Thoughts on the New CCHIT EHR Certification Paths

Earlier today I posted a general explanation of the various CCHIT EHR certification paths as they were talked about at today’s CCHIT town call meeting. If you haven’t read that, go read it first and then come back so you know what I’m talking about when I say EHR-C, EHR-M and EHR-S.

Some of the comments made on the CCHIT town call today really got under my skin (imagine that). I just have to get them out there. Many of them I actually sent out on my twitter account in real time.

CCHIT Does Not Protect Doctors
The first one that reminds me of fingernails on a chalkboard is they repeatedly mentioned that the EHR-C certification was a protection for doctors. I’ve discussed this issue with CCHIT many times before. So, I don’t want to rehash it all here. However, I just don’t understand why CCHIT can continue to perpetuate this idea when no study has shown that it’s actually the case.

In fact, there have been many stories of clinics uninstalling CCHIT certified products for non-CCHIT certified products, because the certified EHR was unusable. Other people like to point to an EHR company that can pay for CCHIT EHR certification has more skin in the game and is less likely to fail. The facts show that many CCHIT certified EHR company are going under. So much for CCHIT EHR certification helping to protect the doctor.

Certainly a doctor selecting an EHR needs to be careful to select an EHR vendor that’s on firm ground. They also need to find an EHR that will be usable for them. They also want to select an EHR which they can implement successfully. Sadly, CCHIT has shown no proof (and in some cases the opposite effect) that it can solve any of these problems. CCHIT is planning for user ratings and usability measures, but we’ll talk about the challenges with those in future posts.

CCHIT EHR-C Certifcation
At one point in the CCHIT town call, they said, “An EHR-C would be done by EHR vendors who want a more comprehensive solution.” An EHR vendor doesn’t go and do this laundry list of requirements that’s made by someone other than their customers because they want a more comprehensive solution. In fact, I had one EHR vendor tell me that they went through the EHR certification list and found about 100 or so CCHIT requirements that produced no benefit to their customers.

Why then, you might ask, have EHR vendors been doing the EHR-C certification?

Up until now it’s been all about marketing their EHR. CCHIT has done a great job making doctors FEEL like a certified EHR is a safer bet despite that not being the case. The number of EHR vendors that were doing CCHIT certification was going down each year. That’s because EHR vendors didn’t care about the features, they just wanted to be able to tell sales leads that they were certified. Of course, this year we’ve seen a major spike with EHR vendors getting certified in anticipation of the possible ARRA funding requirement.

I’m not trying to say all the CCHIT certification requirement list is bad. Some of it is good and should be implemented, but that doesn’t mean 1. that an EHR-C vendor is going to be usable and 2. that ALL of the CCHIT requirements were worth the cost to implement.

CCHIT EHR-M Certification
EHR-M is an interesting twist on EHR-C certification. Basically CCHIT’s saying they’ll just take a specific component of the EHR-C certification and make sure it works. Sounds reasonable. I think this was designed for hospital systems (and sometimes group practices) which might use a combination of systems to accomplish possibly even more than a standalone EHR product could provide. Really could help solve the Hospital CIO’s problem with CCHIT that I posted previously.

One sticky issue with the EHR-M certification is if a hospital system used 5 different software packages as part of their implementation. If any 1 of those 5 software packages decides not to get EHR-M certified then, that location is up a creek. Certainly if they’re a large enough customer they probably have some pull. However, this could be a potential issue if all your vendors aren’t on board with EHR-M. I guess they could maybe just do the EHR-S certification for the system that isn’t EHR-M certified?

CCHIT EHR-S Certification
You thought I was going to be all negative in this post. Well, you’re wrong. I actually kind of like the idea of the EHR-S Certification. I’m not sure how it’s much different than trying to measure meaningful use, but that’s the topic for one of my next posts. That said, I like the idea of a relatively low cost way to certify your use of an EHR.

This does a pretty good job of solving the open source EHR certification problems. It handles the home grown EHR system problems. It deals with the smaller EHR vendors that don’t want to spend their development dollars on the full EHR-C certification problem. It even works for hospital systems that have a mixture of all sorts of systems, but have the required functionality.

The real challenge I see with EHR-S certification is how can CCHIT scale this certification and still keep the costs reasonable enough for a site to want to do this certification. However, if this is the certification type selected by ONC and HHS, why should CCHIT be the only one to do the EHR-S certification? Why couldn’t the requirements be open source and implemented by a whole group of certifying bodies? CCHIT is non-profit after all, so why should they care if other organizations participate in the EHR-S certification? Plus, by having multiple organizations doing the EHR-S certification you have some competition which keeps prices down.

I think it is also worth mentioning that this EHR-S certification could possibly shift the cost burden of EHR certification from the EHR vendors and on to the doctors. Not something many doctors are going to really like. It could easily be seen as a gamble for doctors to pay for the certification in hopes of getting the $44k EHR stimulus money jackpot. Although, the criteria for certification will be published and you should know if you’re going to pass or not before you get started (hopefully). So, let’s call it an educated gamble.

So much more to cover. More coverage of all these issues tomorrow.

About the author

John Lynn

John Lynn

John Lynn is the Founder of the, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference,, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.


  • The idea of opening up the certification process is one that will have to be considered if certification is to be a help rather than a hindrance to the process. It’s one thing for the certification process to be a legitimate hurdle that vendors need to successfully cross to prove marketability. It’s another thing all together for it to be a mountain that can only crossed with the help of a pack mule, and you have to carry the pack mule!

    This will show my age but many of the technological issues circling this field remind me of the very early days of email. Email systems back then were extremely expensive (hundreds of thousands, sometimes millions of dollars for large companies) and they didn’t talk to each other. So you could spend $500,000 for an email system and still not be able to send an email to a potential client because they were running different systems. Customers were not happy and eventually ripped out those incompatible systems once standards were finally put into place.

    Thanks for a thought provoking post.

  • Stephen,
    Thanks for sharing the history around email. That does sound very similar. One major difference is the switching costs of an EMR are much higher than an email system. Converting the data in an EMR to a new EMR at least in our current state is much harder than moving emails. Plus, with emails you could just leave it behind and not worry too much.

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