What is “Meaningful Use”, What EMRs should be “Certified” and Who should do the Certifying

Because of all the money being thrown at doctors and hospitals as part of the HITECH (Health Information Technology for Economic & Clinical Health) Act, a component of the ARRA (American Recovery and Reinvestment Act), it becomes important to use certified EMRs in a meaningful way.

It has always been important to use EMRs in a meaningful way, but now you can get paid ($44,000 per physician) if you jump through hoops created by organizations like CCHIT which is the Certification Commission for Healthcare Information Technology, who want to make money for their executives and suppress competition for their top clients. The government has put the wolves in charge of guarding the hen house. Diversity, choice and competition have taken a back seat to self-serving regulation based on big business payoff of our government at its highest level (the big EMR companies have bought Obama). This is truly breathtaking and incredible (see BusinessWeek May 4, 2009, page 31-37)! The best way to stunt the development of any system is to suppress diversity, choice and competition by putting the rich and powerful in charge. The people in charge want to make more money, they don’t want better EMRs and they don’t want what is best for our healthcare system.

Today’s blog is going to be a little different. I am not going to comment on the present criteria used for CCHIT certification and I am not going to comment on the current state of the “meaningful use” definition. I KNOW what “meaningful use” is. I am a doctor, I have an EMR … I know “meaningful use” when I see it. Walks like a duck, quacks like a duck, looks like a duck. All doctors KNOW intuitively what “meaningful use” is.

I am not going to comment on the specifics of CCHIT Certification Criteria because I KNOW it is not optimal. Tear it all down and let’s start from scratch. It may have served a purpose in the past to move the industry forward, but it has now become a problem. It inhibits innovation, diversity and choice. It costs too much, it is too complex and many very good EMRs are not CCHIT certified. Company’s are wasting their time, money and effort to get certified rather than improving their EMR product! CCHIT’s primary purpose now seems to be self-preservation at any cost. Their executives want to preserve their six figure incomes at any cost.

Instead of commenting on what others have said about these two issues, I am just going to tell you what I think … I am going to keep it simple.

Any EMR that can be used in a meaningful manner should be certified. Period. End of the certification problem. My definition of meaningful use is so simple and so intuitive that certifying an EMR becomes very easy. So easy that you don’t need to pay much money and you don’t need an organization like CCHIT. You can hire a CPA or an Accountant to do the certifying.

Any EMR should be certified if it can do everything listed below. If it can do these tasks, it is being used in a meaningful manner and thus satisfies the “meaningful use” requirement.

What an EMR must do:
●Document a Progress Note
●Store, Index and Provide access to Lab Results, Test Results, Hospital Reports and Consultation Reports
●Store and Track Wellness information for Chronic Conditions like Diabetes (Fasting Blood Sugars, HgAICs, Eye Exams, Kidney Tests and Foot Exams) and Coronary Artery Disease (Blood Pressure, Cholesterol, EKGs, Stress Tests, Echocardiograms, Catheterizations, Cardiac Consultations).
●Store and Track Health Maintenance Information for Routine Care of Adults and Children (Flu Shots, Pneumonia Shots, Immunizations, Mammograms, Pap Tests, PSA, Colonoscopies, Bone Density Tests)
●Write Prescriptions
●Write Orders
●Help Select Diagnosis Codes (ICD-9 and CPT Codes)
●Help Select Level of Care Codes (Evaluation & Management (E&M) Codes)
●Perform Scheduling, Billing and Intra office Messaging OR Interface with a Practice Management System
●Collect and Report data for Quality Improvement Activities and Pay-for-Performance Activities
●Connect with Regional Health Information Exchange Platforms (HIE Platforms) AND be able to Import and Export Data in the Continuity of Care (CCR) or CCD Format

If an EMR can do the above tasks then it is being used in a meaningful manner and it should be certified. My background is Internal Medicine, so there may be adjustments that are need for certain specialties. Some may feel that I should include a patient portal and clinical decision support in the above criteria.

Let’s not overcomplicate this EMR thing. We want doctors using an EMR and we want companies coming up with better EMRs which help doctors provide better, more efficient care at a lower cost. The only way to achieve these goals is to let the market place select the best EMRs. In order to do this, you need innovation, variety and choice. You have to nurture and support small companies. We have to encourage people to get into the EMR business rather than create barriers to entry. Using CCHIT certification and possibly a complicated definition of “meaningful use” we risk inhibiting innovation by snuffing out new and small companies with regulations that are not practical, helpful or wise.

