As the long and winding river that is EHR certification rolls along, CCHIT recently opened up its latest iteration of testing to the public. The two new offerings are “CCHIT 2011 Comprehensive” Certification and, in line with what is known today about “meaningful use,” Preliminary ARRA 2011 Certification. To drill down on the distinction between these two programs, and to learn more about CCHIT’s progress overall, HCI Editor-in-Chief Anthony Guerra talked with CCHIT Chair Mark Leavitt.
GUERRA: I think there is still some uncertainty about CCHIT’s new programs. Would you like to go over them to start us off?
LEAVITT: I think that’s a good idea. On Oct. 7, we opened all of our 2011 certification programs – now we have two that we’re launching. One is called the CCHIT Certified 2011, and we’ve referred to that as the Comprehensive Program, and the other is called the Preliminary ARRA 2011 Certification. And people may choose to refer to that as a modular program, but it’s really just a certification that’s offered in a modular way. We used to talk about a site certification as being a third pathway, but what had become clear to us is that the site certification is an option for either of those. So site certification is just one option under the Preliminary ARRA 2011 program, and it’s also available under the CCHIT Comprehensive. You can think of it as two paths to certification and, in each case, it could be a vendor product or a site that comes to be certified.
GUERRA: And we should think of the modular as the Preliminary now?
LEAVITT: Let me explain the two. The goal of the CCHIT Comprehensive Program is maximum assurance. So we’re basically trying to deliver to providers additional help in selecting an EHR. In the case of the Preliminary ARRA 2011 program, the main goal is flexibility. We’re trying to create a program that presents the lowest possible barriers to developers, to vendors, to providers who have followed any of a variety of pathways to develop products or to assemble products, and not create a barrier for them receiving the ARRA incentive, if those products meet the federal standards.
GUERRA: And then you’ve got your gap certification which would be for any additional requirements that are added to certification by the government?
LEAVITT: Yes, but let me make something clear. The CCHIT Comprehensive Program also meets or exceeds the Preliminary ARRA requirements, though both programs will potentially need an incremental test if any of the standards or criteria exceed those that have been proposed to date by ONC or by the Policy and Standards Committees.
GUERRA: There will be a gap available for both of them?
LEAVITT: Right. The CCHIT Comprehensive Program also includes certification against the federal standards. The Preliminary ARRA is only against the federal standards. So if there is a gap and we need to do an incremental test on products and services from either certification program, we will need to come through with a gap test to get that corrected.
GUERRA: The Policy Committee recommended a gap certification process that could be used against CCHIT ’08 Certified products. Is it accurate that you decided not to go in that direction?
LEAVITT: Yes, we’re not following that particular recommendation. And the issue is that of maintaining a level playing field. There are many vendors that have not been previously certified that would like access to the marketplace. There are also vendors that certified in earlier years, such as 2007 or 2006, who may have been planning to re-certify against our 2009 criteria. So to shut all of those out and only allow the 2008 certified vendors access to this program would clearly constrict the marketplace unnaturally and unfairly. So we have created a level playing field. All vendors are welcome, whether previously certified or whether they have done 2008 before or a different year, they can choose to apply for either of these two programs.
GUERRA: Organizations that have received certification get to the front of the line when it’s time for gap testing, correct?
LEAVITT: First of all, let me just discourage you from using the term gap. We call it incremental testing. We don’t know if it will be necessary or not. In fact, if we thought there would be a lot of new standards still emerging, we might have decided not to launch the preliminary certification now. So we feel pretty good that the standards and criteria won’t be more rigorous than what have been published. We’re just offering the incremental testing as a contingency if there is a new standard that comes out or there’s a change.
The reason we would give priority to those who have already moved forward is that’s just good customer service. If you offer a service or a product and you find a new standard has emerged and the product is no longer compliant with the new standards, you need to correct that before you start selling new products to other people. That’s just the basic picture of this. And what’s more, that test should be very simple. We don’t expect large amounts of new materials to be covered. So we can do those tests very quickly, very simply, and we’ll get those done right away when the final rules and the final meaningful use matrix is available.