A recent article, reporting that NIST awarded a $400,000 contract to Booz Allen Hamilton to develop a framework for electronic health record certification, stirred up lots of questions.
We needed to find out more. It took some time to locate the source document, because the terms “health IT” and “certification” aren’t in the title – instead, it’s entitled “Justification for Other than Free and Open Competition” and it is publicly available by searching fbo.gov for Department of Commerce/NIST documents released January 13, 2010. Or just use this quick link: http://bit.ly/6p2pDD
The NIST document refers to two task areas. First, “develop testing and certification program documents in support of the HHS Health IT Certification Program.” Second, “develop accreditation program documents and a proficiency testing framework to support HHS in authorizing certification and testing organizations.” Note the work product in both cases: documents, not actual programs. We see nothing here to suggest that ONC, NIST, or Booz Allen intend to build and operate a certification program themselves. They do need to develop a well-defined set of policies and processes for accreditation of those programs.
In the Interim Final Rule, ONC said they “decided to proceed with a separate notice and comment rulemaking (which we anticipate publishing shortly after this interim final rule) to establish the policies for the certification of HIT and the process a certification body will need to follow to become an authorized certification body, as determined by the National Coordinator.” [our italics] We think that’s still the most reliable description of what’s underway.
But the NIST document does offer some timing clues. This particular contract, described as a bridge to an upcoming acquisition (i.e. contract) runs 3 months, with a 3 month optional extension. Sounds to us like the soonest the accreditation package would be ready is July 2010, and of course the certifying bodies then have to apply and qualify. By which time, in our opinion, it would be impossible for a provider or hospital to begin shopping for a certified EHR and achieve Stage 1 Meaningful Use in time for the 2011 or 2012 incentives. Let us know if you agree with that assessment.
It appears clearer than ever how crucial our current work is to the health care community and to the practical achievement of the ARRA goals. Next week we’ll release an analysis of the gaps between our current 2011 criteria and the IFR, as well as a plan for promptly closing the gaps.


