Patty Enrado, Contributing Editor

Long before ARRA, more than five years ago, the University of California San Francisco (UCSF) Medical Center began a $50 million electronic medical record initiative. This past summer, UCSF reportedly wrote off a third of that cost and scrapped its contract with the EMR vendor. The EMR system reportedly had technical difficulties that never enabled it to be fully functional. Undeterred, UCSF is forging ahead with its goal of digitizing its patient records, which says a lot about its faith in EMRs.

UCSF Medical Center isn’t the first healthcare system to have a costly, disastrous experience, and it won’t be the last. Industry stakeholders, however, need to work together to ensure that the number of failures dwindle significantly.

The most important thing that the EHR/EMR market can do for itself is to be transparent. If there is no transparency, how can healthcare systems perform accurate due diligence? There’s a business reason for non-disclosure clauses in sales contracts, which prevent purchasers from reporting problems with the health IT vendor or their products, and “hold harmless” clauses, which exempt vendors from any liability. It may guarantee a risk-free business environment for the health IT vendor, but it hurts the EMR market and eventually hurts the health IT vendor’s reputation. Clinicians and healthcare organization executives may be obligated to remain silent about the product and/or the vendor’s problems, but they will talk informally to their counterparts in other healthcare organizations. You’ve heard the complaints. You know which health IT companies did what to whom.

Transparency need not be the enemy of health IT companies if they have solid products and customer support. For those that have had problems - and I’m not saying they have bad products or customer support - it’s a business imperative to fix those problems. There are less-expensive, more flexible EMR solutions that have come into the market in the last year. There will be other UCSF Medical Centers that cut off their legacy vendor and start anew.

There are some in the industry who say so long as the federal stimulus incentives help subsidize the purchase of legacy systems the problems will continue. University of Pennsylvania sociologist Ross Koppel believes the federal government should have put that money to use by developing “more usable and more responsible software.” I think that route would have been successful as a first step, though I still believe in the incentives. There are some who believe the federal government should regulate the EMR industry. If that sounds odious, then perhaps the EMR industry ought to regulate itself.

As for healthcare providers, they need to understand the enormity of the task. What I mean is that they need to not only put up the cash for the initiative but dedicate human resources to the initiative. Dedicate a team, if that is what is required.

I’d be remiss not to mention that for every UCSF there is a UPMC (University of Pittsburgh Medical Center) - large healthcare systems that have successfully implemented big-budget EMRs and are reaping administrative and clinical benefits. The problem is there aren’t enough of them. And that’s why there is hesitation among healthcare systems. As an industry, let’s try to increase those success stories.

Above article published on http://www.healthcareitnews.com/blog/how-healthcare-industry-can-increase-number-successful-ehremr-initiatives

By Joseph Conn / HITS staff writer

The Certification Commission for Health Information Technology is adopting a two-tier system of testing and certifying IT systems.

In a conference call with vendors and developers of health IT systems Thursday, CCHIT Chairman Mark Leavitt announced the not-for-profit organization’s new testing program, as the group readies itself for the new realities of the healthcare IT market since passage of the American Recovery and Reinvestment Act of 2009.

One testing and certification program, dubbed Preliminary ARRA 2011 Certification, will specifically test for compliance with what is expected to be—at least initially—a fairly limited set of criteria that HHS and the CMS will use to determine eligibility by hospitals and office-based physicians for an estimated $34 billion in federal subsidy payments for the purchase of EHRs under the stimulus law.

The other, the so-called CCHIT Certified 2011 testing program, will use an elaborate set of about 300 criteria, primarily developed by the organization since its founding, that will closely resemble previous CCHIT testing and certification programs. The core CCHIT criteria will be tweaked to ensure systems that pass muster for its more advanced testing program also will meet ARRA requirements.

When it began testing IT systems in 2006, and on through 2008, CCHIT had offered just one, gold-standard set of criteria for each type of EHR system it tested—ambulatory EHRs or inpatient EHRs, for example.

But by April, CCHIT announced it would halt further testing to adapt its systems to accommodate the stimulus law criteria, development of which remains a work in progress. At the time of the announcement, Leavitt said the organization would keep its full-featured certification program, but would add two new testing and certification regimes scaled down to meet the minimum requirements of the stimulus law.

