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)