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Electronic Medical Records

EMR developers to either add or reduce jobs. The num- ber of EMR developers adding jobs from 2009 to 2010 dropped by 50 percent (16 percent to 8 percent) and the number of EMR developers reducing headcount (layoffs) improved by 3 percent (from 11 percent in 2009 to 8 percent in 2010). Because of adjustments in costs and revenues between 2009 and 2010, 76 percent of EMR developers say that continued delays in MU will NOT affect their employment. Jobs would hopefully be the last thing to change, as most EMR developers will take other actions before laying off staff. One such action is to increase EMR prices to boost revenues. In fact, we have included these questions in our EMR Benchmark. The results are shown in Figure 5.

Figure 5 – Copyright 2010 by MSP. All rights reserved.

About 43 percent of EMR developers have increased their EMR costs as a result of government MU and other certifi cations that are now required for ARRA reimburse- ment. The remaining 57 percent have not. The average price per provider for EMR deployment was about $43,000 in 2007, before CCHIT certifi cation costs ( $40,000 for three years) and MU certifi cation (price unknown) and many new development costs were added onto these baseline costs. So, today’s EMR is a more expensive product than it was just 5 years ago – before all the government intervention in the healthcare market took off. CCHIT certifi cation and its role in the future of EMR development are somewhat confused. Before ARRA, the government funded the creation of CCHIT, which was charged with improving the rate of adoption of EMRs. CCHIT decided that mandating what an EMR should do and then certifying the EMRs that met their defi nition – by giving a “CCHIT Certifi cation” to an EMR – would expedite adoption, but it did not. It was very effective however at increasing EMR costs. Subsequent legislation required CCHIT certifi cation as a precondi- tion of government reimbursement under programs like the Stark “Safe Harbor” legislation. However under ARRA, CCHIT-certifi cation was no longer suffi cient for the federal government, so it leg- islated a new process for MU certifi cation, raising the

20 July 2010

question: “If CCHIT certifi cation is not suffi cient for MU certifi cation, what purpose does CCHIT certifi cation continue to serve and why should EMR developers pay CCHIT a fee of $40,000 over three years for a certifi ca- tion that is essentially insuffi cient to assure physicians that their EMR is reimbursable under meaningful user certifi cation?” What further relevance does CCHIT have in the midst of the National Institute of Standards and Technology (NIST) now handling MU testing and other independent entities providing MU certifi cation compli- ance? When asked in the MSP 2010 EMR Benchmark about their continued support of CCHIT, some EMR developers don’t think they will continue CCHIT certi- fi cation, but opinion is divided, as shown in Figure 6. Almost 25 percent of the EMR developers who participated in the MSP EMR Benchmark plan to dis- continue CCHIT certifi cation going forward. For them it has little ongoing value. An additional 15 percent are considering discontinuing it. Five percent don’t have CCHIT certifi cation now, so the question isn’t relevant to them. But 58 percent do plan to continue CCHIT certifi cation, in spite of the expenses of having two dif- ferent certifi cations – and the value of CCHIT in the overall process, which seems highly questionable given MU defi nitions. If MU is required, why should another organization layer on additional requirements, and charge vendors to test them separately?

Whatever the Congressional Democrats thought was wrong with CCHIT, rather than fi x it or eliminate CCHIT, they chose to create a much more elaborate and convoluted approach to MU certifi cation. Remember, they did this before they even had a defi nition for MU. Here is the latest on the MU certifi cation process – which, like MU itself, is still not defi ned 15 months after the ARRA legislation was passed by Congress.

Meaningful-use certifi cation issues MU certifi cation requires new certifi cation organiza- tions because the CCHIT organization is not suffi cient by itself. The ONC has proposed a two-stage approach in establishing the new federal electronic health record (EHR) certifi cation process. The fi rst MU certifi cation would be a temporary stage and part of the mandate would be to establish different methods for testing and certifying EHR products. These would become the ONC-approved bodies, which could establish their own testing of EHR/EMR developer systems. CCHIT could be one of these bodies. The goal of these temporary test- ing bodies would be to expedite the evaluation process. The second stage, the proposed permanent process, is much more complex and bureaucratic. It involves individual testing laboratories that would be accredited by the National Institute of Standards and Technology (NIST), an independent ONC-approved accreditor


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