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Electronic Health Records


fl ow customization? If an Internet EHR is chosen, local installed base is less important; everyone can operate their Web browser. Ask consultants for a Gantt chart. Note the sequence of the tasks and ask the consultant to explain them to you. Ask also for a list of EHR products their clients have adopted, and then determine if they are recommending a cross-section of EHR solutions, or consistently picking only a few vendors. The ONC has deferred EHR qualifi cation to RECs, who issue RFQs. The Rhode Island RFQ was 40 pages long online, but also required printing in triplicate and mailed submission. That’s 120 pages of required docu- mentation – a tedious, non-green, time-consuming pro- cess instituted by an organization charged with showing EPs how to live without paper in their practice. Multiply that by 59 other RECs, all using different forms, dif- ferent qualification ques- tions, issuing RFQs around the same time and you realize what EHR develop- ers (and other EP subcon- tractors) went through to qualify EHRs that already had CCHIT certification. EHR developers found com- pleting all these RFQs a daunting, time-consuming and exhausting task. Many with excellent products


simply could not participate and were thus overlooked. Reviewing EHR submissions received took a lot of time; ultimately, a few EHR products qualifi ed, but based on what recognized standard? Why are 60 RECs qualifying EHR developers individually in the fi rst place? Isn’t that exactly what the government created CCHIT to do?


What is CCHIT certifi cation good for? President Bush created the ONC and the ONC created CCHIT to accelerate the adoption of EHRs. CCHIT felt having a minimum common denominator for EHR functionality would do that. In fact, it didn’t, but its certifi cation was required for liability premium discounts, Stark Safe Harbor exceptions and other incen- tives, so 160 EHR developers paid $28K to have their EHRs CCHIT certifi ed. They paid another $75-90K to add features that were not essential to the market specialty, but CCHIT nonetheless considered minimum for an EHR.


Whatever you think of CCHIT, it was at least one, totally transparent standard that included rigid compli- ance testing. In 2009, Obama’s Congress undermined CCHIT certifi cation by having 60 RECs pre-qualifying CCHIT-certified EHR products without validation,


16 August 2010 © 2010 - MSP/Andrew EHR benchmark shows waning support for CCHIT.


based on inconsistent, opinion-based requirements and a cumbersome, expensive process that EHR developers (who didn’t wish to be excluded from selling to 100,000 EPs), were forced to accommodate. Why Congress felt that 60 not-for-profi t organiza- tions, some with little EHR consulting experience, were competent to qualify EHR products for the U.S. market is a mystery. In N.J., NJIT is the REC. It’s a wonderful university with computer engineering courses, but does it have extensive EHR consulting experience? So on what basis is NJIT more qualifi ed than CCHIT to determine for all N.J. EPs what EHR products will be offered? No matter, CCHIT’s certifi cation was undermined. Alisa Ray, new executive director of CCHIT (fol- lowing Mark Leavitt’s sudden retirement), hastens to point out that CCHIT can do the new MU certifi cation as part of the same fee it charges for its CCHIT cer- tifi cation; but that doesn’t change the fact that many EHR developers feel be- trayed by both CCHIT and Uncle Sam, and EHR vendor support of CCHIT is waning, as shown in the MU certifi cation chart. By dumping CCHIT, Democratic legislators de- layed EHR adoption further


and distorted the EHR market towards a small subset of larger EHR developers. But what about the many smaller and emerging EHR companies that HITECH has hurt? If they fail, it will not be because they lacked competitive products, but simply because Democrats have legislated an expensive process too burdensome for smaller EHR suppliers to comply with, even those with CCHIT certifi cation. Ask EHR developers not prequalifi ed by RECs how they feel about Congress, 15 months of delays in clarifying meaningful use and 60 REC RFQs to be completed so they can sell their products to 100,000 EPs that have been driven to the sidelines due to confusion about federal reimbursement requirements. We can’t print the responses here.


Why Congress intentionally moved procurement of $34 billion for EHR technology outside normal govern- ment purchasing regulations, circumventing GSA and federal acquisition regulations, is a matter of speculation. Some cynical observers see the REC process as a vehicle for political paybacks. The EHR qualifi cation process has no overall feature matrix summarizing requirements made by all 60 RECs, nor any explanation of how individual criteria were weighted in picking the qualifi ed from the non-qualifi ed


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