Dear Dr. Blumenthal:

In the 8 months since you became National Coordinator for Health Information Technology, you have achieved a great deal.

• Your HIT Policy Committee has drafted criteria describing the Meaningful Use of electronic health records (EHRs).

• Your HIT Standards Committee has begun to articulate an interoperability framework that should support EHR cross-talk and data exchange which will unlock the potential of EHRs as envisioned in the ARRA legislation.

• You have begun establishing a support system to enable the rapid, national expansion of HIT, which includes Regional Extension Centers and an army of newly-trained HIT workers.

• You set aside funds for Beacon Communities which will serve as proving grounds for your objectives, and started a blog which has generated thoughtful discourse.

In short, you’ve begun building a robust foundation that just might be able to support your efforts to wire the entire US health care system. That is remarkable!

So I have just one question. Do you think you are going fast enough?

After all, the 8 months you've been at the job represents nearly half the total time allotted to you by law to get things tied down and ready to roll by January 1, 2011, the date when HITECH Bonanza Days begin.

I don’t know how you would answer this question, because I haven’t been able to find too much information regarding ONC roll-out schedules and interim critical path dates that need to be hit so that you can meet that deadline.

I am sure though, that there’s still a lot to do, arguably much more than you've accomplished to date. And most of the remaining work involves program implementation, which tends to be more unpredictable and error-prone than the planning and resourcing exercises you’ve undertaken so far.

I understand that you’ll be releasing draft Meaningful Use criteria by month’s end, and that a mandated public discussion period will delay finalization of these criteria until spring (I believe these were originally supposed to be finalized by the end of this year).

But you have not yet published guidelines for agencies wishing to help HHS certify EHRs, nor described the process you will use to approve them. I worry that only 2 agencies have declared interest (publicly) in serving in this capacity: Drummond Group and CCHIT. With 200 EHR vendors soon to be clamoring for certification, that doesn’t sound like enough.

And these agencies won’t be able to start work until May the earliest, given the delay in finalizing Meaningful Use criteria.

As for the certification agencies themselves, they're going to need time to hire and train staff. And of course, none of them will have experience with the new certification process, so there are bound to be glitches as the process unfolds. How long will it take to certify one EHR? How many EHRs can be certified simultaneously? Which EHR vendors get to go first? Can you guarantee that every EHR vendor that wants to get reviewed by year end will get a shot?

There are similarly vexing challenges for the Regional Extension Centers, most of which haven’t even applied yet to serve in this capacity. They too will have to be approved, staff up, put processes in place, and get them right the first time if they are to be useful to providers who want to use their services before the end of next year.

I’m sure you’ve got all this worked out. Somewhere on your desk there is a timeline. And you’ve identified the critical interim deadlines you will have to nail in order to get where you need to be just over a year from now. Would you consider sharing this information with me and other interested parties?

Thank you,

Glenn Laffel MD, PhD
Sr. Vice President, Clinical Affairs, Practice Fusion

Glenn Laffel, MD, blogs regularly at Practice Fusion's EHR Bloggers.