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Heck with "Meaningful Use"- It's "Certified EHR Technology" I'm worrying about

May 18, 2009
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I confess that I’m coming down with a serious case of Meaningful Use Fatigue.
Since the ARRA included that phrase as a condition for receiving EMR incentive payments, the industry has been parsing those two words like a French literary deconstructionist. Google will give you about 9.1 million hits on “meaningful use”.

All the angst reminds me of those people back in school who were always obsessing over what was going to be on the test. Why not just learn the material? The test will work itself out.

Likewise, it seems to me that the best advice for providers to follow today would be:

1. Get a system that works

2. Use like it’s intended to be used

The end result will be real benefits for you and your patients- AND you’ll almost certainly qualify for a good chunk of incentive money.

HOWEVER…

The section of the act that addresses incentives under the Medicare program is titled “INCENTIVES FOR ADOPTION AND MEANINGFUL USE OF CERTIFIED EHR TECHNOLOGY.” What is “Certified EHR Technology”?

For the last few years it’s meant only one thing- CCHIT blessing.

I appreciate the role that CCHIT has played. As a voluntary certification body it has satisfied a very valuable need for organizations who are selecting a system; you had at least SOME independent confirmation that the system you were banking on was functional.

CCHIT’s approach to certification standards has been to influence system development by annually raising the bar. The exact same “certified” system that you contracted for last year, and are still going to be implementing into next year, may not be certified against this year’s standard.

The process of certification that the vendors have to navigate is onerous enough that they have to make a business decision as to whether it’s worth recertifying the superseded versions of their products against the new standards. With the relatively long development and upgrade cycles that are common in healthcare IT, it’s not at all unusual for vendors to have significant numbers of customers spread across three or even four versions of their product.

Let me give you a personal illustration…

We are one of those organizations that one would think is perfectly poised to leverage our status as early adopters of EMR technology into some serious stimulus money. We bought a big, capable system from one of the leading vendors, we’ve got a mature implementation, and we’re using it pretty darn meaningfully.

Our vendor was a big supporter of the CCHIT initiative and our product was one of the first to get certified.

But if you look at CCHIT’s web site, the version of the product we’re running is NOT listed among those with current certification.

It’s not that we’ve been negligent in keeping up with upgrades. We did two point upgrades in the last few months.

The issue we’ve faced is that the vendor is in the process of a major, transformational upgrade cycle that’s been painful for them and many of their customers. They’ve focused so much effort on the new version that they haven’t bothered tweaking the previous version to keep up with CCHIT’s evolving standard, or to run the gauntlet of testing and certification for a product that they want to have everyone off of in the next 12 months. (As if.)

Now, does it hurt anything that my EMR version hasn’t gotten official blessing against the latest list of requirements? Nope. That certification is informational, advisory, consultative.

If it meant the difference in collecting $6Million in stimulus money? THAT would be a problem.

(Lest you think I’m just grinding my own axe here, we are starting our upgrade initiative now and should be safely back in the “certified” camp before the year is out. For now, at least.)

I attended Mark Leavitt’s session at HIMSS where he discussed what he expected CCHIT’s role to be in the certification process. He made some interesting observations.

First, he pointed out that the final call on what “certified EHR technology” means will be up to the new Standards Committee. For what it’s worth, they had their first meeting last week. (Transcript)

Secondly, he indicated that he wasn’t sure that CCHIT would be the only group providing input to the Committee. That sounds like what he should be saying, but are there any other groups out there with enough experience and gravitas in the certification arena to displace CCHIT’s recommendations?

And finally, he suggested that he expects to present options to the Committee, who will need to pick from their menu of choices in such a way as to satisfy their policy goals and political expediency. (Though I’m pretty sure he didn’t say it quite that bluntly.)

The point is that the committee will need to think about what they want to incentivize.

Is the goal to encourage utilization of SOME kind of HIT, to lay the groundwork of finally getting rid of paper-based records? Then they need to set the bar lower and go for the big tent approach.

If, on the other hand, they want to encourage specific functionality (like interoperability, for example), they will need to make sure systems satisfy that functionality to get certified. A lot of companies, and their customers, could get left out in the cold.

Anthony has written very eloquently in this blog space about CCHIT’s role in this critical initiative and about his concerns with the Standards Committee’s ability to meet its mandate.

The committee’s public meetings will all be webcast. There’s also a listserv available for people interested in the process. Your involvement can’t hurt; it might help.

My advice to the committee is that general adoption rates are still far too low. The healthcare industry is going to have to walk before it’s able to run. Help us digitize first. More sophisticated functionality will follow naturally.

Set reasonable certification standards. Don’t promote feature bloat. Let the rules evolve slowly enough that most of us can keep up.

Make sure the systems are usable, but don’t freeze out those that do the critical things good enough.

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