As the industry waits breathlessly for federal guidance on EMR certification, no organization is closer to the edge of its seat than CCHIT. As such, no individual will be more interested in reading that anticipated document than CCHIT Executive Director Alisa Ray. With the impending resignation of CCHIT Chair Mark Leavitt, and no word on his replacement, Ray will be responsible for leading the ultra-important organization through the choppy waters ahead. To learn more about how CCHIT is operating in today’s hazy climate, healthsystemCIO.com editor Anthony Guerra caught up with Ray.
BOLD STATEMENTS
The more we hear, the more it sounds like there are just more and more delays. So this is going to be later and later in coming.
… we would like things to move along. We’re ready for it, too.
Regarding the providers, they need to move quickly because, if you’re just starting now, boy, that’s a steep staircase to climb — to make your decision and implement in time to qualify. I think that’s what’s really scary to us and to others.
GUERRA: We’re still waiting for information from ONC about where they’re going with certification. What do you know about that, and how much does it impact your work?
RAY: I don’t think we know much more than is publicly available. I mean, we were really expecting this to be part of the rulemaking that came out at the end of the year and then, as you mentioned, ONC said, “Well, it’ll be out shortly or any day now,” and we took that to mean something like January, and now here we are still waiting. And what we’ve heard is that it’s going to be a third piece of rulemaking which means it would be subject to public comment too. The more we hear, the more it sounds like there are just more and more delays. So this is going to be later and later in coming. Our position all along has been it’s a huge hurdle for doctors and hospitals to adopt EHR technology, if they haven’t already, or otherwise just get them qualified for the incentives.
So we don’t have any more information on the timing of that. I will share something with you. We had a town call a couple of weeks ago, the end of January, and we asked the participants their impressions about the status of the rulemaking. Almost half of those respondents said, “We think it will be the fourth quarter or into 2011 before things are really happening.” We hope it’s sooner than that, but that’s some of the sentiment we heard.
GUERRA: No matter what the government has done, it’s my impression you have never taken your foot off the gas. Is that accurate?
RAY: We thought a lot about where meaningful use was headed, it was really ambitious and it’s filled with really good things, but it’s a lot to implement and a lot to implement quickly. If you look at where they are with the rulemaking, they’re looking at some really complicated stuff that’s more downstream around the nuances of meaningful use. We did think that the pieces around getting certifying bodies in place and qualifying the technology were simpler than some of the other nuts they’re trying to crack. So we have worked, as you said, to listen to what’s come out of the Policy Committee, or now the final rules. As an organization, one of the things we do is try to be nimble and adjust quickly. So we’ve tried to keep our programs true to the current thinking in Washington that was available for us, just because we think that’s the right thing to do for the providers and also for the vendors, to also help them communicate with their customers about the status of their development. But we would like things to move along. We’re ready for it, too.
GUERRA: I would imagine you’ll spend some long hours with the document ONC puts out.
RAY: Let me update you on where we are. When the IFR came out in the Federal Register, our staff, along with some of our workgroups, got together quickly and published the gap analysis of the criteria, either from our comprehensive program or the modular program. We’re set to re-launch our programs this Friday and start taking applications again. The gaps and the criteria we’ll publish are now aligned with the new Interim Final Rule and, in fact, we’re calling the programs Interim Final Rule Stage 1 Comprehensive and Interim Final Rule Modular. So we’re keeping the modular and comprehensive things that we introduced in October, but we’ve realigned the criteria to those Interim Final Rules because, as you might know, they become effective a month after they’re published in the Register. It’s not to say they may not change them, but we’ve seen things that have become effective and stayed that way for years.
GUERRA: What are the chances that what comes out about certification throws you a curveball?
RAY: We don’t think there will be new things put in there. It’s harder for them, once things go to comment, to create something new. I think things may fall out based on comments. So that would be an easier problem to solve for vendors that come through. We fully expect there may need to be more incremental testing at some point, but at least this keeps everything moving and keeps more transparency and more information about the products out there.
Regarding whether CCHIT will be accredited, we’ve said all along that we’ve been doing this since 2005. We have a lot of experience, there are over 200 products that we’ve reviewed, we have an inspection methodology that seems very replicable and credible and has been widely accepted. We’ve been reviewing different accrediting-type activities, and I think our organization would be lined up to pass those. So we remain confident that we’ll pass the test just as soon as it’s defined.
GUERRA: Due to the time constraints, don’t they have to grandfather in companies that have earned your most recent certifications?
RAY: I know that this fall the committees did make a recommendation for that, but that seems to have fallen out of the final rule. I think everyone’s going to need to start from some point, but at least there has been some uptake on the preliminary programs that we launched in October. Now, again, those vendors are going to have some incremental testing to do to close some gaps, but I am confident there’s going to be a good supply of certified products out there, whether CCHIT certifies them or it’s some other body.
Regarding the providers, they need to move quickly because, if you’re just starting now, boy, that’s a steep staircase to climb — to make your decision and implement in time to qualify. I think that’s what’s really scary to us and to others.
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