Since its founding in 2004, the Certification Commission for Healthcare Information Technology has pursued a mission to accelerate adoption of health information technology by achieving four goalsor, more accurately, three goals and a wish.
The first and most obvious goal of certification was to reduce the risk that clinicians face when making the leap to electronic health records. The second and third goals were to ensure the systems they installed could exchange information electronically and would protect the privacy of patient data.
But the fourth objective required a leap of faith. We thought if certification could ensure that EHRs include features to support meaningful improvements in the quality and safety of care, then maybejust maybehealthcare payers might step up to offer financial incentives for adoption, and the government might lower certain regulatory barriers.
Wishes sometimes come true. Over the past few years, certification became a qualifying mechanism in scores of incentive programs that make money available to encourage clinicians to adopt and use EHRs. The trend culminated, of course, in the biggest incentive program we could ever imagine. Heres a little history that brought us to this point.
In 2006, the CMS adopted a rule that provided safe harbor under the Stark and anti-kickback laws for donation of certified EHRs to physicians by hospitals and other covered entities. Although it took another year for an Internal Revenue Service ruling to clarify its acceptability, the safe harbor was the first encouraging sign of progress toward that fourth goal.
In 2007, the Medicare EHR demonstration project was launched, providing financial incentives for adoption of certified EHRs. And by the end of 2008, our research revealed nearly 100 health IT adoption programs from the federal, state and private sectorsincluding 50 safe-harbor EHR rolloutsstimulating EHR incentives worth an estimated $700 million.
Then came a perfect storm of events: with the economy shaken by a financial crisis, a new administration was swept into office on the promise of change and health reformwith health IT adoption as a leading enablerbecame a national policy priority.
Health IT provisions of the American Recovery and Reinvestment Act of 2009 will forever be regarded as the turning point in the history of IT in healthcarewith $2 billion for the Office of the National Coordinator and $34 billion ($17 billion net after projected cost savings) in Medicare and Medicaid incentive payments for adoption and meaningful use of certified EHRs.
EHR certification now takes on a new importance, as a major public investment needs to be guarded, and CCHIT must rise to this responsibility. Our work has always centered on finding a fair balance between conflicting interests: developing certification that is sufficiently rigorous to ensure that EHRs deliver the expected benefits, yet avoiding creation of a barrier to innovation or a significant addition to the cost of health IT.
The value of a certification process should not be judged by an absence of complaints from product manufacturers, but instead by evidence that certification is fostering a healthy marketplace in which buyers confidently acquire products and diverse sellers vigorously compete.
As the provisions of the stimulus law are implemented, the appropriate stance for CCHIT is one of flexibility and responsiveness. Here are a few of the possible new directions that may emerge:
- Expectations of certification will grow. The stimulus law requires not just adoption of certified EHRs, but also meaningful use, including quality measurement, electronic prescribing and data exchange. CCHIT must ensure that when clinicians choose a certified product or service, these end goals are within reach. This could imply developing means to verify an EHR products usability, the vendors quality of training and implementation, and the availability of ongoing support. In addition, with so much new money available, certification must help protect against fraudplayers who might attempt to game the system, getting the additional payments without making the concomitant investment in improving the care they deliver.
- The schedule of domain expansions may change. EHRs must be available for all providers and facilities eligible for incentives. This summer, we begin development of expansions into behavioral health, dermatology and the long-term-care spectrum, as well as advanced certification options in interoperability, quality, clinical-decision support and security. Still, other areas may need to be added. Medicaid incentives, for example, extend to federally qualified health centers, which include services such as dentistry.
- Decisions at the federal level may affect certification criteria. Each year, CCHIT has submitted its latest criteria to the HHS secretary through the American Health Information Community, which in every case recommended full recognition. The new health IT policy and standards committees being formed may take a more activist stance. The committees might want to accelerate the pace on interoperability or ask for more-stringent quality reporting requirements. CCHIT will need to promptly incorporate such changes to offer fully compliant certification.
Mark Leavitt, M.D.ChairmanCertification Commission for Healthcare Information Technology Submit a letter to the Modern Physician Reader Blog. Please include your name, title, company and hometown. Modern Physician reserves the right to edit all submissions.