One new program would have tested IT systems by “module” against the new criteria under the recovery act, which requires providers to put “certified” EHR systems to “meaningful use” in order to qualify for federal subsidy payments. The proposed new modular approach was expected to appeal to some physician office practices and, more commonly, to hospitals, that want to piece together a comprehensive IT system from component parts produced by multiple IT vendors.

The other new CCHIT regime would have offered “on-site” testing and certification of EHR systems—again, against the less stringent stimulus law criteria with an eye toward qualifying for federal subsidies. This form of testing would have been conducted on systems installed at physician offices or hospitals. It was an approach targeted to appeal to providers who have developed their own EHRs or planned to assemble an EHR from noncertified sources, and to the open source development community, according to CCHIT.

According to Leavitt Thursday, CCHIT’s testing scheme will be modified again, but only somewhat. While site certification has been dropped as a certification scheme in and of itself, “site certification is still there,” Leavitt said. “In Preliminary ARRA Certification 2011, you can get a product or a site certified.”

Leavitt said it’s unclear whether providers adopting EHRs that have passed the test under the more rigorous CCHIT Certified 2011 program would want on-site certification, but if there is demand for the service, CCHIT will provide it.

Starting in June and running through its latest report in August, the HIT Policy Committee, which was created under the recovery act, has issued three sets of recommended definitions of meaningful use. Some of those recommendations have been controversial. To have market relevance, however, any program of certification of EHR systems that CCHIT develops must take those meaningful use standards into consideration to ensure that certified systems will enable providers to meet meaningful use standards and qualify for federal subsidies. The meaningful use standards, ultimately, will be developed by the CMS, which is tasked with running the bulk of the EHR subsidy program through Medicare and Medicaid.

In addition, CCHIT has to keep an eye on the Office of the National Coordinator for Health Information Technology at HHS, which, on behalf of the HHS secretary, will issue its own certification criteria for EHR systems, since, to qualify for subsidies under the stimulus law, providers also have to use “certified” EHR systems. Leavitt said CCHIT is forecasting ONC will issue its final rule on certification standards by Dec. 31 this year and that they probably will be the same or perhaps even less stringent than the recommendations the HIT Standards Committee made to ONC in August.

“We believe the final requirements will be the same as or less stringent that the current recommendations,” Leavitt said.

Both CCHIT testing and certification programs will open for vendor applications Oct. 7. Duration of certification is expected to run though Dec. 31, 2012, when certification criteria under the ARRA are expected to be ratcheted up, becoming both more numerous and more stringent.

Fees for certifying systems will vary with the certification scheme and the product, according to CCHIT Executive Director Alisa Ray. Under the CCHIT Certified 2011 program, the fee to a vendor to certify an EHR is $37,000 for either an ambulatory-care or an emergency department system, $49,000 for an inpatient system and $18,000 for an electronic prescribing system. Annual renewal costs are $9,000 for each, except e-prescribing, which is $7,000.

For Preliminary ARRA 2011 Certification, costs are pegged to the number of modules being tested, with fees set at $6,000 for one or two modules, $10,000 for three to five, $15,000 for six to 10, $24,000 for 11 to 20 and $33,000 for more than 20. Annual updates range from $1,000 to $5,000.

According to EHR vendor representative Justin Barnes, who listened in on Thursday’s CCHIT call, CCHIT probably has hit on the right strategy by launching its new testing and certification program this fall, based on an educated guess at what the government’s criteria might be, but before the final rules are published. Barnes is the chairman of the Electronic Health Record Association, and a vice president overseeing corporate development, marketing and government affairs for Greenway Medical Technologies, a Carrolton, Ga.-based EHR system developer.

“The detail that we have right now around meaningful use, you really can’t write a product to it,” Barnes said. “The interim final rule will come down at the end of this year. I think that will be a fairly close definition that we could follow. I think it will be plenty to work off of. The certification process, I believe, will be tweaked a little bit as well.”

Barnes said he hopes Leavitt is right when he predicts the ONC and the CMS will not vary too far from the current recommendations in writing the preliminary rules. He also said he hopes they don’t dally in unveiling their preliminary rules so everyone involved, both EHR vendors and users, have time enough to act.

