Thoughts on EHR Certification Criteria Interim Final Rule

Time for a break from the regularly scheduled HIMSS programming (sorry there’s just a lot of HIMSS content to still be published) for some thoughts and comments on the EHR Certification Interim Final rule. What can I say? I was inspired by CCHIT’s comments on the EHR Certification criteria.

First, since I mentioned CCHIT’s comments, I have to admit that I think that CCHIT made some very reasonable comments. I’m not sure I really disagree with any of the detailed points that they offer in their comments. What’s probably most interesting in CCHIT’s comments is the last two sections where they talk about the adverse impacts that this rule is likely to have on small EMR vendors and more importantly, small healthcare facilities. I’m not sure I agree completely with their analysis, but it was nice to see CCHIT backing the small businesses.

Now, just a few comments of my own about the major problems with the Interim Final Rule. I’m not going to go through the finer points. Just some major thoughts about what ONC better avoid as they adjust the criteria.

The first challenge that I think they face is the times that they apply certain criteria to hospitals and ambulatory the same way. They’ve actually made a good effort to separate the two entities, but they need to do more since a hospital EMR is VERY different than an ambulatory EMR. In fact, CCHIT even points this out a number of times in their comments as well.

Probably the largest problem I see with this criteria is their inability to take into account the various specialty needs when it comes to an EHR. The criteria basically treats all doctors offices the same. This is a problem that is going to have a widespread effect and is likely to really hinder EHR adoption.

ONC really needs to take a hard look at the criteria and think through how that criteria is going to affect the various specialties and specialty EMR software out there. One concept they should consider is that maybe they aren’t trying to define a certification criteria for an “EHR software” for one market (healthcare), but instead are trying to define a certification criteria that will work for “EHR software” across 100 markets (each of the specialties).

Certainly, we’re going to see a lot of consolidation happening in the EMR industry. However, the more I think about it, the more I think that there’s not just one EMR industry, but that there’s a whole collection of industries out there. Every time an EMR software is installed in a new specialty, it’s like they’re trying to enter a new industry. Now, just imagine trying to create a criteria for software that applies across all these industries. No wonder it’s a major challenge.

Next up, ONS should place much less emphasis on the certification criteria and let many of those criteria be shown in the meaningful use guidelines. Let EHR vendors innovate in how they are to accomplish the meaningful use criteria. It’s simple for an EHR vendor to create new features. That’s just a matter of time and cost. However, it’s much different for an EHR vendor to focus its energy on creating a usable system.

If the “certified EHR” component of the stimulus requires EHR vendors to build too many features, then we’re going to end up with a number of poorly designed and unusable EHR systems in clinical practices. Implementing these unusable EHR systems will do nothing but hinder the adoption of EHR systems.

Not to mention, if the EHR vendor shoddily implements a feature to become a “certified EHR” and then the feature is too cumbersome to actually be used, the doctor will be the one left holding the cost of the EHR with no access to the stimulus money. This will also help to hinder EHR adoption.

ONC should focus less on features (EHR Certification) and more on results (meaningful use) and allow the various EHR vendors to innovate on how they will provide the results.

Finally, ONC should focus the certification efforts around establishing standards where EMR vendors are unwilling to standardize. This type of focus will provide a real an actual benefit to doctors who can benefit from this sort of interoperability. Stop focusing on features and functions that will provide little value to doctors.

At the end of the day, the criteria need to be simplified to apply more broadly and to not stifle innovative EMR software companies. Too strict criteria will hinder EHR innovation and more importantly, long term adoption of EHR software.

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.

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