How do I post my comments?

Many of you have asked, so here is the direct link to CCHIT's public comments forum. In order to submit, you first have to register a username and password.

CCHIT public comments forum begins Monday

Remember that one time I decided to be really obnoxious and chastise the physician constituency for not speaking up about the ongoing EMR Certification process? Well, I stand by my obnoxiousness! Because now you actually have a forum to make yourself heard. Observe, the latest from the Certification Commission's newsletter:

"The first 30-day public comment period of the 2011 development cycle will open Nov. 16 – Dec. 15, 2009. Comment will be accepted for the first round of criteria for additional electronic health record (EHR) Comprehensive certifications not included in the Commission’s Oct. 7 launch of CCHIT Certified® Comprehensive and Preliminary ARRA certification programs.

These expanded areas include Clinical Research and Dermatology criteria (optional add-ons to the current Ambulatory EHR certification) and Behavioral Health EHR criteria - both standalone and as an optional add-on to the current Ambulatory EHR certification. Comment will only be taken through the Commission’s Web site."

Feel free also to share comments below, or email me with questions. Up next: stay tuned for a summary of the latest on certification guidelines.

--FR

Reductive Positivity Amidst the Mire of Uncertainty

Dearest Readers,

Sure, sure, sure, we're all like, "What's going to happen with EMR?" "What if I don't get my incentive payment?" "Why won't Craig call me back?"*

(*This concern may, in fact, apply only to me.)

Friends, I have the answer: We must accentuate the positive. Because my last post was a real downer. And because things could always be worse. You could, for example, be Amy Winehouse. And -- what's more -- there have been some truly encouraging developments in the past few months with respect to EMR certification:

1) CCHIT is working around the clock alongside ARRA to define meaningful use for EMR vendors. Sure, it's still half-baked, but we can nevertheless smell its cake battery goodness emanating from the kitchen into the living room as we watch cartoons with our baby brother and fight over the remote control. And, sooner or later, Mom's gonna call us in for dessert. And by "Mom" I mean CCHIT/ARRA, and by "dessert" I mean we'll know for sure what the heck "meaningful use" means. And then lots of $$$ for you and your practice via the stimulus package's incentive payment plan.

2) Who am I really to push you to make a decision before you're ready, but: when you think about it, there is actually no reason to fret about the impending certification criteria. As I wrote in this article, EMR vendor compliance is an absolute, unconditional, take-no-prisoners, definite MUST. As in, vendor survival will depend solely on this compliance. As in, no need to delay. As in, what are you waiting for? As in, I won't hold it against you if you continue to wait, but there are some extremely important reasons why you shouldn't, like this one, for example.

3) IO Practiceware continues to be awesome. If you're not part of an ophthalmology practice, I'm sorry IO can't offer you our ophthalmology-specific software -- but if you are, you can smile broadly and pat yourself on the back for choosing the field in which the best EMR vendor in the universe has chosen to specialize. And then you can buy our software. (Why are we the best EMR vendor in the universe? Here are a few reasons why.)

So there it is folks, as promised. Reductive positivity. Because, in the words of the atomic particle: "I was pretty bummed yesterday when I lost my electron -- but you know what? Now I'm more positive."

--FR

Briefly: "Meaningful Use" Response from CCHIT

After the ONC (Office of the National Coordinator) published its Meaningful Use guidelines and objectives (available here, with annotation), CCHIT responded with a cover letter assessing the value and anticipated shortcomings of those guidelines.

IO Blog commentary coming soon...

EMR: The Buyer's Dilemma

Catch-22. Cart-before-the-horse. Chickens-before-they-hatch.

Pick an idiom. It seems from your email messages that any of the above encapsulates the conundrum of buying an EMR system before it has been certified. And we at IO Practiceware feel your pain. But we'd also like to put you at ease. But not in a sleazy way, involving low lighting or Barry Manilow music. Because, c'mon, Barry Manilow makes you uncomfortable, and you know it.

You may have many reasons to delay your EMR decision until next year or beyond, but concerns about CCHIT certification should not be one of them. IO Practiceware -- and all other EMR vendors -- have no choice but to follow the ARRA rules. It's true that certain consultants and other industry figures say that practices must wait until vendors get certified -- but this presumes that there's a high level of uncertainty and/or ambiguity surrounding the process and guidelines for certification. But there simply is not. Companies can either choose to take the necessary steps or choose not to.

For everyone's sake, we choose: certification.

And, it's like, um, obvious. Not only are we being compliant for our customers' sake, but getting certified is an unconditional must if we -- or any company -- hope to remain on the market as a viable EMR vendor.

