Written by Stevie Davidson Monday, 08 November 2010 21:24

I have to take the time to write about Certification.  I cannot believe still how convoluted this area is when it comes to complete and accurate information that is being disseminated to providers and their staff.  I sat on the phone for an hour with a provider who is near and dear to me, and he was going on about Meaningful Use and I said well guess what? it really doesn't matter because your product isn't certified.  First their was silence, then came the thunder.  Of course I have no mercy because my job is to protect, guide, and educate. So when I hear the level of misinformation coming from a client and I have to argue and spend an hour trying to undo the brainwashing, it is exhausting and painful.  However, I love my docs and practice managers so I have to resolve myself to the fact that education has taken the forefront because this industry is out of control.  Everyone is an expert and my lord I wish everyone would stick to what they know best and let the rest of us do our jobs.  I think everyone is used to my novels by now, and this is going to be a long one. Too much information to share, so grab a cup of coffee or maybe even a glass of something stronger because you are going to need it.  So here we go....

It doesn't matter if you are just looking, about to sign, or already have an EHR in your practice, everything here will apply to you for one reason or another.  Of course catching it before you sign is optimal, but for early adopters you have the power to renegotiate. Plese don't think you don't, because competition is stiff and word of mouth marketing is critical for EHR vendors these days.  

Let's start with the basics and then I will share some interesting things to help protect yourself with regard to certification and the difference between the organizations that certify products.  The Office of the National Coordinator for Health Information Technology (ONC) has appointed three (3) organizations to be ONC-Approved Testing and Certification Bodies (ONC-ATCBs).  The ATCBs certify EHR products for Stage 1 Meaningful Use (MU) only at this point in time. The certification is called ONC-ATCB 2011/2012.  It is the only program that will qualify and Eligible Provider (EP) for their MU payments.  The three (3) organizations are The Certification Commission for Health Information Technology (CCHIT), Drummond Group, Inc., and InfoGard Laboratories.  The ONC has a website that you can go to that has a consolidated list of all the products that are certified and the respective version.  It is called CPHL for Certified HIT Product List.  It is not updated daily, so best practice is to go to each of the ONC-ATCB websites directly and check the products there.  Vendors have a choice of where to get certified, however I have to tell you that CCHIT has been doing a comprehensive certification track since 2006 before ARRA and HITECH hit the scene, and honestly the others don't have much credibility with me. They are cheaper than CCHIT from what vendors tell me, but many products are doing Drummond to get on the map quickly and then paying for CCHIT anyway .  I think vendors know and I agree that there is an A and B list, and it is always good to be safe than sorry.  InfoGard?  I have no clue what they are doing.  They haven't listed any products yet  so I guess they are a slow start, which then causes me to raise an eyebrow.

Gotcha Number 1:

Watch for the vendors that plaster CCHIT certified everywhere.  A nationally recognized company that has in-patient, HIE, and ambulatory EHR products is doing just that. Their HIE is certified as modular which means critical functionality isn't there or failed certification, and their ambulatory EHR hasn't been certified since 2007.  What a cluster of misleading information for a provider. Shame on them.  They are speaking everywhere and telling providers, practice managers, and anyone else who will listen they have whatever they need to get them to MU. What a racket.  You need to learn the CCHIT website, read about the different types of certification tracks, and educate yourself.  Beware of vendor idolatry, it will get you every time.

Gotcha Number 2:

So the ONC-ATCBs are required to use the federal government's testing procedures and guess what, they made a big boo boo. They erroneously incorporated the wrong standard to electronically record, modify, retrieve, or submit syndromic surveillance information. Once they realized this they changed the Final Rule. So if it was final before, what does that make it now? In light of this, products that were certified prior to October 13th were not required to get re-tested with the correct standard so you can be left in the cold with not being able to meet a criteria for MU or other initiative that you need.  You need to ask your vendor if they made that switch.  If you didn't sign your contract, don't take their word for it, get it in your contract.  If you are on an EHR, get an addendum to your contract that they did do it and are attesting you will get your MU payments or meeting a different objective you may have.

Gotcha Number 3:

Did you know that if your product is certified, the release that is certified counts?  So if you are on version 4.0, and the vendor gets 5.0 certified you need to upgrade before you start reporting.  If you are not on a version that is certified, you are getting nothing.  Not like you aren't already skeptical about that.  So not only must you watch for certification closely, but make sure they are keeping up on getting their versions certified and they are committed to meeting Stage 2 and Stage 3 of Meaningful Use.  This current testing process is nothing compared to what it will need to be and they are only testing the basics, and you are investing a tremendous amount of money not knowing if they will meet the next rounds of criteria because the Feds seem to care more about increasing the adoption rate.  At what cost?  

The last piece of information I want to give you is it doesn't matter whether you are going for MU reimbursement or not. Understanding what you are buying, and more importantly why you are buying it is the real task at hand.  Understand your needs of why you are adopting.  You can be purchasing right now, waiting a bit if you are not in the market for MU, or you need something a single solution can't give you and you piece a bunch of different certified modules together to get a custom solution.  Just don't go in blind and I see it more and more every day.  Too many listen to the last person they spoke to and then it becomes the gospel.  My goodness just stop the madness.  If I need a specialist for my heart I got to a cardiologist not a car mechanic.  It is the SAME THING. Please do your homework. 

Understand the difference between CCHIT's 2011 Comprehensive Certification Training and the ONC-ATCB 2011/2012 Certificatiion for Meaningful Use.  It is very different, and when looking at products look for the ones that have both.  CCHIT is giving EHR vendors the ONC-ATCB Stage 1 Certification Stamp for free if they go for their comprehensive  2011 certification.  Meeting the feds testing process is very substandard compared to their comprehensive, so make sure you are looking at the products that are doing both.  So at least you know that the product has the punch behind it to get through that criteria and not just the 123's of Stage 1 Meaningful Use with no security or comfort of what happens next.

Dr. Karen Bell who is the Chair of CCHIT has a great blog as well.  Make sure you check this month's out, she does a wonderful job of outlining the core differences between their long-standing comprehensive certification vs. the ONC-ATCB 2011/2012.  I can't apologize for the length of my blogs, but when I do get up here in between my staff I usually have so much to blabber about I can't help myself.  Next time I will speak about Privacy and Security and what my legal expert and I have ready for docs.  Look for that requirement in your MU checklist.  It is a kicker, and no one is speaking about it.  You can be sure I will....Until next time.

Stevie