Recap: CCHIT Town Call for work group volunteers

For those of you who missed the recent CCHIT Town Call on volunteering for work groups, here are the slides and the audio from the call.

[NOTE: These slides were revised on March 23, 2009, to incorporate recent changes to the work group structure. Therefore, the audio will not match the slides.]

Questions and Answers

How can you be certain that the HHS guidelines for EHR adoption will rely on CCHIT for certification? What if the Federal Government has a totally different agenda. I understand that they have to deliver the federal mandates for EHR standards by Dec 31, 2009.

What if they decide that the current VA EHR or a variant thereof is their choice. Afterall this is funded by tax payer dollars and theoretically belongs to all of us. Why should an EHR in progress, like my company, spend incredibly large sums of money for CCHIT?

Please review the March 17 Town Call presentation and audio published on this site. It provides answers to your questions.

If you start accepting applications for the working groups on 3/23, these are presumably relatively standard forms. My interest is in the LTC related working group. Where can I find the template for the application?

The instructions and forms for application will be available beginning on March 23 at http://www.cchit.org

What is CCHIT’s plan to support certification of niche EMRs for subspecialties where the market is not big enough to support the development of full ambulatory functionality, and indeed, physician customers place much lower priority on such functionality vs support for the specialty functions? Might CCHIT consider certification of subspecialties with Foundation criteria plus specialty functionality?

Does this imply the need to revamp Foundation criteria to be minimum criteria needed by all EMRs? What is the current status of Foundation?

Foundation criteria have been harmonized across the current certification domains – ambulatory, inpatient, etc. Our certification programs already include a basic ambulatory EHR certification with add-on programs for special areas such as child health and cardiovascular medicine, so this process has already begun. In the next few development cycles, we have identifed six additional add-on categories. As noted in our Town Call, our certification programs will be flexible and adaptable to the new rulings and administrative decisions of the HHS Secretary and Federal agencies, including ONC and CMS. Those decisions could conceivably result in a more modular approach to certification.

How does one apply to to become part of the Security and Privacy workgroup? Can multiple members from the same organization be part of this group?

Application instructions will be available at http://www.cchit.org beginning on March 23. To preserve a fair balance of stakeholders, multiple members of a single organization would not be appointed to a single group.

How does submitting for reimbursement for incentives change the way we report in our cost report?

This is not a question we can answer since we are not a Federal agency and we do not administer reimbursement. This is probably best directed toward CMS.

I understand that the CCHIT has a lot a gound to cover in a very short time; but if attention is not paid to the details of implementation, there could be problems and frustration down the road. Even the workgroups are looking at fairly big pictures.

Case in point, my three children recently visited a medical group in our community here in South Pasadena, CA. Two of them were about to be given immunization shots they already had; fortunately my memory served me well and prevented the mistake. The physician told me that they have coverted all the records to the new EHR system in the last two years.

Certified software products alone does not garantee proper implementation of EHR systems. One solution is to empower the patients to track their own health records and verify those at the doctor’s office.

Therefore, certified software products should provide the necessary features for patients to download the info and check their own records.

This feature would also allow patients to monitor their own health over time–tracking their level of LDL or HDL, etc.

While the CCHIT is already planning to expand on its HIT certification, judging from many of the comments and questions from the folks out there, there are a lot of people are still on first base.

I believe that an implementation workgroup would be helpful to the physicians and IT providers.

This workgroup would provide answers and guidelines developed by the other workgroups from privacy and security issues to interoperability and decision support system.

It may even provide guidelines as to the naming convention and data field requirements for reporting communicable to the local county and state public health agencies or even for patients to download the data correctly.

As noted in the Town Call: expectations for certification no longer end with product testing. Responsibility extends to usability, meaningful use, quality measurement, data exchange –and ultimately health IT‟s role in health reform. Implemention may fall into the Commission’s considerations in the coming development year.

How do you anticipate the 2009 certification cycle will be be affected by the fact that the initial ARRA certification requirements need not be issued until the end of this year. Will it start on time and do you anticipate the need for mid-cycle adjustments?