IO Practiceware will be certified as an EMR-C ("Comprehensive"), as opposed to -M ("Module"), by CCHIT for the 2011-2012 period -- which is the soonest possible period for all vendors. (There is no freestanding 2009-2010 certification. In fact, all currently CCHIT certified vendors must be re-certified for the new period.) Testing will begin in September 2009, and we are gearing up for this process by developing all the necessary enhancements for our software. (Here is an article that breaks down the timeline in greater detail.)

So, believe it or not, you can start to breathe easy. In a world of relative uncertainty and inexplicability -- where haircuts like this achieve national celebrity -- CCHIT certification should be a comfort, not a source of angst. Given the recent revisions to its criteria, CCHIT has become a means by which EMR can achieve high functionality, uniformity, and interconnectivity. Vendors like IO Practiceware, committed to the success of customers and the EMR industry, will do what it takes, get certified, and work to improve American health care.

--FR

More on CCHIT from ModernHealthcare.com

Article on exploring the effects of the new meaningful-use criteria.

The Latest from CCHIT: "New Paths to Certification" (Recap)

If you didn't have time to take part in today's Town Call with CCHIT (or, if you did, and would like a pared-down recapitulation), here is a list of major points worth knowing:

There are now three paths to certification, and three different certification types therein:

• 1) EHR-C - which stands for EHR Comprehensive
• 2) EHR-M - which stands for EHR Module
• 3) EHR-S - which stands for EHR Site

All three constitute certification, but differ in their requirements.

Comprehensive - "Rigorous certification of comprehensive EHR systems that significantly exceed minimum Federal standards requirements." Needs to meet all of the Meaningful Use Objectives.

Module - "Flexible certification of Federal standards compliance for EHR, HIE, eRx, PHR, Registry and other EHR-related technologies." Needs to meet one or more of the Meaningful Use Objectives. Applies to many specialty-specific EMRs.

Site - "Simplified, low cost certification of EHR technologies in use at a specific site." Applies to "any physician office, clinic, hospital, other facility or network that has self-developed or assembled an EHR from various sources and wishes to apply to ARRA incentives."

Process of Applying for ARRA Incentive Payments

• Certification by CCHIT allots various certification "codes" to the EHR vendor -- which apply specifically, and exclusively, to that vendor, and vary depending on the corresponding status (EHR-C versus -M versus -S have different codes) . These are then conveyed to the health care provider upon usage.
  
• Health care provider submits these codes in their ARRA incentive payment application.
• Health care provider must also submit additional "measure data" required for ARRA's own definition "meaningful use" (separate from CCHIT criteria).
  

Other Info / Points of Clarification

• Providers do not apply to CCHIT for the incentive payment; they apply to HHS. The means by which this will be done is still unclear, and has not yet been stipulated. Will it be a contractor? An online site? Via regional extension centers? What we do know is it will be through some government-named body that will 1) accept CCHIT codes and provider application; 2) assess, reject or accept quality measure data; 3) send or withhold the incentive check.
  
• EHR-M status can be awarded to groups of vendors. If certification is awarded to a group of vendors, they collectively must cover all (as opposed to one, or a few) Meaningful Use Objectives.
• Certification awarded in two year increments.
• Certification no longer "locked" into a software's parent version; all upgrades that maintain the previously approved Meaningful Use Objectives maintain those corresponding approval codes.
• A provider's site can be certified as EHR-S, even if the EHR software has not been approved as EHR-C or EHR-M. If a site uses an EHR-C or EHR-M, then it is certified as an EHR-S. The converse, however, is not true: EHR-S does not confer -M or -C certification status onto the software in use.
• CCHIT testing will begin in September of 2009. There will be no freestanding certification for 2009-2010. All testing will be geared toward the ARRA requirements for the upcoming 2011-2012 period. In other words, there will be no maintenance of any old CCHIT certification. (Click here for more on ARRA timing.)

If you have additional questions, you can email dwilson@cchit.org, me, or you can submit your comment below.

Complete CCHIT Presentation slide show available here.

CCHIT Hosts "Town Call" Web Conference June 16 & 17

Tired of seeming complacent? Well, here's a chance to make yourself heard:

CCHIT to Propose New Paths to Certification

CCHIT has announced two Town Call web conferences on June 16 and 17 to gather stakeholder input on new paths to certification of electronic health record (EHR) technologies, with the goal of supporting more rapid, widespread adoption and meaningful use under the American Recovery and Reinvestment Act of 2009 (ARRA).

To join the calls:

Tuesday, Jun 16, 2009 1 PM EDT / 10 AM PDT
“New Paths to Certification: Dialog with the Open Source Community”
Dial-In Number: (866) 900-5706
Conference ID: 15249954

Wednesday, Jun 17, 2009 11 AM EDT / 8 AM PDT
“New Paths to Certification”
Dial-In Number: (866) 900-5706
Conference ID: 15316708

For more information, see CCHIT Town Calls.

