While the College of Healthcare Information Executives (CHIME) approves of the general concept of ONC's two-stage approach for EHR certification - a temporary and a permanent certification - the healthcare CIO organization has problems with the details of the approach.
CHIME is concerned that the approach continues marketplace instability, given that the industry is still awaiting the final ruling on meaningful use criteria and certification regulations. CHIME is also concerned that this process paves the way for unnecessary product replacement. CHIME has a point.
The organization has some valid recommendations. The temporary certification should be structured in a way that builds on current processes and then dovetails with the permanent process, so getting the temporary certification isn't a wasteful practice.
CHIME puts the responsibility of the certification process squarely on the shoulders of the vendors. It would be interesting to hear from vendors on this issue. A handful already says their products are guaranteed to meeting meaningful use. Should this be the standard? I think it should be. Right now it is the market differentiator, but it should be every vendor's promise and meaningful use should be built into every EHR product. Obviously, IT isn't a core competency for physicians. If we want to drive EHR adoption, vendors should do their part and align product functionality with meaningful use criteria, and take that worry away from physicians.
Vendors should also take responsibility if the certification body that certified their products loses its authority. They need to be given time to have their products recertified. Additionally, if providers continue to demonstrate meaningful use from a product whose certification body has lost its authority, they should not be penalized. The goal is to derive meaningful use, right? If that's the case, don't get bogged down in policy technicalities.
I believe, as CHIME asserts, that vendors should fully disclose which functionalities of their products are certified. They should also fully disclose compatibility issues. To gain trust among physicians and drive adoption, vendors really need to provide transparency in all aspects of their products.
It's also up to vendors to ensure that their individual EHR modules can communicate according to adopted standards and the interoperability of their modules are certified.
The request for clarification on the definition of a self-developed EHR is valid. I don't know how common it is for a physician's office to modify either the entire system or a module. If there's a need to do so for usability's sake, you don't want to take that option away or create more complications for the physicians. It could result in the system not being used to its full potential or not at all.
I agree with CHIME that changes in requirements should coincide with meaningful use evolution or interoperability advances. In other words: Down with expiration dates that have nothing to do with technological innovation or meaningful use evolution, which will bring more value to EHRs.
ONC has a lot to consider before it finalizes the certification process regulations, but CHIME's concerns and recommendations should be high on the priority list of considerations.
Patty Enrado blogs daily at EHRWatch.com.