Anthony Guerra, founder/editor, hsCIO.com
While ONC has been moving at a pretty good clip since December when it released the Meaningful Use NPRM and Certification IFR, right up until the announcement this week of its final temporary certification program, it’s apparent just how jammed up its timeline is becoming.
The temporary program seems clear enough, as there is minimal departure from the one proposed in the Certification-Process NPRM released earlier this year, and by waiving the customary 30-day delay between publication in the Federal Register and enactment, it’s also clear ONC is doing everything possible to remove lags in the process. On July 1, or thereabouts, the temporary rule will become law (or something like it), and organizations can start applying for ONC Authorized Testing and Certification Body (ONC-ATCB) status.
But right off the bat, we see the process creeping into summer and, eventually, fall. ONC, of course, needs time to evaluate the applications, and has given itself at least 30 days to do so. And once organizations start to receive their ONC stripes, they will then have to develop a process for EMR vendors to apply for certification with them. Once the industry understands those requirements, vendors will have to prepare their applications, which could take considerable time when appreciating the complexity of these technologies and the costs of applying (which I’m sure won’t be insignificant). Then the ONC-ATCBs will have to evaluate what will certainly be a glut of applications.
And just how many ONC-ATCBs will be on the market to handle the tsunami of applications? By my count, possibly two — CCHIT and The Drummond Group. After they stamp their imprimaturs on the applications, the vendors will then shout to the market that they’ve been certified, so you can be sure there will be a glut of advertising and marketing spend to get the word out.
And then it will be time for those physicians (and few hospitals) who’ve been waiting for a government-approved stamp to hit the market and buy something. When might that happen in earnest? October, November? Of course, the day I bought my iPod I could do little more than turn it on, so how long will it take for those organizations to become Meaningful Users of the technology? And remember, ONC’s Meaningful Use looks to be of the most serious and intense kind, with all sorts of quality reporting and electronic output of data for patients.
ONC’s certification goal has always been to make it easier for the less savvy buyer to navigate the marketplace. It may be on the road to finally making that vision a reality, but how do the dates jive with its parallel vision to reward those clinicians for meaningfully using the technology? To me, it’s clear the whole process is about a year out of whack. If certified products are going to hit the market in fall, why not give clinicians a year to study them before testing what they’ve learned.
On day one, I could barely turn on my iPod, but today, I’ve got my Podcasts automatically downloading into it. I’ve come a long way, and the physician community will too. ONC just needs to give them a little more time.
Margalit Gur-Arie says
Unless…..
CCHIT will be turning on a dime and will immediately recertify all 2011 certified EMRs, and there are many including most of the big ones. Neither CCHIT nor the vendors need to put any extra work in this.
Drummond on the other hand will be playing catch up and since CCHIT is not charging any 2011 certified vendors for the final certification, those big customers are spoken for.
Vendors that are waiting for all final decisions to be made before starting development will be unpleasantly surprised. Same holds true for providers.
Anything that is 2011 CCHIT certified, either comprehensive, or Stage 1 and even ARRA (for all modules), should be bullet proof.
There really is no reason for anybody to wait until October – November. You are probably right that many will anyway.
Paul Roemer says
At times I think the ONC has taken a Captain Queeg approach to its oversight of EHR, counting the strawberries while all heck is breaking loose around them. Meaningful Use, Meaningful Use ROIs, Certification, RECs.
To me, these are prime examples of missing the focus of the problem, like mopping up water from an overflowing sink instead of simply turning off the water.
Would a single hospital, on its own accord, meet the Meaningful Use standards if the standards did not exist? If they did, it would be by accident. I spoke on this issue last week at the DC Health 2.0 meeting and by way of explanation offered the following illustration. Let us assume each hospital threw a dart at a dartboard whose two axes are EHR functionality and user rollout/penetration. The dart is then removed, and then the next hospital’s representative tosses their dart. This is repeated 4,200 times, leaving a dartboard with 4,200 holes.
The ONC representative steps to the line, and tosses a single dart—wherever the dart lands define the Meaningful Use standards for all of the hospitals. Clearly, 99.9% of the 4,200 hospitals will be nowhere near the standard. The same result would have happened were there no Meaningful Use. Hence, the Meaningful Use standards will have no meaning to most of the hospitals other than to have them do something they would have not done on their own, thereby altering their original business strategy in some capacity.
Certification, from my perspective brings with it the same sense of misdirection or feint. It certifies you qualify for money independent of whether having the money is in your interest or is not.
When hospitals implemented their ERP systems, systems like Lawson or SAP, hospitals didn’t need standards other than their own. They did not need systems which had received the ONC’s “Good Housekeeping” seal of approval.