An EMR and HIPAA reader, recently pointed me to a post on a Google Group called “Response to HIMSS ‘Call to Action’: Interoperability First.” The response starts with a short discussion of the need for government to promote and support some sort of interoperability standards. I’ve said a number of times before that interoperability should be a focus of government, because interoperability is more of a public health benefit than it is a benefit to doctors.
After discussing interoperability, the response discusses reasons why CCHIT certification is an inappropriate standard for the HITECH act to use to determine “certified EHR.” Take a look at the reasoning:
As it currently exists, CCHIT certification is an inappropriate standard for federal funding, authorization or endorsement of HIT systems:
*CCHIT 2009 certification has over 450 separate requirements, the collective effect of which tremendously increases the cost and complexity of IT solutions. Many of these requirements are “functional specifications” that should be determined by customer needs and priorities, rather than by committee. These requirements foster (if not mandate) the development of rigid, monolithic systems.
*The monolithic approach to certification taken by CCHIT does not reflect the current advances in information technology being leveraged by other industries where integrated solutions are used to support the complete “end-to-end” business process. Integration and interoperability are essential to leverage the potential of “cloud computing” and other service orientated delivery mechanisms.
*CCHIT works to the benefit of a small number of large EMR vendors that can command a high price from the relatively small segment of the market able to currently afford their products. It is essentially anti-competitive, and establishes a major barrier to entry by new vendors and open source projects (where the majority of innovation will take place).
*A quick count from the CCHIT website gives the following results for the number of systems certified for ambulatory EMR (including conditional certifications and multiple certified products from a single vendor):
i) 2006 = 93
ii) 2007 = 55
iii) 2008 = 14
*At this rate of attrition, the number of certified products will dwindle to the single digits.
*The shrinking number of vendors that are capable of meeting CCHIT certification exposes a fundamental flaw in its current organizational structure – CCHIT is funded by the very vendors it certifies. In order for it to maintain revenue, it needs to provide a reason for vendors to continue to either:
i) re-certify on a regular basis
ii) apply for new certifications
*The problem with this model is that, in order to justify ongoing re-certification, CCHIT must continue to add new certification requirements year-to-year. The driver for more requirements is not necessarily the needs of customers or the best interest of the healthcare system, but the need to have new requirements against which to certify vendors. This is illustrated by the fact that CCHIT has recently reduced the length of the certification from three to two years, and is adding numerous supplemental certifications in areas like child health, cardiovascular, etc. There is no end to the number of requirements to which this could lead, but there is no evidence it will serve anyone well in the long run, other than the few large vendors with the resources to keep up with this process, and CCHIT itself.
*Although in theory vendors can apply jointly for CCHIT certification, in practice the monolithic certification process will limit the ability for vendors to provide component solutions from which customers can choose to create best-of-breed, low cost solutions that best fit their needs. For instance, in the ambulatory arena, this might typically be a combination of Practice Management, EMR and e-Prescribing solutions.
*Certification of Practice Management systems in other markets (e.g., UK) has arguably reduced innovation and investment, increased the total cost of ownership and consolidated the market to such a point that there is limited choice and the barrier to entry for new entrants into the marketplace is unaffordable.
I think this is just the start of what could be said, but it raises some really important points about certification.