CCHIT’s 2009-2010 certification cycle will begin as planned in July. Adjustments are always made throughout the development year based on public comment cycles and Commission guidance. There will be opportunity between the beginning of the cycle and it’s scheduled completion in May/June 2010 to accommodate any certification program changes required as a result of ARRA.

The language of ARRA and HITECH is all around interoperability as the primary driver of certification; while there is mention of other areas such as clinical decision support the overriding emphasis is on interoperability. Looking at the current CCHIT certification criteria, while interoperability is a piece of the certification pie, it is actually a relatively small piece. By a quick count just based on source workgroup, there are 500 criteria for inpatient certification of which just 42 are from the interoperablity workgroup. I know that’s a simplistic analysis and that there are other interoperability criteria as well, but the question remains: if certification is designed to encourage interoperability and CCHIT as currently structured is approximately 10% interoperability and 90% “everything else” – how reasonable is to expect that CCHIT will be adopted without major changes in definition of scope? Perhaps CCHIT should be working towards an interoperability-specific certification track as a way of aligning itself with the language and intent of ARRA?

CCHIT’s future certification programs will be adapted to the requirements of ARRA, including rulemaking and administrative decisions made by the Secretary and Federal agencies such as ONC and CMS. Advanced Interoperability is already a certification program chosen for further development in 2009-2010.

It is my understanding that there are no plans for a certification protocol that would cover entities focused on reporting/monitoring comparative effectiveness, ie. HIT systems that collect and support cardiac/ortho implant registries. Is it possible to include this topic in the near future? If so what steps must be taken to initiate this process?

Current Ambulatory EHR criteria already require general reporting capabilities without reference to specific domains such as cardiology or orthopedics. Advanced Quality is already a certification program chosen for further development in 2009-2010.

Do you anticipate from moving from a Pass/Fail EHR certification process to a process of passing basic minimal EHR requirements and then achieving advanced certification that meets the basic level of certification along with a more advance requirements? ie…+Advanced Security, +Interoperability, +UserInterface, +Specialities?

CCHIT continues to support the concept that a product should pass 100% of the criteria for a defined certification program to be considered in conformance with the requirements of the program. As noted in our Town Call, our certification programs will be flexible and adaptable to the new rulings and administrative decisions of the HHS Secretary and Federal agencies, including ONC and CMS. Those decisions could conceivably result in a more modular approach to certification.

I read in recent article from AMA Assn news that the national health IT coordinator will be authorized to make available a qualifying EHR system to physicians for a nominal fee. Can you expand on the availability of this EHR system and CCHIT involvement?

The language in ARRA reads:

‘‘SEC. 3007. FEDERAL HEALTH INFORMATION TECHNOLOGY.
‘‘(a) IN GENERAL.—The National Coordinator shall support the development, routine updating, and provision of qualified EHR technology (as defined in section 3000) consistent with subsections (b) and (c) unless the Secretary determines that the needs and demands of providers are being substantially and adequately met through the marketplace.” and
‘‘(c) AUTHORIZATION TO CHARGE A NOMINAL FEE.—The National Coordinator may impose a nominal fee for the adoption by a health care provider of the health information technology system developed or approved under subsection (a) and (b). Such fee shall take into account the financial circumstances of smaller providers, low income providers, and providers located in rural or other medically underserved areas.”

We can’t predict a Secretary’s future ruling on EHR marketplace availability or the amount or conditions of a nominal fee. It seems clear throughout this legislation that any qualified EHR would still need to meet the conditions of certification and meaningful use if a physician wished to qualify for funding under this new Federal program.

Does the conflict of interest requirement require disclosure of stock held in companies offering EHR systems (e.g., GE, Siemens, etc.)?

The conflict of interest questions contained in the CCHIT volunteer application will require disclosure of any material equity holdings in health IT companies that could apply for certification.

Are we to understand that the 2009 Ambulatory Cert requirements will be out later in the year in 2009? We had expected them in May, but will they be delayed this year, due to ARRA?

The 09 Ambulatory EHR criteria and test scripts will be published in May 2009 and application for 09 Ambulatory EHR certification will open on July 1, 2009.

CCHIT will adapt its future certification process to meet the requirements of ARRA and any resulting Federal rulemaking or administrative decisions.

