Embracing the new CCHIT certifications

A few months ago, CCHIT suffered from what I like to call “angry letter round 1”.

This is were I send a very pointed, ultimatum letter to an organization of the general form “your are hurting my community, stop it or else”. Personally I find that about %50 of organizations respond positively and about %50 do not.

I am happy to say that Mark, Dennis and the other members of the CCHIT team have won my respect and appreciation with how they have taken a 90 degree turn from being an organization that was largely ignorant regarding the health FOSS movement to one that listened and engaged carefully, and has now come back with a plan for certification that I personally, and from what I can tell the FOSS community generally, can embrace.

This post is me doing that. At this stage I am comfortable recommending (to whoever is making the decision) that CCHIT be allowed to be one organization allowed to certify for ARRA funding, under their new EHR-C/EHR-M/EHR-S certification model.

Specifically, I am talking about the new site level certification program. Here is a cut and paste from the CCHIT townhall pdf regarding EHR-S site certification.

Certification Program Concepts for EHR Sites (EHR-S)

  • Definition: Certified EHR-S sites have developed or assembled EHR technologies that comply with Federal standards and enable them to meet all Meaningful Use Objectives.
  • Provider applicability: 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.
  • Certification requirements: Functionality available (regardless of deployment model) that enables providers to comply with applicable Federal standards, implement adequate security practices, and meet Meaningful Use Objectives.
  • Inspection methods: Virtual Site Visit technology with offline inspector review and follow-up correspondence.
  • Cost range: ~$150 – 300 per licensed provider (ambulatory); hospital pricing model TBD. Scholarships for eligible providers (FQHC, underserved population, critical access, etc) if grants can be obtained.

This along with the fact that all of the new certification programs will not require re-certification for minor software revisions, means that there is a clear path for FOSS adoption along with ARRA funding assuming CCHIT certification is endorsed.

Of course, as Dr. Billings points out, there are a lot of details to work out. However, unlike other critics of CCHIT, I have never felt CCHIT to  be duplicitous, rather they were one of the many groups who were trapped in a way of thinking that I disagree with.  Now that CCHIT understands how our community frames the EHR problem, they have done a good job creating a certification that can work for us.

This is a huge relief. I was afraid that our small community 501c3 Liberty Health Software Foundation, (LibertyHSF)was going to need to learn how to certify, create a standard to certify against and then get ourselves approved by the ARRA powers before the end of the year. Not good.

I would like to thank the FOSS community members who helped make this possible, especially Dennis Wilson, who served as a bridge between us and CCHIT. Thanks to Mark and everyone else at CCHIT who made such drastic rethinking of your core business in such a short time, we appreciate it!

I am now serving in the role as the director of LibertyHSF, and I need to start being careful to note that this is my personal opinion, and not the official opinion of LibertyHSF. I think LibertyHSF will probably have the same position, but I need to have a community vote on that before we will put something up on libertyhsf.org. That process takes a little more time to arrange. Still I personally have been one of the most vocal critics of CCHIT on this blog and I thought it appropriate to note that I approve of CCHIT’s most recent actions. (UPDATE 7-13-09 CCHIT has blogged about this post)



6 thoughts on “Embracing the new CCHIT certifications”

  1. Fred, interesting to hear that you are now comfortable with the new CCHIT, three-tiered certification process. Agree with you that CCHIT has certainly made an effort to hear concerns from the market including yourself, other smaller vendors & physicians with RYO solutions. I commend them for such outreach.

    Unfortunately, I can not share your support of CCHIT as a certifying org (and this is not just CCHIT, but any certification org that wishes to place a heavy hand on the market) as I still believe the overall CCHIT certification process to be too complex, burdensome and to date has not shown any impact on EHR adoption or improved interoperability for data sharing and care coordination. Yes, it is not completely CCHIT’s fault as interop depends on how a solution is ultimately configured and implemented, but is that not the point – CCHIT and its certification process, at the end of the day, does not guarantee interop, which leads to the conclusion, so why bother?

    And please, don’t even get me started on usability testing.

  2. John,
    I think there can be considerable improvements to the way CCHIT certifies, but they do have a process for change. They are a workgroup driven organization. Before, FOSS was essentially frozen out of the certification process for very fundamental reasons, now I think participants from the FOSS community will be much more common. To discuss your specific complaints, both EHR-S and EHR-M are intended to be much simpler certification models, much close to whatever ARRA ‘meaningful use’ will end of meaning. EHR-C will continue to be large and burdensome for the -people that want that-
    Regarding interoperability, while CCHIT has not done enough, they have created Laika which is probably the most substantial step towards true interoperability, with the possible exception of Mirth and the Connect project. But efforts like that take time.

    Usability is also a good point, and they are considering how to handle usability scoring now. But again, this is a participatory organization. You can volunteer and have a say….


  3. Fred, explain to me please why you agree that $150-300 per provider for EHR-S is such a good idea.

    To me that implies for a 5 user site of a FOSS EHR, CCHIT wants to extract $150-300 from each of those 5 physicians. In which case I have to ask … what are they certifying?

  4. Remember EHR-S is going to be a lot of work for CCHIT. They are going to have to fully automate some relatively complex tests and then provide a standard interface to those tests, that FOSS developers like me are going then write to. Once that has happened, then CCHIT needs to charge on a per doctor basis for the following reasons.

    • It is the only way to be fair to single Docs. To turn your question around, why should it cost more for a single practitioner than the per-doc cost for a group?
    • CCHIT needs to be able to continue to fund the considerable development required to automated these tests. Granted CCHIT will make more money when docs at a site share an EHR, but compared to the costs of EHR-C, it is still chump change.
    • It is only a ‘good’ assumption that all 5 docs in a 5 doc practice are using the same software. So CCHIT may be certifying 5 separate EHR systems for the group.
    • There is an upper limit here for the EHR-S model. For instance, if there were a group with 200 providers it might be cheaper to sponsor the EHR-C cert for a project

    Now, what I -am- concerned about it the issue of FTE doctor vs mere user. There are many volunteer clinics that rely on hundreds of doctors to participate once or twice a year. These small clinics would go out of business if they had to treat every user as a doctor under the CCHIT EHR-S certification. In fact such a site might only have 1 FTE doctor per year… it just happens to be made up of 100 different individual docs. But these kinds of issues are the kinds of things that I believe CCHIT will effectively address using their workgroup model as they move forward.


  5. I’m not reading it like that. It reads to me as a virtual visit where someone looks over your shoulder while you demonstrate that the system can meet the functional requirements. No automated suites.

    In your scenario, if there is only 1 FTE where the FTE is using the same software, there can be no reason to ask to certify each user. Certification is for software, and not for users.

    Of course the logical follow on is that if CCHIT gets away with this, they will then want to impose a “drivers license” on each doc, where each doc gets certified to use a particular system – renewable yearly of course. Think of the revenue stream that will bring them!

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