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Dr. Jeff

13 Comments

  • Agree with your definition of “meaningful use”–simple (as much as is possible) will likely dictate use. A great analogy: Light bulb (labeled w/specs), placed into lamp (which is UL certified) which is then plugged into a socket in the bathroom (with GFI). Falls into wet sink (which sets off GFI & breaks electricity flow.) Enter the EHR: Specs developed (via NIST or like agency), app certified (variety of different sources), used in meaningful fashion (CDS & data reports on outcomes.) GFI for health?–continued inefficiencies & costs…

  • What can I say?

    You are just irrationally ranting against CCHIT using some facts that are taken out of context.

    Your post could be taken seriously if you wouldn’t have suggested a CPA to perform the certification. What the heck does a CPA know about EMRs?

    You are obviously unaware of valuable changes that CCHIT has proposed to lower the costs of certification and make it available to diverse groups of developers and health organizations.

    Certification goes beyond user interface functionality. Interoperability criteria is something the user does not experience directly but it does impact the meaningful use of an EMR.

    To create a more transparent process it is advisable that other testing authorities be created. They will most likely emulate the CCHIT process if they want to get up and started any time soon.

    Before ranting can you do your basic homework?

    Thanks,

    The EHR Guy

  • I fear I must agree and disagree with some of the original post and the subsequent comments, but from a different perspective. CCHIT, while referred to as “Certified” has labeled themselves in this manner- there is no body of professionals or Agency that has certified their ability or skills to do anything. I also agree that the concept of a CPA being involved in this certification process of the ability of any application to do anything when there isn’t a clear set of FORMALLY APPROVED STANDARDS or guidance that meets any agreed upon criteria to audit against.
    For 5 years now I have been asking where is the effort to develop LEGITIMATE Standards that are consensus based, open to any/all participants, with balanced participation from all impacted parties, that are subject to public review and DO NOT only involve parties paying to participate in the process.
    Additionally, where is the guidance for ensuring any information collected is in a format that is not proprietary or tied to any one vendor that will ensure persistent access to content regardless of upgrades to applications, lack of continued support, organizational buyouts and mergers, etc. How do we ensure the information collected today remains viable for 3, 5, 10, 50 or more years? Infants being born now have a life expectancy in excess of 80 years- don’t we owe it to them to establish systems that don’t result in their medical records going from “digits to dust” like so many other electronic information systems have?
    While other may not agree with everything stated here, http://shrinkster.com/17ze I think some of it and the embedded links (if they’re still active!) may ring true with most of you. And if the links aren’t active… well, maybe that helps support the concerns.

  • The EHR Guy,

    I have done a lot of homework and I think I have explained why EMRs can be certified by CPAs. It is a simple check list (see above). CPAs are good at checking checklists!

    I have a lot of respect for your opinions, but I really don’t see a need for CCHIT.

    I have read blogs from Al Borg and David Kibble, MD, MPH and I tend to agree with their perspective about CCHIT and the certification process. I will try to include some links to their better informed opinions.

    I do rant but I rant after doing a lot of homework. This type of ranting is sometimes a good thing. In the case of EMRs, someone better start ranting soon or we will be taking to a very bad place by the big EMR companies and CCHIT.

    Maybe you can be more specific in the problems you have with my opinion. For example, why do we need a complex and expensive ceritifation process? Why can’t it be as easy as I have outlined in my original entry?

  • I thought this was a great blog entry from Al Borges, MD. He goes over a feud that Mr. Leavitt from CCHIT is having with David Kibbe from the American Academy of Family Practice. It is a very entertaining blog.

    From Alberto Borges, MD’s Blog:

    “Today Mr. Leavitt, in an angry editorial response in The Health Care Blog6 wrote about his feelings about non-certified EMRs, his political enemies, and especially about Dr. Kibbe:” — Al Borges

    “All I can say to Mr. Leavitt is “GIVE ME A BREAK AND ADMIT THE OBVIOUS!” CCHIT is a HIMSS shill and represents a well-orchestrated attempt to corner the HIT market in the USA. Dr. Kibbe is a likable man, but what has found him an audience is that most people agree with his statements and position that it is improper for HIMSS to back CCHIT.” — Al Borges

    To read the whole blog: http://www.hcplive.com/mdnglive/The_HIT_Realist/Kibbe_Leavitt

    Read the whole blog entry. It is well worth it.

  • With an emerging national Health IT policy being developed (for the first time ever), what constitutes “certification” is up for grabs. CCHIT’s traditional approach comes from creating criteria in a policy vacuum, and have been criticized as being excessively feature-focused. Over the years, new criteria are added (never removed), and what we are left with is “feature bloat” – around 500 line-items that represent a significant development burden for new EHR emerging companies, without resulting in any clear improvement in product.

