoperability and CCR, but in order to compete with CCHIT, we would need to add a few obvious things to the list, but would keep the list short. Heck, even God kept his list to 10 Commnadments, no?

Al

 

Go for it, tech dudes, developers, and vendors.
Anything to keep small, nimble products in the game sounds good to me. I definitely agree that standardization and inter-operability should be a priority for a good EMR, and that somewhat knowledgeable purchasers will probably be looking for that.....
...Our EMR is "CCR compatible" or "ERCSMO certified" ... will be one factor to use to weed out products that you do or don't want to look at. (I will be pushing our selection process to only consider products that are, or that have on ongoing plan, to be CCR compatible).
I think that most docs will want look at products that have passed some kind of litmus test, that have stood up to some kind of scrutiny, and why not start looking at ones on the "CCR list", for example.

If the CCHIT cert process looks too onerous (the Microsoft of certification), then give us the alternative, user-friendly "Mac"  ERCSMO certification.

alborg:

      BTW, I would like to call it the "ERCSMO" (The EMR Certification Group for Small to Medium Sized Offices). Other naming ideas would be appreciated.

Hi Al,

How about calling it "SHOVEL" (Software for Healthcare Organizations EMR Voluntary Ligitamacy). If anything, just think of the fun we can have with SHOVEL and CCHIT mentioned in the same sentence :)

Al,

Super idea. We are a much larger and older organization than CCHIT. Our recommendation should mean a great deal more than a big-money payoff and a percentage of the take. (I have never heard of a certification that demands a percentage of the take. Well, I have, but it was in an episode of "The Bowry Boys").

We all want certification that means something to the individual doctor. Here are a few examples, lifted from another post. (We have a few going on CCHIT right now.) Isn't this more what we all had in mind?

1. Stop criminals from stealing millions of dollars from well-meaning doctors by marketing non-existent products or features and/or building locks and traps into the product which would make a doctor depend on a vendor to get his own medical data.

2. Test the products independently--not self-tested as called for by CCHIT--for running speed and reliability. Does the software even work outside of the laboratory?

3. Certify for interoperability.

4. Confirm by actuall user interviews that a customer service entity is actively supporting the EMR product, and define exactly the terms and availability of that service.

5. Certify all lab interfaces promised or advertised by the vendor to assure that this and all other parts of the EMR system are represented accurately.  

6. Certify financial responsibility and exit strategy to make sure that no user will ever be at risk of losing his medical data due to lack of same.

7. To verify that EMR pricing is truthfully represented, eliminating the element of surprise in delivery of purchased goods and services.

What can you add to or subtract from this list? I don't think we need any tax money to do what comes so naturally for us. We don't want anyone to own us.

>>> How about calling it "SHOVEL" (Software for Healthcare Organizations EMR Voluntary Ligitamacy). If anything, just think of the fun we can have with SHOVEL and CCHIT mentioned in the same sentence :)

Oh that sounds great! I had thought of "Federation Userbase for Certification Umbrella" ("FUC-U"), but "SHOVEL" seems more appropriate. It'll be interesting if we can get over 40 vendors to unite in this process... the needed critical mass, since CCHIT now seems to have 40 mostly high-priced vendors "signed up" according to their website.

The CCHIT initiative reminds me of the tax on yachts that was levied by the Democrats in the 1980's with the proposed thinking that the rich would be taxed via their "toys". The result was that the yacht industry disappeared in the USA. I wonder how far-reaching consequences this certification "tax" will have on the EMR industry as a whole, in which many EMRs really do thrive on shoe-string budgets.

I'll eventually transfer this thread to my BLOG... I gotta ask Nick how to do it.

Cheers,

Al

I could agree with this to a degree.  I believe the CCHIT initiative at 300 core features is ridiculous.  On the same note, how would we determine a basic list that would protect the Physician?  Who would determine this?

I like the CCR idea as a start, but there is so much that is needed.   For instance it should at least capture enough data to allow for P4P.  It should have Sript Writing.  It should allow for research on ICD9 codes.

I could go on and on. 

You get the point.

Brendon:

I could agree with this to a degree.  I believe the CCHIT initiative at 300 core features is ridiculous.  On the same note, how would we determine a basic list that would protect the Physician?  Who would determine this?

I like the CCR idea as a start, but there is so much that is needed.   For instance it should at least capture enough data to allow for P4P.  It should have Sript Writing.  It should allow for research on ICD9 codes.

I could go on and on. 

You get the point.

Actually we (the forum) are uniquely situated to do this the right way.  Let us come up with an excel spreadsheet of basic features and host it on a blog.  We can have the vendors here and users comment on it.  If any feature is contentious, we use the convenient 'poll' feature where all registered (with possibly member id verified to prevent ballot stuffing ) members may vote.  That should settle any disagreements.

