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Al Borges, M.D.
I have sent my complaint to FTC: the matter is:
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This letter is regarding the fee for CCHIT certification and why it will eliminate the small vendors of EMR- Electronic Medical Records. As I understand it costs an EMR company about $28,000 for 3 yrs and another 9,600 for 2 yrs to maintain the certification process. It costs about $200,000.00 for an EMR company to go through the certification process. These costs will ultimately be borne by public; initially vendors pay, then they pass on to medical practices. Ultimately patients and insurers will pay more, as it will work its way up into payment formulas (as I understand payment formulas are what Government uses to determine the reimbursements to practices). This I believe is rather unnecessary and expensive proposition. Many of the EMRs small practices use cost around $1000 (what we use - Amazing charts cost $995.00 for 1 user- It is a stable and sound product for small practices, the developer Dr. Jon Bertman is a practising family practioner who is constantly making upgrades-http://www.amazingcharts.com). The software developer will have to sell 200 copies of software just to pay for this certification process!.In my opinion it means nothing to have CCHIT Certification in running day to day practice of medicine taking care of patients. Many doctors who bought expensive softwares (read CCHIT certified) feel they are stuck with it, as they have already invested heavily in that software and breakups cause a lot of interference in day to day operations. I also hope CCHIT will not abuse the power it has to twist the arms of Medicare etc., to allow only CCHIT certified products to participate in P4P (Pay for Performance the US government is trying to institute) etc.I request FTC to look into this organization as it threats the small vendors. ________________________________________________________________________
Regards
Great, Joseph! The more FTC complaints they get, the more they will investigate what is going on.
Here is the FTC reply to my letter:
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Subject: Response to your complaint Ref No. 9111192 To: alborgmd@yahoo.com From: COMPLAINT@FTC.GOV Add to Address Book Add Mobile Alert Thank you for visiting the FTC's web page and for using our NEW electronic Talk To Us form. Here's what happened to your information after you sent it to us: One of our consumer counselors reviewed the information you sent us. If it was related to the FTC's law enforcement responsibilities, we entered it into our shared law enforcement data system. We share this data system with law enforcement agencies throughout the United States and Canada. Attached is your electronic response, which includes your reference number. Any enclosures can be found at www.FTC.GOV under the News Releases, Publications, Speeches option. Information from consumers like you helps Federal, State and Local authorities investigate possible illegal practices and enforce our laws. Someone from the Federal Trade Commission or another law enforcement agency may contact you if they need additional information to help them in an investigation. Thank you for using our Talk To Us form, and please continue to use the FTC's web page, www.ftc.gov, to get free information to help you avoid costly consumer problems.
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Got reply from FTC:
Response to your complaint Ref No. 9117754
Thank you for visiting the FTC's web page and for using our NEW electronic Talk To Us form. Here's what happened to your information after you sent it to us: One of our consumer counselors reviewed the information you sent us. If it was related to the FTC's law enforcement responsibilities, we entered it into our shared law enforcement data system. We share this data system with law enforcement agencies throughout the United States and Canada. Attached is your electronic response, which includes your reference number. Any enclosures can be found at www.FTC.GOV under the News Releases, Publications, Speeches option. Information from consumers like you helps Federal, State and Local authorities investigate possible illegal practices and enforce our laws. Someone from the Federal Trade Commission or another law enforcement agency may contact you if they need additional information to help them in an investigation. Thank you for using our Talk To Us form, and please continue to use the FTC's web page, www.ftc.gov, to get free information to help you avoid costly consumer problems.________________________________________________________--
As I recall, the money used by the six large companies to "study the EMR problem" came from the U.S. taxpayers. Their study must have revealed to them the wisdom of forming a monopoly by imposing their own bloated standards on the rest of the EMR vendors.
Just my opinion, but if only these six companies are granted the CCHIT seal of approval, I will smell a rat. Six of them, in fact.
Robert Gleeman, Medical Journalist for EMR Update.com Email: robert@emrupdate.com Tel: 1-650-968-6359 Skype and ooVoo user name: robertgleeman EMR progress is a matter of fact. EMR Update supports your right to know.