“If there are any discrepancies, that could pose an interest to some people if you have to do heavy product development,” Barnes said. “It takes 12-plus months for the product cycle to add functionality on the ambulatory side and 18-plus months on the inpatient side. There is a word of caution here. That’s why we’ve urged ONC to move on this as fast as they can.”

Above article published on

http://www.modernhealthcare.com/article/20090904/REG/309049989/0

Time to take a look at the costs associated with the 2011 CCHIT Certification programs. If you’re not sure which programs I’m talking about, you need to go read my post about Preliminary ARRA Certified 2011 and CCHIT Certified 2011.

The following are the costs that CCHIT plans to charge for their 2011 EHR certifications:

CCHIT Certified 2011 Ambulatory EHR – $37,000 with a $9,000 annual renewal

CCHIT Certified 2011 Inpatient EHR – $49,000 with a $9,000 annual renewal

CCHIT Certified 2011 Emergency Department – $37,000 with a $9,000 annual renewal

CCHIT Certified 2011 ePrescribing – $18,000 with a $9,000 annual renewal

Preliminary ARRA Certified 2011 1-2 modules – $6,000 with a $1,000 annual renewal

Preliminary ARRA Certified 2011 3-5 modules – $10,000 with a $2,000 annual renewal

Preliminary ARRA Certified 2011 6-10 modules – $15,000 with a $3,000 annual renewal

Preliminary ARRA Certified 2011 11-20 modules – $24,000 with a $4,000 annual renewal

Preliminary ARRA Certified 2011 >20 modules – $33,000 with a $5,000 annual renewal

*These are estimates subject to final approval

Of course, the ones that matter most are the CCHIT Certified 2011 Ambulatory EHR for $37,000 and the Preliminary ARRA Certified 2011 >20 modules for $33,000. Why? These are the two certifications that most people care about. If you’re an EHR vendor, then you’re going to want to do one of these two options (Assuming you’re going to go with CCHIT certification. More on that later.). These are the two options which should eventually be recognized as the certified EHR requirement for the ARRA EHR stimulus money.

Which CCHIT Certification Should I Do?

The question an EHR vendor has to make is which of these two certifications make sense. Will having CCHIT Certified 2011 help you to sell more EHR software than just being Preliminary ARRA Certified? I’m guessing that it probably won’t. Most people I’ve seen really just want to make sure they get the ARRA stimulus money to pay for their EHR. Plus, with either certification you’ll be able to honestly tell a clinic that you have a “certified EHR.” Most doctors won’t know or care about the difference in the certification types.

Many might think that it’s only a $4,000 difference between the Preliminary ARRA 2011 certification and the CCHIT Certified 2011 so why not just get the later. It is interesting that the costs are so close to each other. However, remember that this isn’t the only cost associated with becoming certified. One EMR vendor I talked to put the software development costs to become CCHIT Certified in the six figures. We won’t know for sure until CCHIT publishes the final certification criteria, but I project that the CCHIT Certified requirements will number close to 300 while the Preliminary ARRA requirements will be close to 100. That’s a huge difference in development costs to meet 200 more requirements which your customers may or may not find useful.

Some might use the CCHIT Certified 2011 to try and assure potential buyers that they’ll have a more successful EMR implementation because of this certification. Many might actually believe it, but unfortunately there’s no evidence to prove this is actually the case.

EHR vendors should also be aware that CCHIT is looking at doing a site certification as well. This might be a better option for some EHR vendors who work with people who have few people actually interested in the EHR stimulus money.

Other EHR Certification Options Beyond CCHIT

It’s still too early to know for sure if other EHR certifying bodies are going to be created to handle the HHS certification requirements for EHR. However, I’m willing to bet that at least a couple will be created.

Basically, CCHIT has set the price for EHR ARRA certification at $33,000 with a $5,000 annual renewal. I could be wrong, but that seems like a lot of money to certify a piece of software. I’m guessing that some entrepreneurial folks will find a way to do it for cheaper. Could you certify 100 EMR vendors for less than $3.3 million? We’ll see what ONC/NIST requires from a certification organization, but seems like a pretty nice business model to me.

For EMR vendors, this is important because competition amongst certifying bodies will most certainly drive the cost of EMR certification down. Then, the PR battle between CCHIT and the new certifying bodies will begin. Basically, this could be really interesting to watch if someone else decides to join the EHR certifying fray.

