CCHIT Certification, and President Obama’s Medicare Bonus Payment Incentives

Published: 09th March 2009
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What is CCHIT Certification?

The CCHIT or Certification Commission for Healthcare Information Technology was organized in 2004 by three leading non-profit private associations commonly known as HIMSS, AHIMA, and the Alliance. The initial concept for CCHIT was to develop a uniform set of guidelines for the Healthcare Industry encouraging the development of a standardized EHR/ EMR platform or system with an efficient process for certification. (EMR / EHR / Electronic Medical Records / Electronic Health Records are used synonymously in this article).

The goal was to engage the private sector to take the lead role in establishing a specified set of parameters that were practical and quick to implement in meeting the needs of a Physicians' Medical Practices and Hospitals in transitioning to or upgrading EHR. The underlying challenge however, was to develop a solution that could accelerate the voluntary adoption of this idea as an industry wide, uniform, interoperable, and robust Health Information Technology system, that also had to be credible and have a streamlined certification process.

CCHIT - Expanding Its' Purpose

Today there are literally hundreds of EHR / EMR software solutions on the market making it extremely easy for providers to "virtually" get lost in the huge maze of vendors and their products. This is especially challenging considering the fact that most providers are not IT experts and nor do they have the time to become one. Thus, in more cases than not, Physicians and managers can quickly become frustrated with the whole process and simply put it aside for now. Unfortunately, this comes at the cost of one most important steps in the EHR selection process and that is, initially assessing their specific Medical Practice needs and then matching those requirements with an EMR solution that has all the right set of features, functionality, and benefits that best meet not only the Physicians or Hospitals current needs, but also very crucial, be flexible in meeting their needs in the future. Another primary purpose of CCHIT certification was to minimize the risk to the Physicians investment in EHR software and products, while also accomplishing the following:

  1. Ensure that EMR products protect the highest level of privacy of personal health information

  2. Develop bona-fide incentives enhancing the development, availability, and adoption of EHR software and hardware solutions by Physicians

  3. Facilitate interoperability of EMR products with the emerging national health information network, also referred to as RHIO's

The EHR CCHIT Certification Criteria

In 2004 the key certification criteria included EHR products that were designed for use in Physician offices and today these are referred to as Ambulatory EHR.

In 2006 the CCHIT certified standards were expanded and required vendors to demonstrate compliance with an additional 16 new criteria. In 2007 another 96 criteria were introduced and most recently in 2008, as a result of improved technology, greater practical experience, and added political pressures 19 more criteria were added to the list of certification requirements.

These 19 new criteria focused upon the following areas:

  1. Increased electronic prescribing features including better access to a patients' medication history, formulary, and eligibility

  2. Improved and safer medication dosing adjusted for a patients' weight, age, gender, and other related physiological factors

  3. Greater prevention of adverse reactions caused by drug interactions or allergies

  4. Implementation of standardized formats and platforms for exchanging fundamental patient information including medical history, current diagnosis and treatment, and other patient demographics for continuity of safe and high quality patient care.

  5. Enhanced ability to send, receive, and review X-rays, Scans, and other diagnostics imaging

  6. More accurate, protected, and better management of patient consents and authorizations

  7. Increased use of standardized formats and platforms receiving, storing, and sharing laboratory and diagnostic results

Does CCHIT Certification increase the cost of EMR to Physicians?

The initial cost to vendors seeking CCHIT certification is about $28,000 and unless revoked, this certification is valid for a three-year period. In addition, vendors must pay an extra $4,800 in year 2 and $4,800 in year 3 which fees apply to marketing and licensing fees. If, during this 3 year period a product is significantly re-engineered or re-architected, the vendor must re-submit and start the entire process over again, including paying the fees to become recertified with the major updates. Minor updates typically do not need to go through this costly recertification process.

How many vendors make the CCHIT certification grade?