Do you anticipate adding additional security criteria to the Inpatient 2009 Certification Criteria? The ARRA discusses many legal items that are not covered in CCHIT Criteria, such as Accounting of Disclosures. Do you expect these items to be added to the criteria for certification?

The 09 Inpatient EHR criteria are scheduled for a final public comment period from March 30 to April 28. They will not be finalized until mid-May.

CCHIT will adapt its certification process to meet the requirements of ARRA and any resulting Federal rulemaking or administrative decisions.

Can you summarize the role of Vendor Stakeholder?

From its inception, CCHIT has included a broad range of health IT stakeholders – physicians and providers, consumer representative groups, payers, health IT vendors, quality improvement organizations, government agencies and more – in its development of consensus-based certification programs. On the board of Commissioners, in volunteer work groups and through public comment, vendors have contributed to that consensus with practical advice about product development. And, for the past 3 years, they have continued to bring new products for testing and certification as that consensus-based process raised the bar of certification higher.

Many of the IO criteria directly reference HITSP specs. There are times these specs are too restrictive as the use cases they were scoped to are not always in line with EHR – EHR interop. Do you see the existing HITSP specs being as relevant with the CCHIT 2010?

As required by ARRA, CCHIT will base new criteria on standards approved by the Office of the National Coordinator and its Health Information Technology Standards Committee.

What about healthcare IT in other care areas, like Ambulatory Surgery Centers? Many of them have software, but CCHIT does not Certify in this area.

From time to time, the Commission conducts an open call for expansion. Such a call was recently completed and new programs were approved at the Feb 17, 2009 Commission meeting. To assess the potental for a new program’s success, the Commission considers factors such as the public benefit of expanding certification, stakeholder readiness for certification and the cost to develop certification. Certification represents basic requirements that the Commission believes are appropriate for common care settings where most Americans get their care. As its work has matured, the Commission has added new programs for special populations, special settings and medical specialties such as child health, cardiovascular care and emergency departments. CCHIT acknowledges that certification may not yet be available for every care setting. Expansion will continue based on new Federal requirements, Commisson priority setting and the Commission’s capacity.

What does it cost for a vendor to get their EHR product certified through CCHIT? What accounts for this cost? Will the cost change in the future?

Information about certification fees is available in the program certification handbooks at http://www.cchit.org/certify . The Commission is a private, 501c3 nonprofit with a charge to become self-sustaining. Collected fees cover the costs of certification program development, product inspection – including application review and administration, paid jury observation, techincal testing tool development, testing technology infrastructure and product listing – and stakeholder outreach. Certification fees are adapted to the health IT marketplace and the resource capacity of the Commission.

I am looking for a out-of-the-box Microsoft SharePoint-based EMR solution. Could you give me some pointers to the vendors who already have implemented either WSS 3.0 or MOSS 2007 EMRs.

CCHIT cannot make product recommendations.

Will quality reporting and disclosure reporting (under the privacy section) require the creation of new functionality and standards within certified EHRs?

CCHIT will adapt its certification process to meet the requirements of ARRA and any resulting Federal rulemaking or administrative decisions.

Have you considered a sliding scale for companies grossing less than $1M per year for the certification fee?

Early surveys of both large and small vendors ruled out a sliding scale fee for certification due to the required financial reporting that would be necessary to administer such a fee structure. As it has already done with non-profit health information exchanges, the Commission may establish special grants to reduce certification fees for non-profit or non-commercial developers of EHRs. That will be dependent upon the availability of funds to support such grants.

The current CCHIT requirements include functionality that may not be needed by small practices. Assuming the HHS standards will represent a basic minimum standard, will CCHIT develop certification for just the basic standards?

CCHIT will remain flexible and responsive to the requirements of ARRA and any resulting Federal rulemaking or adminsitrative decisions.

Why are the workgroup meetings not open to the public?

CCHIT is a private, 501c3 nonprofit organization, not a public agency. Regular work group meetings are held via teleconference as frequently as weekly. All work group meeting minutes are available to the public at http://www.cchit.org.

[NOTE: We are in the midst of compiling responses to all of the questions posted during the call. We will post additional questions and answers here once that effort is complete.]