Above article published on

http://www.emrandhipaa.com/emr-and-hipaa/2009/09/14/cost-of-new-cchit-ehr-certifications/

Bernie Monegain, Editor

The Certification Commission for healthcare information technology has announced that it will launch new certification programs on Oct. 7.

CCHIT officials announced Tuesday they will offer an updated comprehensive electronic health record certification program, called CCHIT Certified 2011, as well as a modular certification program – called Preliminary ARRA 2011 – that is limited to the standards for qualifying EHR technology under the American Recovery and Reinvestment Act (ARRA).

“There is a high risk that providers would not achieve meaningful use to qualify for the ARRA incentives in 2011 and 2012 if they wait until late 2010 to implement certified EHR systems and technologies,” said Mark Leavitt, MD, chairman of the commission. “On our town call Sept. 3, which drew over 700 attendees, we received valuable feedback on our proposed programs and a strong indication of interest from health IT companies and developers in applying for timely certification under these programs.”

Leavitt said the commission has followed the recommendations of the health information technology advisory committees to the Office of the National Coordinator (ONC) and believes there is sufficient information to offer preliminary ARRA certification.

HHS criteria and standards are slated for publication by the end of 2009. Final rules on meaningful use are expected in the spring of 2010.

If that process results in the introduction of new requirements, the commission will offer vendors with preliminary certifications an incremental inspection at no additional fee to bring their certifications into alignment with the final rules.

The commission’s certification materials, including criteria, test scripts and certification policies for both programs, will be published Sept. 24 on the CCHIT Web site. Applications for certification will open online on Oct. 7.

To help HIT companies and developers to make 2011-certified EHR technology available to providers, the commission is offering a workshop in the Chicago area on Oct. 1. The workshop, Get Certified 2011, is designed to orient companies and developers to the new certification process and help them use the new certification program tools effectively.

Above article published on

http://www.healthcareitnews.com/news/cchit-poised-begin-new-certification-programs

Bernie Monegain, Editor

The Healthcare Information Technology Standards Panel has approved new interoperability specifications for electronic health records, data exchange and architecture that align with the federal government’s stimulus package for healthcare IT.

“HITSP has transformed its existing work to be completely aligned with the American Recovery and Reinvestment Act of 2009 (ARRA),” said John Halamka, MD, chairman of the panel. “These approved specifications represent the culmination of some 90 days and 13,000 hours of volunteer effort to meet the requirements of this landmark piece of legislation.”

Approved by the panel at its July 8 meeting are:

• HITSP/IS107 – Electronic Health Record (EHR)-centric Interoperability Specification
• HITSP/TN904 – Exchange Architecture and Harmonization Framework Technical Note
• HITSP/TN903 – Data Architecture Technical Note
• HITSP/SC108-SC116 – Service Collaborations

On April 7, HITSP began to leverage its 13 Interoperability Specifications (IS) and 60 related constructs to consolidate all information exchanges that involve an electronic health record system. The work was organized around ARRA requirements, specifically for the HITECH section.

HITSP formed temporary “tiger” teams to map EHR-related information exchanges to ARRA requirements. These teams identified “capabilities” – specific, implementable business services that use existing HITSP constructs to define and specify interoperable information exchanges. For example, the Communicate Hospital Prescriptions Capability addresses the interoperability requirements needed to support electronic prescribing for inpatient prescription orders.

Twenty-six capabilities have been defined that support the workflow, information content, infrastructure and security and privacy requirements laid out in the ARRA legislation.

HITSP capabilities also address the “meaningful use” of health information technologies. Last week, the Office of the National Coordinator for Health Information Technology (ONC)’s Health IT Policy Committee recommended a definition of meaningful use that names seven electronic exchanges to be required by 2011: e-prescribing, lab results, clinical data summaries (problems, medications, allergies, laboratory reports) from provider to provider, biosurveillance, immunization registries, public health and quality measurement.

“HITSP capabilities provide specific transactions supporting all seven of these required exchanges and others that will be needed in 2011, 2013 and beyond,” said Halamka. “Going forward, the panel will continue to work closely with ONC to respond to ARRA and meaningful use requirements that can be addressed by EHR systems.”