As of January 2009 there were only 162 CCHIT Certified EHR vendor solutions in the market. Noteworthy here is that there are some 300+ relatively active and visible vendors with 100's more in addition to those. Looking further into the breakdown of the 162 Certified EMR vendors raises concerns as to the real value and actual validity versus perceived notions to Physicians in relying upon vendors that generically claim to be CCHIT Certified EHR. The current list of certified vendors breaks down like this:

  1. Only 92 EHRs have received certification under the 2006 Ambulatory EHR criteria which were not officially certified until April 30, 2007

  2. Only 55 EHRs have been have been certified under the official 2007 certification criteria of which, many are simply multiple updated versions of the same product by the save vendor

  3. A mere 15 EMRs have been certified under the official 2008 criteria of which a number of those are previously certified products that added-on certifications for Child Health and Cardiovascular Medicine

Compare these numbers against the 300+ prominent and 100s of other less active EHRs in the market, one could reasonably infer that there are many smaller players that may offer very innovative and cost-effective solutions but may not have the time nor financial resources to expend on certification let alone, the doubling of costs for recertification every time they make significant changes. This then begs the question, could formal certification actually be creating an unfair playing field and even barring smaller or newer competitors whom otherwise, may be pioneering the "next big thing" from entering the marketplace and ultimately lead to limiting the choices and higher prices to Physicians and Hospitals?

If this is the destined result of CCHIT certification for Physicians, there may be some financial relief in sight. The current Administrations' Economic Stimulus Package recently received legislative endorsement and was signed into law by President Obama on February 17, 2009. Included in this package is a very specific piece that clearly demonstrates the Presidents goal of having a Personal Health Record for every American within the next 5 years. To achieve this end, $19 billion is earmarked for Healthcare Industry Technology advancement. At face value, utilizing the omni giant Medicare system as the vehicle of distribution, a portion of these funds are to be used as bonus payment incentives to encourage Physicians and Hospitals to make the transition to EHR and other technologies, sooner than later. The Office of National Coordinator for Health Information Technology (ONCHIT) is charged with developing and implementing financial incentive programs for qualifying Physicians and Hospitals who can expressly exhibit and document the "meaningful" use of certified EHRs and meet performance-reporting guidelines.

$2 billion of this $19 billion is targeted as a "jump start" for Physicians implementing electronic prescribing and the carrot stick, a 2% incentive bonus beginning in 2009 and then being reduced to 1% in 2010. The remaining roll-out incentive is a phased process whereby beginning in 2011 and continuing through 2015 the total Medicare bonus incentives for each eligible Physician can range from $41,000 to $60,000, with $18,000 available in year 1 of this five year plan. Thereafter, Physicians and Hospitals can expect reduced Medicare reimbursement or even straight up denials of claims. Medicaid and third party private health insurance payers are expected to follow similar suit in nature and so Physicians and Hospitals who take immediate steps to become eligible for incentive payments will reap the greatest benefits throughout this window of opportunity in Healthcare Industry Technology system reform and transition.

What does CCHIT certification really net to Physicians?

Traditionally, EMR is a long-term investment and providers must be careful when trying to select the right solution that not only meets their needs today, but also is flexible in meeting their changing needs and industry reforms in the future. However, most Physicians have extremely limited time and resources to cut their way through the thick of the fog of literally 100s of vendor solutions on the market and conduct a detailed evaluation for making the best determinations. To help narrow down this huge maze of choices and give Physicians and Hospitals better leverage over their precious time and resources, many experts suggest limiting the search for an EHR to only those vendor solutions that are CCHIT certified. One major benefit of this strategy is that CCHIT certification should expedite their due diligence and assure Physicians of attaining sound functionality in their EMR system.

While it appears that legislative bonus payment incentives are tied to CCHIT certification, there is a caveat to this approach of placing too much importance on CCHIT certification in that, this could prematurely eliminate a significant population of new or maturing, and more innovative and powerful solutions from smaller vendors who simply cannot afford the high costs of becoming CCHIT certified. Another thought is, just because a product is not certified, does not necessarily mean it does not meet the specific requirements of becoming certified, and for that matter, it has not been made clear that CCHIT certified is the requirement for payment incentives rather the primary criteria that payment incentives are being tied to is, the "meaningful" use of EHR and other identified technologies, to be eligible for the Medicare bonus payment incentives. In fact, a vast number of Practices most likely do not need the 300+ features presently mandated and evaluated by CCHIT and administered by ONCHIT.

Sometimes too much of a good thing is just that, too much

In selecting an EHR loaded with features, Physicians should be asking, "do we really need and want to pay for a bundle of extra features and functions we may never use now or in the future?" Although this is often used as an exciting vendor selling point, it is the best reason for properly identifying and assessing your Practice or Hospitals' actual needs and then looking at the requirements of CCHIT certification. In comparing vendors, this will help ensure you are not over-paying for more than you need. Additionally, ask the vendor to address how their solution qualifies your Physicians to be eligible for Medicare and Medicaid bonus payment incentives, especially regarding for the monies that are available now. Again, another good reason to spend time on creating an extensive checklist of all the features and functions your Practice or Hospital needs from an EMR. While doing so, consider staff and provider adoption and implementation, quick ROI, improving business efficiencies, patient information processing and sharing, and improving patient care and safety, increasing net revenues, and ensuring Physicians have an Abundant Quality of Life socially, personally, and especially in family life. Most experts would probably agree on at least this one thing, "that today, it's about working smarter and not harder to improve your bottom-line and also enjoy life."

