Draft Letter to Dr. Mark Leavitt, MD, Ph.D / Add your signature

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Nick Harrington Huh? [:^)]

Posted: 03-24-2006 6:40 AM

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The following Draft Letter will be finalized early next week, with the addition of any poster name who confirms their inclusion by replying to this post with their Signature. Please restrict replies to this post ONLY to signatures. Any comment about the letter should be made upon a separate thread.

All credit goes to Alberto Borges, MD (alborg) who has drafted this letter.

Dr. Mark Leavitt, MD, Ph.D.

Medical Director and CCHIT Chair HIMSS

18407 NW Keller Road North Plains, OR 97133

March 24, 2006

Dear Dr. Leavitt:

On behalf of the physicians and vendors that participate daily at emrupdate.com we want to thank you and the Certification Commission for Healthcare IT (CCHIT) for providing us the opportunity to offer feedback on the Phase II reports by the CCHIT workgroups and on the CCHIT process in general.

There has been a great deal of discussion concerning the CCHIT initiative at emrupdate.com in various threads throughout the past month and although both sides of this controversial evaluation process are represented, there is an overall general feeling of apprehension, depression, anxiety, and anger over the perception that this process may change the future EMR infrastructure for the worse, with a loss of freedom, a stifling of the growth of EMRs, and the dampening of new initiatives. There is widespread concern that the CCHIT certification requirements is presently too onerous.

Inexpensive EMR companies, non-traditional EMR companies, open-source EMRs and EMRs that are specialty specific may not be able to compete in a market where insurance companies may in the future require a rigid CCHIT certification which includes feature requirements that their respective clients will not need nor will not be willing to pay for.

The large up front $35000.00 fee plus a percent of royalties is perceived to be a large burden that could cause a “weeding out” of the market out of upstart and other smaller EMR companies that can not afford these high royalties without markedly increasing their fee structure, and thus eliminating their advantage over higher priced EMRs.

We would like to suggest the following:

Markedly decrease your up-front fees and eliminate the percent royalties provisions. In most other certification arenas, the cost is usually ranges from about $150-$300 (Verisign-like certificates) to slightly over $1000 (Board certification for physicians). The government should pick up any shortfall in revenue since they stand to gain through future Medicare cost savings.
Eliminate the “all or nothing” certification process. Consider a tiered certification process, s.a. “Gold”, “Silver” and “Bronze”. Alternatively, EMRs can be certified as having certain listed features, s.a. “150/328” features, allowing the buyer to know exactly what they are purchasing. EMRs should be verified that the EMR pricing is truthfully represented, eliminating the element of surprise in delivery of purchased goods and services.
The certification features should be pared down to a dozen of the most important features, especially those features that deal with interoperability and the making of the CCR universal. All other features would be suggested, but optional.
Self-testing should be reassessed. The EMR products should be independently tested for the items that are advertised. Consideration should be made for running speed and reliability. Does the software even work outside of the laboratory?
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.
Vendors should not in any capacity be involved in the certification process as evaluators.
This initiative introduces us to a slippery slope of arbitrary item inclusion, all of which should be removed or made optional. Today, that decision to include peds-specific content effectively removes those EMR's going after internal medicine, geriatric, adult endo, gastro, uro, and other specialty markets.
CCHIT should define criteria for a lab interface so that every EMR did not need a separate interface for every lab vendor. We need to define a set a lab names/codes so that a CBC is a CBC on both coasts and in between.

We hope that the above suggestions are helpful in the forward planning within CCHIT. If you have any questions, please do not hesitate to give any of us a call.

Sincerely,

Alberto Borges, MD

Oncologist

MS Word EMR Project

alborgmd@yahoo.com

Nick Harrington email me or Skype: nickharrington emrupdate.com
If I have seen further it is by standing on the shoulders of Giants" Sir Isaac Newton 1676

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Nick Harrington replied on 03-24-2006 6:42 AM

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Nick Harrington
nharrington@ambay.com
Director / Ambay Software Ltd.
Administrator / emrupdate.com

Nick Harrington email me or Skype: nickharrington emrupdate.com
If I have seen further it is by standing on the shoulders of Giants" Sir Isaac Newton 1676