Last week I spoke with Mark Leavitt, the CEO of CCHIT, about his best thinking regarding certification in a post-ARRA world.
In the past there have been 3 groups who have requested improvements to existing certification criteria:
1. Self developers who achieve a high degree of functionality through continuous improvement of home built software
2. The Open Source community
3. The Health 2.0/iPhone as application platform/multiple thin web-application combined to provide EHR-Lite functionality community
CCHIT held 2 Town Halls, each with 500 people, to publicly discuss a new approach to certification.
Mark's slides are available online
The New path to certification has three branches:
EHR-C The Certification of a Comprehensive EHR. This is what has been done to date. The product itself is certified, not the specific implementation at a specific site. EHR-C products should be able to meet all meaningful use criteria if implemented properly. The cost to the vendor for certification is $30,000-50,000 per product. EHR-C is for providers who seek maximal assurance of EHR compliance and capabilities.
EHR-M The Certification of a Module such as e-prescribing, lab ordering/resulting, clinical charting and data exchange. A clinician could assemble multiple modules and be certified regarding the specific functions they perform. Integration of data between modules is the clinician's responsibility. Meaningful use may be possible, but depends upon how the modules are used together. The cost to the vendor for certification is $5000-$35,000 per module. EHR-M is for providers who prefer to integrate technologies from multiple certified sources.
EHR-S The Certification of Site for the functionality that can be achieved using the software installed there. A screen capture function is used to document capabilities and this capture will be reviewed by an expert remotely. The cost is $150-300 per licensed provider. EHR-S is for providers who self- develop or assemble EHRs from non-certified sources.
In addition to these three paths, “version lockdown” is no longer needed or relevant. For EHR-C and EHR-Mcertifications, updated or enhanced versions of a code base would inherit certified status without need for CCHIT approval. For EHR-S sites, updates or enhancements would not require recertification.
I've heard a great deal of positive feedback about this new approach. The work of CCHIT to enhance its approach, the work of the HIT Standards Committee to define the certification criteria needed for meaningful use, and the work of the HIT Policy Committee to review certification in general will result in a comprehensive certification plan aligned with ARRA by the end of of 2009.
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