The following is a list of critical questions and steps a Physician or Hospital should initially consider in their EHR selection process:

  1. Is the Electronic Medical Record or Electronic Health Record vendor solution CCHIT certified? If yes, then ask to which years' standard and then to prove it. If the answer is no, then ask them if their solution meets the latest certification standards or if they going to become CCHIT certified, and to prove it.

  2. Does their EHR / EMR solution support all of the requirements of the Physicians specialty? This is especially important because CCHIT acknowledges that its' criteria may not meet the needs of all specialties such as Behavioral Health, Emergency Specialists and Departments, and many other specialty Practices)

  3. Does it allow the Practice or Hospital to share information electronically with other Physicians, Hospitals, Pharmacies, Laboratories, Radiology Centers, and other related medical service providers? (the basic requirement of any compatible system in these regards, must have an HL7 Interface both inbound and outbound with the ability to interoperate with other systems)

  4. Does it enable Physicians or Hospitals to measure and report critical Quality Indicators as required to be eligible for the impending Federally supplemented, bonus payment incentives? (based upon the "meaningful use" of Healthcare Information Technology and Levels of Performance that were signed into law by President Obama on February 17, 2009)

  5. Can the vendor demonstrate a proven track record of providing outstanding customer support before and after the sale?

  6. Are references from similar type, specialties, and size Practices and Hospitals available, preferably within nearby proximity, who can provide independent opinions about the vendors product and their experiences working with them in terms of need assessment, planning, implementation, function, and on-going support?

  7. Does the vendors' solution effectively monitor and Flag potential adverse drug reactions and interactions?

  8. If you are currently using a Practice Management or Billing software, does the vendors' EMR have its' own stand-alone interface that seamlessly integrates with your PM or Billing software or, will you be required to purchase an additional third party software to interface with your system as well as, be able to share a common database through their EHR product? (either way, ask them to prove it)

  9. If you are updating, replacing, or a first time user of a PM or Billing software and introducing EMR to your Practice, Group Clinic, or Hospital, does the vendor have its' own single-source and fully integrated PM and EHR which does not require purchasing any third party interfacing software? If yes and as needed can their solution be phased-in over a period of time, to better fit within any budgetary concerns and for cases where key Staff and Provider adoption and learning curve experience may be an issue in order increase utilization efficiency and contribute to a quicker ROI?

  10. Over the course of the next 3 to 5 to 7 years as Practices and Hospitals needs change with growth, advancements in technology, or as Federal Regulations, Mandates, or political or economic climates may change, can the vendor or their existing solution meet or adapt to these new challenges and provide on-going support, upgrades, or new solutions, and Medical Business Insight

The majority of these questions are primarily foundational and functional in nature while there is another pressing list of non-functional requirements that require equally important attention in the Electronic Medical Records selection process. An essential non-functional aspect of every Medical Practice and Hospital they share in common are their Human Resources (key staff and provider opinion leaders, their commitment, adoption attitude, and ability to deal with change). The other areas of non-functional value needing consideration include Capital Investment (start-up cost, hardware, annual maintenance, and IT costs, ROI) and, the Organization Structure (owners, stakeholders, decision makers, and key management leaders)

While all this can be an overwhelming task that few have the time to do, there is light at the end of this Healthcare Information Technology tunnel in that Physicians and Hospitals do have an option for help that can also ensure eligibility for the various bonus payment incentives designed to encourage a speedy transition to EHR. There is an emerging selection of qualified Independent EMR / EHR and PM consulting firms who will do all the cumbersome and costly up-front legwork for you while navigating you through the stormy ocean of choices. In fact, there are well established companies that will perform these initial services and at no cost to Physicians or Hospitals. It follows then, that it would be wise before you buy, to do some homework and seek-out a reputable Independent EHR Consulting company that can save you thousands of dollars right up-front, thus steering clear from companies charging hefty up-front fees and then followed by expensive per hour consulting billing hours, which may range from $125 to $200 per hour, plus expenses.

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