Comments on: Reading the Tea Leaves in a Disclosure Document: When will ONC and NIST be prepared to accredit health IT certifying bodies? http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and-nist-be-prepared-to-accredit-health-it-certifying-bodies/ Electronic Health Record (EHR) information and news Mon, 16 Jan 2012 02:46:45 -0800 hourly 1 http://wordpress.org/?v=3.1.2 By: CCHIT Responds to Booz Allen Hamilton EHR Certification Contract with NIST | EMR and EHR http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and-nist-be-prepared-to-accredit-health-it-certifying-bodies/comment-page-1/#comment-1801 CCHIT Responds to Booz Allen Hamilton EHR Certification Contract with NIST | EMR and EHR Sat, 23 Jan 2010 08:31:58 +0000 http://ehrdecisions.com/?p=801#comment-1801 [...] Mark Leavitt has published his analysis of the $400,000 contract that NIST awared to Booz Allen Hamilton to develop a [...] [...] Mark Leavitt has published his analysis of the $400,000 contract that NIST awared to Booz Allen Hamilton to develop a [...]

]]> By: Glenda Williams, VP Marketing http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and-nist-be-prepared-to-accredit-health-it-certifying-bodies/comment-page-1/#comment-1799 Glenda Williams, VP Marketing Fri, 22 Jan 2010 20:29:09 +0000 http://ehrdecisions.com/?p=801#comment-1799 I agree with that assessment 100 percent! Mark Leavitt stated in a Chicago article in September 2009 that “There is a high risk that providers would not achieve meaningful use to qualify for the ARRA incentives in 2011 and 2012 if they wait until late 2010 to implement certified EHR systems and technologies,”. In short, they probably would not receive any incentives until 2013. The meaningful use requirements states that the solutions must be used for 90 days continuously in order for the Provider to receive the incentives. That’s 3 months. The average EHR solution takes about 4 months to fully implement. That’s a total of 7 months. This would require the Provider to initiate their implementation in June 2010 in order to qualify for incentives in 2011. It would be wise or recommended that the providers add an additional month for product evaluation and selection. This would suggest that the Provider start the process in May 2010. If the accreditation package won’t be ready until July 2010, and the vendor can’t test for certification until July, one could easily surmise that the certified apps won’t be available to the Providers until sometime in August 2010. If the Provider needs to get started in May 2010, and the apps are not ready until August, this presents some very interesting challenges. Regards, Glenda Williams, VP Marketing Pristine Technology Solutions, Inc http://www.pristechsolutions.com Waiting Room Solutions, SaaS Enterprise EHR I agree with that assessment 100 percent! Mark Leavitt stated in a Chicago article in September 2009 that “There is a high risk that providers would not achieve meaningful use to qualify for the ARRA incentives in 2011 and 2012 if they wait until late 2010 to implement certified EHR systems and technologies,”. In short, they probably would not receive any incentives until 2013.

The meaningful use requirements states that the solutions must be used for 90 days continuously in order for the Provider to receive the incentives. That’s 3 months. The average EHR solution takes about 4 months to fully implement. That’s a total of 7 months. This would require the Provider to initiate their implementation in June 2010 in order to qualify for incentives in 2011. It would be wise or recommended that the providers add an additional month for product evaluation and selection. This would suggest that the Provider start the process in May 2010.

If the accreditation package won’t be ready until July 2010, and the vendor can’t test for certification until July, one could easily surmise that the certified apps won’t be available to the Providers until sometime in August 2010. If the Provider needs to get started in May 2010, and the apps are not ready until August, this presents some very interesting challenges.

Regards,
Glenda Williams, VP Marketing
Pristine Technology Solutions, Inc
http://www.pristechsolutions.com
Waiting Room Solutions, SaaS Enterprise EHR

]]> By: Booz Allen Hamilton, Inc Receives Non-Competitively Awarded Contract to Develop Certification and Accreditation Program for testing EHR Systems « Law Blog 2.0 http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and-nist-be-prepared-to-accredit-health-it-certifying-bodies/comment-page-1/#comment-1793 Booz Allen Hamilton, Inc Receives Non-Competitively Awarded Contract to Develop Certification and Accreditation Program for testing EHR Systems « Law Blog 2.0 Mon, 18 Jan 2010 00:00:36 +0000 http://ehrdecisions.com/?p=801#comment-1793 [...] Document: When will ONC and NIST be prepared to accredit health IT certifying bodies?” (see http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and...) made some interesting [...] [...] Document: When will ONC and NIST be prepared to accredit health IT certifying bodies?” (see http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and...) made some interesting [...]

]]> By: Glenn Laffel, MD, PhD http://ehrdecisions.com/2010/01/15/reading-the-tea-leaves-in-a-disclosure-document-when-will-onc-and-nist-be-prepared-to-accredit-health-it-certifying-bodies/comment-page-1/#comment-1789 Glenn Laffel, MD, PhD Sat, 16 Jan 2010 02:52:17 +0000 http://ehrdecisions.com/?p=801#comment-1789 I agree with Mark's point that ONC has a lot of work to do in not a lot of time. And I applaud Mark and his organization, CCHIT, for making every effort to be ready when it comes time to apply to become an outsourced provider of HHS certification services. In fact, I sincerely hope that every organization aspiring to provide such services to HHS is engaged in the same rigorous preparation that Mark and his organization are doing. If this is the case, then it's not clear to me whether starting from scratch with the IFR criteria is better or worse than performing a gap analysis compared to existing criteria, as CCHIT proposes to do. Regardless, kudos to ONC for recognizing the importance of scrupulously maintaing vendor neutrality in every decision it makes, including this decision to ask Booz for help developing a certification process. ONC's concept of "EHR Modules" was a tour-de-force in vendor neutrality, for example, in that these modules help legacy EHR vendors come up to speed quickly on Meaningful Use, AND they permit innovators and specialty product vendors to assemble themselves into something comprehensive and yet transformational in the EHR market (in terms of price points, ease-of-use and so on). ONC's decision to work with Booz in developing a certification process is another example of its recognition of the need to be indifferent to the market...including the market for certification services. Thank you, Glenn Laffel, MD, PhD Sr. VP Clinical Affairs Practice Fusion www.practicefusion.com Free, Web-based EHR I agree with Mark’s point that ONC has a lot of work to do in not a lot of time. And I applaud Mark and his organization, CCHIT, for making every effort to be ready when it comes time to apply to become an outsourced provider of HHS certification services.

In fact, I sincerely hope that every organization aspiring to provide such services to HHS is engaged in the same rigorous preparation that Mark and his organization are doing.

If this is the case, then it’s not clear to me whether starting from scratch with the IFR criteria is better or worse than performing a gap analysis compared to existing criteria, as CCHIT proposes to do.

Regardless, kudos to ONC for recognizing the importance of scrupulously maintaing vendor neutrality in every decision it makes, including this decision to ask Booz for help developing a certification process.

ONC’s concept of “EHR Modules” was a tour-de-force in vendor neutrality, for example, in that these modules help legacy EHR vendors come up to speed quickly on Meaningful Use, AND they permit innovators and specialty product vendors to assemble themselves into something comprehensive and yet transformational in the EHR market (in terms of price points, ease-of-use and so on).

ONC’s decision to work with Booz in developing a certification process is another example of its recognition of the need to be indifferent to the market…including the market for certification services.

Thank you,
Glenn Laffel, MD, PhD
Sr. VP Clinical Affairs
Practice Fusion
http://www.practicefusion.com
Free, Web-based EHR

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