I have tried several times to put a complaint in, but the server keeps timing out. Here is my narrative:
The CCHIT organization is generating a set of rules attempting to set standards for electronic medical records(EMR) said to protect practitioners and patients alike. The standards lists are severely bloated and promote undue hardship on smaller EMR startup companies by expanding development tasks above and beyond reasonable operating standards. It raises development costs and its $28,000 examination fee coupled with its annual update fees are especially onerous when it is noted that certification is version specific which will limit upgrades to users. It will also require new application and testing fees for significant version releases to remain certified. These costs are difficult for small businesses to meet and ultimately get passed to the physician and patients. The CCHIT effort, while admirable in intent, will harm small businesses, physicians and patients while only benefitting a small group large EMR development companies. Physicians will be held hostage to high costs because smaller, equally efficient EMR sytems will be driven from the market. These smaller EMR business efforts help keep the physician user cost base down by offering respectable/functional competition to companies who could very well generate a monopoly by diminishing small business development efforts.
R Terry Ellis
DescriptMED, LLC
Get Done, Go Home!
Tour The Chart!
Re: Material to bolster complaint Ref No. 9111192
Also, reference to similar complaint, Ref No. 9117754
Dear Sirs:
Thank you for taking the time to read my complaint. I and others look forward to seeing how things progress. You might wish to combine the complaint No. 9111192 with the complaint No. 9117754 since they both deal with the same CCHIT organization.
You might also wish to see a copy of an article soon to be published at an upcoming Healthcare Informatics Extra electronic newsletter. The title is "Will CCHIT Stifle HIT Competition and Raise EMR Prices?", and its URL is http://www.emrupdate.com/forums/ShowThread.aspx?PostID=56300#56300. This article goes slightly deeper than the brief summaries that have been sent to you, attempts to apply the FTC "Antitrust Primer" and has 2 simple tables to highlight some of the anticompetitive aspects of the current situation with the anticompetitive CCHIT process. I hope that this will help with your efforts.
Sincerely,
Al Borges, MD
Al, I probably should have posted this here, but at any rate here's an article I ran across that I think has some impact on the subject as well. Is Medicare non-compliant?
Barbara Duck Ducknet Services TabletKiosk Sales Information
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Hi Barbara:
If you look at a post that I put up several minutes ago here, you will see that HHS does not officially endorse CCHIT in their most recent Federal Register memorandum, http://www.emrupdate.com/forums/thread/56447.aspx, although they do reserve the right to do so.
It definitely doesn't seem to be HIPAA compliant!
I may be a bit late here to post. Just last night I posed this question to HHS at their website. If more users pose this question may be HHS will put this on their question and answer page.
The link is:
http://answers.hhs.gov/cgi-bin/hhs.cfg/php/enduser/ask.php?p_sid=fkABgAji&p_accessibility=0&p_sp=cF9zcmNoPSZwX3NvcnRfYnk9JnBfZ3JpZHNvcnQ9JnBfcm93X2NudD00MjkmcF9wcm9kcz0mcF9jYXRzPSZwX3B2PSZwX2N2PSZwX3NlYXJjaF90eXBlPWFuc3dlcnMuc2VhcmNoX25sJnBfcGFnZT0x
http://answers.hrsa.gov/cgi-bin/hrsa.cfg/php/enduser/ask.php?p_sid=YyiggAji&p_accessibility=0&p_sp=cF9zcmNoPSZwX3NvcnRfYnk9JnBfZ3JpZHNvcnQ9JnBfcm93X2NudD02MDYmcF9wcm9kcz0mcF9jYXRzPSZwX3B2PSZwX2N2PSZwX3NlYXJjaF90eXBlPWFuc3dlcnMuc2VhcmNoX25sJnBfcGFnZT0zMQ**
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The questions I wrote is:
RE: CCHIT certification for Electronic Medical Records for Doctors office. Can HHS give a clarification re: this organization. Thank you. Because this process is so expensive (More than $200,000 for 3 yrs) for small vendors to go through, many otherwise successful EMRs have decided not to get certified. CCHIT is now being blamed as an organization formed by ill-intentioned big EMRs to drive out competition from small EMRs.Please visit:http://www.emrupdate.com/forums/thread/56115.aspx
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Regards.
Thanks joseph! I've added that and other of your entries into the letter index at http://www.emrupdate.com/forums/EditPost.aspx?PostID=56268&ReturnUrl=%2fforums%2fShowThread.aspx%3fPostID%3d56268%2356268
Let me know if I've left out any of your initiatives. BTW, I just finished sending a letter to Dr. Kibbe of the AAFP!
Got response from HHS:
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Your question has been received. You should expect a response from us within 24 hours.You may also update this question by replying to this message. Because your reply will be automatically processed, you MUST enter your reply in the space below. Text entered into any other part of this message will be discarded.[===> Please enter your reply below this line <===][===> Please enter your reply above this line <===]
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Regards:
r2t2ellis
I appreciate your effforts. Sir. Thank you very much. Hopefully more and more small EMR vendors and even vendors who write free EMR will contact FTC.