I love CCHIT.  Having an independent body assess EHR functionality is a wonderful service for us buyers of that technology.  CCHIT gives the seal of approval to those vendors that that have comprehensive EHR functionality requirement.

Apparently someone involved with writing the Federal Stimulus bill loved it as well.  It is apparent to me that it is intended to be a mechanism for determining if a healthcare organization qualifies for EHR incentive payments.

However, assuming CCHIT can determine acceptable EHR functionality is based on the flawed assumption that an EHR is a single purchase from a single commercial vendor.  Organizations that have achieved EHR functionality through the use of multiple specialized applications don’t have a certified EHR in the eyes of CCHIT (and therefore in the eyes of the ARRA it appears).

Let’s say I have a vendor that meets all but one requirement, perhaps their ePrescribing is inferior.  In the past I would simply find someone with niche capabilities to fit that need.  Good for me since I don’t have to start all over just to address that one need.  Good for the start-up that saw a need and met it.

But, in the ARRA world this is no longer an option.  Instead I don’t qualify for EHR incentives because I am not using a qualified EHR technology.

This concern has reached the level of drama in the open source world.  The Open Source folks had an open forum with the CCHIT folks at HIMSS yesterday.  It kind of got ugly.  CCHIT is just tied to an old single vendor paradigm which cannot accommodate this legitimate approach.

The problem is that vendor functionality does not determine how well an EHR is implemented.  I could have a vendor that provided my organization the richest functionality one could imagine, and still implement it in a way that totally sucks.  Conversely, I could cobble together several applications, none of which could qualify on their own for CCHIT certification, but implemented in the right way create something more functional and beneficial to my patients than some CCHIT certified applications.

We should return CCHIT to a buyer’s guide and stop using it to determine government patments.  The goal is good EHRs.  Certification distracts from that more than it ensures it.

Let me be the first to announce the delay of the deadlines to qualify for EHR incentives.  Actually, there is no official announcement or even open discussion – yet.  But, I believe it is inevitable.  I believe this for two reasons:

1. In my experience, government mandates delays are the rule
2. This EHR deadlines are completely unreasonable

Remember APCs, the revised Medicare funding mechanism for outpatient procedures?  Remember the big push for the deadline followed by a last minute delay.  In fact can anyone think of any significant government deadline that did not change?  My favorite example is the recent cutover to digital television.  We gave American couch potatoes years to go buy a converter box (or get cable service).  Millions were spent on advertising, web sites and coupon giveaways.  If there was ever a deadline that should have stuck it was that one.  Still, it was delayed from February to June.

We are giving hospitals and medical groups less time to implement EHRs than we gave television stations to change their broadcast capabilities.  The EHR is at least two magnitudes of order more complex.  Integrated Delivery Networks, such as mine, have essentially one year to implement an EHR for doctors and another year to implement the hospital EHR.  Note: I am assuming the rest of 2009 will be used for planning and waiting for the definition of “meaningful use.”  I have been working on this my entire professional career.  It is not a two year effort.

So, a delay is inevitable.  That is not to say that CIOs and other healthcare executives should plan on a delay.  I don’t think that would be prudent.

The other pressure for us is that healthcare, like corporate America, is focused on belt-tightening.  I have a backlog of really good ideas to reduce the cost of care to our patients.  Our new focus on Electronic Health Records will reduce our ability to implement these ideas.  Then again, I think that was the purpose of the incentives.  Get healthcare organizations to make EHRs a top priority to get them implemented once-and-for-all.