Let us first agree that about initial # of core features is a good number to shoot for for the first cut.  We can have one of the moderators post this on a poll the options 50, 100, 150, 200.  Let us see where that lands us first.  We will go from there.

Any thoughts?

Naveen,

I agree that it would be the responsible thing to do-- this community of users and vendors decide on a list of those important features when choosing an EMR.

Brendon, though you expressed willingness to particiapate in CCHIT testing, your solution could be one of the first to bite the dust.  Just read the test scripts.  You've got to build a traditional EMR to pass.

Next on the list are the specialty EMRs followed by open source-- who's going to pay them to do busy work for the next year when it will do little to satisfy their users needs? Stop working on CCR because it's not needed to pass. Drop document management. Drop any sophisticated mechanisms for collecting information rapidly because we must all step back a few years in technology. Take out the fingerprint sensor because there is actually a test for password strength. The list goes on....

 

How about a set of features that are classified according to need (desirable, essential etc), and vendors/writers can then say their software implements how much of each set.

This means that the user can see if the vendor in question meets their required dataset or not, without imposing the burden of having to do all of it.

S.O.S ( Simplified interOperablity Standard )

 

The excel spradsheet is an excellent idea- many thanks for your excellent posts.

Idea - one of the first things that we can do as a group is to forward a letter to CCHIT with our suggestions, complaints, and concerns about the things upsetting to so many of the members in the community similar to the one sent in by EMRVA at http://www.himssehrva.org/docs/CCHIT_doc_Phase1.pdf#search='CCHIT' .

The CCHIT comment period ends on 3/31/2006 (see http://www.cchit.org/publiccomment4.htm ). This way we voice or issues and give them a chance to respond. They will most likely blow us off, but it'll be our first action as a emrupdate.com EMR group. I'll put it together in the next few days and then allow for you guys to edit it, sign it, and then send it off.

Cheers,

Al

I agree with the group that an alternative "certification" for the small EMR vendor (ie one that markets an affordable system for the small practice) for the reasons stated in the previous posts and threads.

I am always amazed how acronyms in medicine have always been misleading. As we all know "WNL" is supposed to mean "Within Normal Limits", while in reality it too often means "We Never Looked".

The acronym for Certification Commission for Healthcare Information Technology is "CCHIT."  Didn't this austere and well funded organization ever consider the repercussions of this acronym on their credibility. Even for the physician for whom price is no object, purchasing a EMR that is"CCHIT" certified has got to cause second thoughts. (Calls to mind the old Abbott and Costello "Who's On First routine, as in "What is CCHIT?".....)

For this reason I suggest we forget acronyms (Like SHOVEL and CCHIT) and any vendor that adheres to the guidelines that we establish become "Certified by Emrupdate.com" and can feature a logo on his website. After all this site is where most MDs look for suggestions re: EMRs.

- Andy  (No CCHIT) Schuman, M.D.
________________
Andrew Schuman, M.D.
Developer, the "Practical Medical Record"
Electronic Pediatrician LLC
www.electronicpediatrician.com

Actually, our workgroup (yes, I am partially responsible for all this CCHIT) gets to tackle the functionality public opinion comments.  What has happened in this process is that each special interest group (LeapFrog, for example) voices their must have list of features.  Each comment is taken very seriously - maybe too seriously.  These requests get into the queue and just get added to a list that has become ridicuously large.  The more opinions, the more the 'minimum' functionality list grows.  I have been a hold out for fewer features to avoid stifling innovation and to keep costs under control.  Ironically, physicians have probably been the most vocal about "must have" features.  As one might predict, anything done by committee and consensus (like HL7) becomes a giant compromise - a beast that serves no master. 

There are numerous unanswered questions still.  How does a specialty EHR (that lacks certain features by design) pass CCHIT certification?  What happens if you pass on 299/300 criteria?  Answer: You fail CCHIT certification.  What is the appeal process?    If you as a vendor fail CCHIT certification, it will create doubt.  Why didn't you pass?  Will this be the nail in the coffin?  Isn't a CCHIT certified EHR a safer place to park our money in the long run?  Who are the judges and are they really unbiased?  If there are any HL7 members as judges, we are probably in deep CCHIT since I have publicly emasculated HL7. 

CCHIT will matter most to large medical groups who seem to always get 'consulted' into buying the most expensive EHR.  Docs that do not hang out here or do not do any reseach probably won't give a flip. You will have one hell of a time explaining failed CCHIT certification to the marketplace - and CCHIT certified EHRs will use this to scare off customers from their non-CCHIT certified competitors.  The sad thing is that a Mysis will probably CCHIT certify even though in the world of public opinion, they generally come in last - at least according to the survey of FPs published in October 2005 and consensus opinion here.  The goal of CCHIT is noble, but I fear the giant compromise inherent to committee design has undermined it.  Let the market decide what is best.  Darwin or intelligent design....