Above article published on

http://www.healthcareitnews.com/news/standards-panel-aligns-interoperability-specs-arra

By Steven Kraus, DC, DIBCN, CCSP, FASA

This spring, I traveled extensively to Washington, D.C., for a variety of reasons, mainly to advocate on behalf of chiropractic physicians as our government initiates massive health care reform efforts.

I attended the HL-7 Conference, which is an invitation-only gathering of health care officials dedicated to setting the programming standards for health information exchanges (HIEs) and standards for required data for electronic health records (EHRs).

The conference, sponsored by the Agency for Healthcare Research and Quality, has historically been limited to hospital and allopathic audiences. This year’s group was expanded for the first time to include other health care experts, and I was the designee from the chiropractic profession. My goal and commitment to the profession remains clear: I want to ensure that the interests of chiropractic physicians are considered in any and all discussions related to policy-making for health care information technology. And in the case of HL-7, chiropractic participation is critical so the concerns of our profession with regard to the development of HIEs will be heard.

The catalyst for broadening this conference audience was presumably the economic stimulus package, formally known as the American Recovery and Reinvestment Act (ARRA) of 2009, which includes more than $19 billion to fund the introduction of electronic health records in every physician office in America. The section of the ARRA that deals specifically with this appropriation is the HITECH Act, which outlines the requirements for funding eligibility. To be qualified for incentive payments offered through the legislation, doctors must adopt qualified EHRs that have the functionality to communicate with HIEs, making the standards by which HIEs are governed extremely important and elevating the prominence of interfacing capabilities with other systems.

I’ll discuss more about the requirements for incentive payments later in this article, but the main reason I share my involvement with the creation of health care information technology standards is to demonstrate how the general health care industry is finally opening its arms to the chiropractic profession. We’ve been dancing on the periphery for years, but finally, we are gaining recognition as an essential component of health care delivery and actively participating in these important discussions regarding policy, standards and reform.

Reform = Collaboration + Technology

Speaking of reform, during that same visit to D.C., I also met with Sen. Tom Harkin’s staffers as well as government relations personnel from the American Chiropractic Association to discuss the evolving model of reform for our health care system. As I shared in a previous column, elements of several models are under consideration including the Medical Home Model, which relies heavily on collaboration among health care professionals in order to improve the quality of patient care. Harkin and several of his colleagues are outlining a comprehensive national health care reform plan we can expect to be introduced later this year.

The cornerstone of that plan will be collaboration, and the framework to support collaboration will be driven by technology. While many uncertainties still remain, these two elements are certain. And with collaboration at the forefront, Harkin and others understand that chiropractic physicians and other nonmedical providers are an integral element of national reform. The reform movement is committed to supporting true wellness, something doctors of chiropractic have been preaching for years.

Now it’s time for us to rise to the occasion and continue walking our talk, while we have people watching us and listening. The first step in walking the talk is adopting EHRs. Why? Because technology will create the path to collaboration by assisting case management through registries, database queries, instant access to information, alerts and reminders, and all the related tools the digital age provides us. We need technology to form the health care teams that will improve patient care for every American.

With the anticipated health care reform model so heavily reliant on technology, those who do not adopt an EHR will be left out of the health care framework. In fact, the government is emphasizing the critical role an EHR will play in successful reform so heavily that it is funding the digital transition in its entirety. In order to adapt to the new model of health care, we must adopt an EHR. Since the government will pay for our EHR (up to $44,000 for each physician), we’re simply being asked to fund the energy and effort to implement it. Seems like more than a fair deal to me.

How to Access Your $44,000 Incentive

As I mentioned earlier, the process to fund your EHR is structured through incentive payments to physicians who adopt such systems. Not all health care professionals will be eligible for incentive payments, but doctors of chiropractic are an approved group, as they are covered by the Social Security code defining physicians, which the ARRA is using as its definition.

Two major areas will be evaluated by our government when determining payment approvals. First, the EHR system must be qualified, and second, the system must be used meaningfully by the chiropractic physician. A qualified EHR system must have the capacity to handle patient demographics and clinical health information, and also must have clinic management capabilities, as outlined by the entity that certifies qualified EHR. Only a certified EHR system will be eligible. The certifying body has not yet been announced, but the industry anticipates that the Certification Commission for Healthcare Information Technology (CCHIT) will be the likely choice since it was approved in 2006 by the government’s Office of the National Coordinator of Health Care Information Technology and Medicare to manage such efforts.