    The ARRA Certification approach is based on “meaningful use” criteria, and are basically what you outline. Some of the work done by CCHIT may, in fact, be leveraged, but a pluralistic approach to certification seems likely. What counts, after all, are results rather than “features.” Competition among EHR vendors should be around usability, interoperability and affordability – and such competition will help all involved in healthcare delivery. Anything that (knowingly or unwittingly) stands in the way of innovation and competition is counter-productive. The status quo is not something that can survive – the result of the status quo, after all, is that EHR adoption is very low… despite being dominated by CCHIT-certified, monstrously expensive EHRs with user interfaces that are dogged by clumsiness and unusability, and difficulty in achieving interoperability.

  • Why goverment give incentives? Why payer themself not certified EMR? Why payer themself not devlop EMR? Why goverment not devlop EMR? Why Payer not take over any good EMR? Why govement not take over EM? I think there is no need of incentive given by goverment. insead of that goverment has to build or buy EMR and give to all doctor free. I think this is less costly.

  • Robert, you have nailed it! I agree with you 100%.
    Dr. John, having the government take this over would be a disaster. The government is good at regulating and making a level playing field, it is not good at building things, innovating or managing things. The most expensive (and worst) EMR would be a FREE EMR from the Government!

  • Just want to emphasize the jist of the post which I agree with:

    What an EMR must do:
    ●Document a Progress Note
    ●Store, Index and Provide access to Lab Results, Test Results, Hospital Reports and Consultation Reports
    ●Store and Track Wellness information for Chronic Conditions like Diabetes (Fasting Blood Sugars, HgAICs, Eye Exams, Kidney Tests and Foot Exams) and Coronary Artery Disease (Blood Pressure, Cholesterol, EKGs, Stress Tests, Echocardiograms, Catheterizations, Cardiac Consultations).
    ●Store and Track Health Maintenance Information for Routine Care of Adults and Children (Flu Shots, Pneumonia Shots, Immunizations, Mammograms, Pap Tests, PSA, Colonoscopies, Bone Density Tests)
    ●Write Prescriptions
    ●Write Orders
    ●Help Select Diagnosis Codes (ICD-9 and CPT Codes)
    ●Help Select Level of Care Codes (Evaluation & Management (E&M) Codes)
    ●Perform Scheduling, Billing and Intra office Messaging OR Interface with a Practice Management System
    ●Collect and Report data for Quality Improvement Activities and Pay-for-Performance Activities
    ●Connect with Regional Health Information Exchange Platforms (HIE Platforms) AND be able to Import and Export Data in the Continuity of Care (CCR) or CCD Format

    If an EMR can do the above tasks then it is being used in a meaningful manner and it should be certified.

  • Excellent definition of what an EMR must do. Your list of criteria seems reasonable & achievable with current technologies yet there are many IT professionals who believe interoperability is very difficult to resolve, and it is not hard to solve. Current installed systems rarely share data and it is the user (the healthcare professionals) and patients who suffers.

    Most EMR systems require the healthcare organization and its users to significantly change internal processes. This is a red flag when evaluating any EMR software. Any system should improve healthcare service delivery and not disrupt current procedures.

  • CCHIT will soon become obsolete as “the” certifying standard for healthcare technology.

    HIT Policy Committee is working on specifications for validating meaningful use, and sooner or later these will become the certification criteria.

    I would think that HIT’s recommendations will probably become a national standard, and may be incorporated into ISO standard later on.

    You will have ISO auditors (like SGS and Moodys) who will do the certifying.

    Right now, CCHIT is a monopoly and national standards are not created to facilitate a private entity’s business – at least in theory.

  • It was really good post lot of useful information. On the point of usability and defining the term ‘meaningful use’, I would add further that the medical practitioners are looking to avail of this federal incentive by trying to comply with the definition of meaningful use but at the same time EHR providers are looking at their own set of profits.
    This misunderstanding is mostly I believe as a result of wrong interpretation of the federal guidelines. The EHR providers need to look at these guidelines from the prospective of the practitioners who deal with different specialties.
    Each specialty EHR has its own set of challenges or requirements which I believe is overlooked by im most EHR vendors in a effort to merely follows federal guidelines. This is resulting in low usability to the practitioners, thus less ROI, finally redundancy of the EHR solution in place.
    I think ROI is very important factor that should be duly considered when look achieve a ‘meaning use’ out of a EHR solution. Though one may get vendors providing ‘meaning use’ at a lower cost, their ROI / savings through the use of their EHR might be pretty low when compared to costlier initial investment.

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