Another Letter to the Editor, Government Health IT Blog (very complete!!!)

Letter received:
 
Subject: RE: Letter to the editor at "CCHIT Gets Official Status".
Date: Thu, 16 Nov 2006 09:10:46 -0800
From: "Nancy Ferris" <nferris@1105media.com>   Add to Address Book   Add Mobile Alert

To: "Alberto Borges, MD" alborgmd@yahoo.com

Dear Dr. Borges,

Thank you for letting me know of your views of CCHIT and certification. 
I was not aware of these kinds of objections to the process.

Unfortunately, we cannot find any record of a letter to the editor from
you.  If you would like to send it again, please send it directly to
the attention of the editor in chief, John Monroe.  His e-mail address is
jmonroe@fcw.com.

If an occasion should arise, I will be contacting you for comments to
include in a future article on CCHIT.

Regards,

Nancy Ferris
Senior Editor
Government Health IT
http://www.governmenthealthit.com/

Response sent out:

Dear Mr. Monroe:

I read with interest the article that appeared in your newsletter, "CCHIT gets official status" dated 10/27/2006. I would like you to know that there is another side of CCHIT which makes this organization much more controversial than they are currently perceived. The founders of the not-for-profit Certification Commission for Healthcare Information Technology (CCHIT) make this company out to be one out to do a community service by posting a set of standards that will eventually regulate the EMR market and in that manner increase the adoption of EMRs in physician offices. In their website you read that all organizations involved are "not-for-profit" and that those that are involved are "volunteers". Their marketing is so slick that even the US Government, though the department of Health and Human Services (HHS) is giving them backing through monetary and other means.

As both a physician in practice and as a programmer of the very system that runs my office, I initially was left to wonder why, at this point where adoption of EMRs is so low, should the market suddenly begin to be regulated by a set of complicated standards? If they are needed, then why doesn't the government simply post these standards and test them for free like they did with the ANSI standards ("verification", as is used for billing Medicare and other insurance companies)? I was also left wondering why are such high fees involved with this private enterprise? Wouldn't that stifle innovation, competition, and overall force the smaller, less expensive (and occasionally FREE) EMRs out of the market?

I then began studying the very pillars of CCHIT and what it really represents. I've found CCHIT to be an albatross, a blight on the U.S. EMR market that if it is left to thrive can potentially cause much harm. I've also come to the realization that CCHIT EMRs have already shown themselves to be twice as expensive when one views the EMR cost matrix which has been available for years at http://emrupdate.com/. These prices are pre-CCHIT, before the onslaught of competition-thwarting certification has begun. This doubling the cost of EMRs will be its eventual downfall, but we at http://emrupdate.com/ have taken on the responsibility of making folks aware of the realities of this organization. We feel that vendors and physicians alike will react to the stark realities that underlie the CCHIT process and they will ignore the saavy presentation brought forth by its founders.

Here are some areas that are of concern:

1. "Not-for-profit" designation. The 3 founding organizations of CCHIT, included the American Health Information Management Association (AHIMA), the Healthcare Information and Management Systems Society (HIMSS) and The National Alliance for Health Information Technology (Alliance).  All 3 are "not-for-profit" as is the CCHIT organization itself, yet HIMSS represents a vendor trade lobbying organization and neither it nor CCHIT represent any one of the "not-for-profit" purpose categories of religious, charitable, educational, literary, or scientific. They claim to "educate" Congressmen about HIT issues, but many consider that more lobbying for the advancement of the high priced EMRs that are sold by the vendors involved with HIMSS than for anything else. Not-for-profits are supposed to limit their lobbying efforts to less than 3% of their operating budget, yet one recent article in Health Data Management noted that HIMSS is concerned about a Democratic-Congress initiated ban against privately funded travel and other lobbying expenses. Lastly, not-for-profits strongly stipulate that there should be no distribution of financial gains to directors, officers or members, yet their own incorporation papers state that: "Any profits that are made by CCHIT are disbursed among the same CCHIT vendor-owners at year's end." An obvious conflict of interest arises for not only suppression of competition but by forcing small business vendors to lose profits by paying large fees that eventually flow to the competition who are the actual owner/operators of the CCHIT organization. For the fiscal year 2006 their own Commission meeting minutes has an income statement: "...we could end up with net income of one million dollars at the end of the fiscal year, which is December [2006]."
2. CCHIT as a "Recognized Certification Body". The collusion of government with the private sector under the umbrella of forming an official "recognized certification body" is worrisome. This collaboration will stifle innovation, markedly decrease competition by smaller vendors with less costly electronic medical record (EMR) products, and add a layer of fees and costs that is unnecessary. The growth of the health infomation technology in the United States was already growing at an increasingly healthier rate.in the previous 5 years driven by decreasing EMR prices. This involvement by government has set up an environment where physician consumers will now have to purchase much higher priced "certified" EMR systems in order to see Medicare and other patients with government-backed insurance programs. Abuse will be seen on both ends of this process- on the government side by the use of mechanisms such as pay-for-performance to further decrease physician reimbursement and in the private sector where the large, powerful vendors which control CCHIT from within will profit from the fees paid for certification, and also will profit from the loss of competition from smaller vendors unable to pay for the high cost of certification.
3. CCHIT goal: ensure interoperability (compatibility) of HIT products. The most important issue that CCHIT is supposed to address, but hasn’t (and doesn't plan to address fully through 2008), is interoperability. The Continuity of Care Record (CCR) interoperability standard from ASTM International, is a proven method for sharing a patient’s health information between care providers. The cost for vendors to implement the CCR standard is minimal and already vendors are being verified by entities such as the American Academy of Family Practice.
4. CCHIT goal: reduce the risk of Healthcare Information Technology (HIT) investment by physicians and other providers. CCHIT focuses on “enterprise” type functionality that would never be used by an individual provider or by small group practices. This is especially disturbing when you consider that individual providers and small group practices represent 88% of all practicing physicians. CCHIT also does not certify an EMR system will be truly functional for the purchasing physician office. It only tests a set of preordained list of features some of which are inappropriate or simply unwanted by the vast majority of purchasing offices. Cost is the main barrier to the growth of HIT, and the costlier the EMR, the more money is at risk when purchasing an EMR. CCHIT, by increasing the overall cost of EMRs through its high certification fees and through the loss of competition will increase, not decrease the overall risk of purchasing an EMR. The only real way to increase the use of health information technology is to make EMR systems less bloated with requirements and much less expensive. This reduction in risk will not be brought about by some theoretical certification-based "assurance" theory.

In summary, the CCHIT certification process flies against everything that living in the United States stands for- free enterprise, decreased taxes and user fees, increased innovation, increased heterogeneity of choice, and finally the growth of the American HIT industry into world leadership. CCHIT will likely end competition from free, open source, and low cost EMR products and will affect the viability of not only small to many mid-level EMR vendors, but also physician offices alike by markedly increasing the cost of EMR purchases and maintenance. CCHIT has won the backing of big government, of the large insurance industry, and even of a small handful of medical societies. It has been able to collect a large sum of money to conduct its activities. Even with all of this, it's overall survivability still is tenuous, since CCHIT must also strive to win over the hearts, minds, and financial support of those physicians who work in small to medium sized offices.

The upcoming year (2007) will determine whether vendors and physicians alike are willing to practice under this CCHIT cartel and pay the extra costs associated with certification. Even Mark Leavitt MD.recently said that "certification will help business. If you don’t see an acceleration in the [EHR] market, then we’ve failed.” If this becomes a reality, then a smaller, less onerous to competition, less costly and a fairer system focusing on interoperability verification would most likely become the more accepted and successful process to advance HIT for the healthcare system in the United States.

Sincerely,

Al Borges, MD
• Oncologist in private practice, Arlington, Virginia
• Author of the free MS Word EMR Project (http://briefcase.yahoo.com/alborgmd)

Very well written Al, even if it is in triplicate!

 

Yeah, this emrupdate editor sucks. I even tried to change the triplicate in HTML, but simply does what it wants to do...

It pretty much puts together all the data that we now have about CCHIT. I hope that they post it not as a letter to the editor, but as an outright article!!! Our research deserves such focus.

CCHIT's main aim is to increase uptake of EMRs  ...

Looking at http://www.centerforhit.org/PreBuilt/chit_assembly05.pdf, Dr Kibbe reports on page 12 that the greatest perceived barrier to adoption of EMRs is in fact cost.  So, the effect of CCHIT is only going to reduce uptake as it will lead to increased pricing.

Nothing back yet from Mr. Monroe. I've sent a tickler letter in case the original got deleted again as spam.

Hmmm... This time I did get an out-of-office response (so that means the other letter got nixed as spam):

"I will be out of the office until Monday, Dec. 4, and I will not be
checking e-mail. If you need to reach someone immediately regarding
Federal Computer Week, please contact Florence Olsen at folsen@fcw.com. If
you need to reach someone regarding Government Health IT, please contact
Paul McCloskey at paul.mccloseky@sbcglobal.net."