The second requirement, “meaningful use,” is determined by three important measures: (1) connectivity to health information exchanges and other EHR systems so they can share information when authorized by the patient; (2) regular reporting of quality measures to the Centers for Medicare & Medicaid Services (CMS), including capturing outcome assessments and performance of pain assessments; and (3) e-prescribing capability. Because we don’t have prescribing privileges, it is unknown at this time whether this will remain a requirement for doctors of chiropractic. With regard to reporting requirements, the general structure of the plan suggests that reporting of quality measures will likely be managed by the PQRI (Physicians’ Quality Reporting Initiative), a standardized mechanism that already exists.

As much as $44,000 can be paid as an incentive to a doctor for investing in a qualified EHR system. And in clinics with multiple physicians, each physician can qualify for the incentives, as long as the aforementioned terms are met. And while we know that CMS will be involved, its specific role is still being evaluated with regard to reporting and eligibility requirements for doctors participating in the incentive program. For example, minimum billing thresholds such as an annual $25,000 in covered services to CMS are being considered in order to be eligible for the incentive payments. However, there is some discussion on consideration for proportionate payments if the threshold is not met. So, if you average 16 Medicare patient visits a week, you would likely qualify. I will follow-up on this issue in a future article once the policies and standards relating to the Department of Health and Human Services and Medicare have been formally released.

To access the full $44,000, which is paid through Medicare in stages (four annual installments starting in 2011), the EHR system has to be qualified and used in a meaningful way starting in 2010. To clarify the timing, it is necessary to explain PQRI’s influence on the process. PQRI, which is expected to oversee reporting requirements, currently requires reporting on at least 80 percent of patients. To accommodate this requirement, the EHR system would need to be in use for the majority of the year prior to the first incentive payment, assuming adherence to PQRI standards will be required. Hence, EHR implementation in 2010 is necessary in order to receive an $18,000 first payment in 2011 and maximize the incentives available.

For new users, implementation of an EHR system typically requires 90 days to six months. Given the expectation that meaningful use will be necessary for the better part of 2010 in order to get a 2011 incentive payment, the implementation process for chiropractic physicians should begin promptly in 2009. Those who had the vision to implement a qualified EHR and can demonstrate meaningful use are already eligible for the full incentive payments.

Penalties for Not Transitioning to EHR

The Evolving Health Care Landscape: Technology Front and Center Those who choose not to transition to an EHR system will be penalized beginning 2015 and continuing through 2018. These penalties will be assessed through a reduction in your Medicare claims reimbursement on services billed. To further motivate adoption, some states have already passed laws that mandate EHR use after 2014 in order to attain a license to practice or to renew a license, concurrent with the stimulus plan. With financial and legal ramifications in play, the incentives to adopt an EHR now are enormous.

The Reform Cube

Given the benefits the government is providing chiropractic physicians, it is a wonder that any of us are still waiting to implement EHR. If the financial incentives are not enough motivation, doctors of chiropractic must consider what role they will play in the health care reform cube. Our health care landscape will soon shift to a different model; consider a cube in which quality, cost, and delivery of care through collaboration and access exist at each point, while technology sits squarely in the middle. Technology improves quality by offering reminders, alerts and other assistive techniques; technology lowers costs by reducing duplication of services; and technology improves collaboration and access by providing a mechanism to share patient health information across all providers. All of this allows for a robust clinic management system.

As chiropractic physicians, we strive to improve quality, we seek to reduce costs, and we crave the opportunity to collaborate on the health care team, so the cube is the ideal home for us. When we adopt the proper technology, we gain not only substantial financial support, but also membership in the cube. And isn’t membership what we’ve been asking for from the health care community all these years? This membership is not for the sake of privilege, but for the sake of having other providers refer patients to receive the benefit of chiropractic care, achieve wellness, and experience cost-effective and efficacious care naturally. Accept the invitation now - it won’t be offered again.

Above article published on

http://www.dynamicchiropractic.com/mpacms/dc/article.php?id=53922