GUERRA: Could you give me a brief overview of your company, and some context as to why you are qualified to test EHRs against the certification criteria HHS creates?  

DRUMMOND: Well, we’re new coming to this area with respect to the HL7 part of things, even though we’ve been involved in that off and on since 2000. We were the original people helping the early groups that actually looked at ways to transport the documents around in a secure manner, but we’ve been tracking this for 10 years off and on.

Our company focuses on interoperability for all sorts of different software, to ensure the information flows appropriately back and forth between different entities in a secure private manner. We usually do about 10 different standards a year, and we do a lot in retail, automotive, consumer packaged goods. Right now, we’re probably one of the key leaders in doing the same sort of thing we’re talking about right here for the North American Power Grid, which is another one of Obama’s key focuses coming out of ARRA Title IV.   

GUERRA: You said you’ve been approached by numerous EHR software and services companies that need to be certified. Can you just expand on that, even if you’re not willing to name the companies?  

DRUMMOND: Since we’re neutral, we never name companies unless we have appropriate release on that, so I really can’t name them. A lot of companies – those who look like they’re focused on the doctors’ offices and smaller hospitals, outpatient, ambulatory type stuff – have been coming to us for the last six or seven months asking if we can help them get certified, asking if we can get involved in this.

My read would be they seemed to feel like they’re being left out of the current certification regime. I’m not completely sure in all detail why that is but, because of that, because we do certification in such broad areas for interoperability, we decided now is the time to enter this market, especially since the ARRA Act Title IV threw a lot more resources at this area. 2011 is approaching very rapidly, and people have to start moving this way if they want to achieve meaningful use.

So we figured it was probably time. If we look at other supply chains, which we do a lot of work in, we see that about 80 to 90 percent of all the people participating in the information flow in the supply chain are small or medium vendors, are small or medium companies. The same is happening here, and my read would be that some of the smaller ones don’t think they’re being taken care of. I don’t know if that’s key or not because I’ve looked at the CCHIT stuff and it looks like they’re doing a pretty decent job of putting together the stakeholder groups and putting together the testing regimes.

GUERRA: So you don’t have a better sense of whether they feel the current pricing is too high or if the certification process is too long? You’re not getting a more definite sense of what it is they’re coming to you for?

DRUMMOND: We’ve been kind of overwhelmed with a lot of this for the last three or four weeks, so we’re going back to interview some of them just to see what the actual problem is. I should know more in probably three or four weeks.

I expect that this is like normal testing where pricing is always an issue. Every test that anyone does, people think it’s too high because it’s one more cost to add in the end. The flipside is we find that once people understand what pricing gives them – it’s almost the last part of their software cycle – they see the cost is not nearly as high as they would anticipate, because it’s a cost of shifting from internal testing to external testing, and it also gives them a big marketing boon because someone is stamping their seal of approval on you, you’ve met these conditions. And that marketing boon is worth anything, you pay for that sort of thing.

GUERRA: Why did you decide to get into this business when there are so many questions around how everything will actually work?

DRUMMOND: What’s going on is focused on how you’re going to use EHRs to make life better for the patient from a hospital sharing information, to privacy and security, and how you communicate information to public health agencies. But a key part of that is those are procedural type issues and like-it-ought-to-be type issues. You have to go through and say, “Did you meet this as an end user?” But a key part of that is they have to buy certified products that meet conditions, and the conditions are those that you get from use cases like, “I want to go do ambulatory care, I want to go do emergency room type things, and I want to do e-prescription.”  Those are part of this set of things that you’ll have to go implement to start meeting this overall meaningful use definition. And that’s a very bounded technical area which talks about how you guarantee that they conform to the specifications, how you guarantee they conform to their requirements, how you guarantee Vendor A can talk to Vendor B, which is a very, very hard thing to do quite often, especially if you have 50 or 60 or 70 vendors doing this sort of thing. That’s the area we do very, very well. We’re very, very neutral. Our clients range from IBM to Microsoft. We do this worldwide, so we’re very comfortable doing that.

GUERRA: Is there any startup money in this for you from the government? 

DRUMMOND: We haven’t looked for that yet. That’s the next thing we’re going to be doing. Most of our tests are either sponsored by a third party – which might be the government (we call it scholarships) – or paid for by the people who are having their own products tested. It’s those people who usually pay because the benefit they get is in debugging their software and also major marketing clout.

So right now we have to wait for what CMS is going to do with the federal registry notice. We have about a month and a half before we start seeing where they’re going in this whole area. So we’re just looking into that. We’re very coupled to the technology part. Now the other issue is making sure we put all the rest of the procedural parts together, and that looks very doable also.

GUERRA: Why announce this now?

DRUMMOND: We’ve been talking about it and thinking about it for several months and now is when it popped, so we released it.

GUERRA: Did you have any conversations with people on the Policy or Standards Committees?

DRUMMOND: We got most of our feedback from a lot of these vendors who were calling us over the last six or seven months. We’re well-known for certification in several industries, and that’s where many of these vendors found us. For example, we do auditing for the DEA regarding controlled substances. So people found us through those links and they’ve been talking to us about doing this. That started our whole research in this area. And we have really not gone up the ladder all the way to the top yet because it looks like it’s just evolving too fast to really start throwing a lot of effort at that right now.

Our focus really is the technical part of things regarding how you test products so they are conformant to what you want, so they’re very interoperable and you can buy them off the shelf. I’m talking about COTS – commercial off the shelf products. You know those are going to work without additional effort. That’s our focus, to make those things work.

We have worked with stakeholder groups in many industries, and we often find it’s best if the testing agency is completely neutral. Even though they talk to the stakeholder groups, they are neutral from the stakeholder groups.

GUERRA: How closely have you investigated CCHIT’s methods, model and structure? This will be, at least for awhile, your main competitor.

DRUMMOND: We think it’s very important to keep the stakeholder groups who define the requirement areas distinct from the testing parts, if at all possible. That doesn’t mean it can’t be the same organization, but it means you have to have some really clear boundaries. So CCHIT has both of those combined, and we always try to avoid having those two combined very closely.

Our focus would be very much on working with CCHIT, our working in parallel with them, but we all have to use exactly the same test criteria to make this whole thing work. So it has to be defined somehow so that happens. We need to focus on the technical aspects in making everything come together appropriately, so that when people go buy these products they can say, “Well, I’m one step into meaningful use. I have one key component in place. Now, I have to show how I use it to get the rest of it.”

GUERRA: The government is essentially forcing the separation of establishing the criteria from the testing. So that’s going to happen to CCHIT.

DRUMMOND: That’s very smart. That’s what we’re doing actually in this smart grid; we’re making those things distinct because they have to be that way.

Part II