Be sure to tune in!

CCHIT: Docs, What Matters to You?

Few credible articles begin with sweeping generalizations, but here I go (again): Doctors are acting as mere bystanders while regulatory groups -- for whom physician's needs are not paramount -- decide the future of electronic medical records. And the world. (How's that for sweeping?)

But, seriously, here's what's been going on: Docs receive pronouncements from the government, or other organizations like CCHIT, that will not only determine the fate of health care IT, but which will radically influence their day-to-day lives as medical practitioners. In the meantime, there's a lot of fretting, twitching, Googling, and conjecturing about what is to come. It's an insidious kind of self-disenfranchisement: doctors proactively (and rightfully) strain to listen to the cacophony of voices that have something to say about EMR, but are then reluctant to disagree with what they're hearing. And most of the time these voices do not address or accommodate the specific needs of ophthalmologists -- the ones who will actually have to come in contact with the new technology.

Docs, it's time to take matters into your own hands!

Okay, so I work for an EMR company. If you're a doc, there are probably some trust issues here. But, in all seriousness, it's become apparent to my colleagues and me that, without fail, the issues that concern doctors about electronic health records do not align with the issues prioritized by the higher ups.

And why should they? Apples and oranges, folks. Doctors want an EMR that will work for them: something that is fast, usable and will not compromise their work flow or productivity. In turn, EMR vendors are working to develop products that will respond, specifically, to these challenges.

The government, on the other hand, presumes the blanket success of the EMR industry to be a foregone conclusion. As such, health care higher-ups have preemptively -- and prematurely -- devoted their efforts to the regulation and proliferation of the industry.

But -- what industry? C'mon.

Consider CCHIT-certification. Nearly all stipulated criteria thus far have revolved around issues external to individual practices -- issues like auditing or interconnectivity. There's nothing inherently bad about tackling these issues, but it's a total cart-before-the-horse scenario. The timeline has been curiously inverted, such that less-pressing issues garner precedence over other measures that would ensure usability.

Take, for instance, the requirement that EMRs support DICOM images. Fine. It's something that, if uniformly adopted, would foster standardization and, eventually, interconnectivity. The problem is: almost no (or at least, very few) ophthlamic machines create DICOM images. There's no so-called "community network" to move these images around in. So why, then, make this a pressing issue for 2009?

The need for more doctor involvement in the regulation of EMR is clear. How can you get the ball rolling? Write to ASCRS. Write to AAO. It's at least a start. Make sure that your interests are being met. Create pressure so that the issues that matter in the exam room (speed, interoperability with practice management systems, etc.) are prioritized.

EMR is still in its infancy. In order to serve doctors and to succeed as an industry, we should be most concerned with enhancing and streamlining actual usage. Of course, IO Practiceware believes deeply in the importance of interconnectivity with other practices -- but it should be Stage 2, as opposed to Stage 1, of the CCHIT certification process.

Stage 1: Let's make it happen.

--FR

Email the author

Squeaky wheels seek CCHIT oil

CCHIT's timeline for EMR certification excludes ophthalmology-specific EMRs like IO Practiceware until the year 2011. While we in the Eye Care community have an overwhelming urge to go Chuck Norris on CCHIT, we're going to first try peaceful resistance.

If you believe in the value of specialty-specific EMRs, make your voice heard! Post comments below.

To start the dialogue, here is a letter from Gregory Leopold, CEO of IO Practiceware:

Some of the most innovative EMRs are specialty-specific. This is certainly true in ophthalmology. While it may be self-serving to say so, it is true that non-specialty specific EMR have generally failed to supply ophthalmology practices with the tools they need to record their exams properly and cost effectively. The American Academy of Ophthalmology has been working with a group of ophthalmology-specific EMR companies to develop scripts for CCHIT certification for ophthalmology-specific EMR vendors. The work on these scripts has been completed and they could be used immediately to certify ophthalmology specific EMR companies.

While we appreciate CCHIT’s willingness to work with us in this area, the timeline for completion of the CCHIT certification process for eye care – which is currently set for 2011 – is unacceptable. Other EMR vendors in the AAO sponsored group share my concern and disquietude.

It is crucial that the timeline be moved to 2009 – or that some sort of arrangements are made for ophthalmology-specific EMR companies to receive some sort of “in progress” certification that allows us to participate in a marketplace that increasingly shuts out non-CCHIT certified products.

Either let us in now or tell the world that it’s OK for us to be “in the process”. It would be a great disservice to the cause of EMR if CCHIT were to drive some of the most innovative EMR companies out of business because it could not certify them promptly.

If our respectful protestations don't get CCHIT's attention, we may have to resort to Article B: a diatribe of semi-vulgar, though pun-obscured expletives entitled, "Cut the *BULLCCHIT*" (stay tuned).