CCHIT Certifies New Products; Should Health Centers Purchase These?
By: Michael Lardiere
The Certification Commission for Health Information Technology (CCHIT) — currently the only certifying body for EHRs — announced that is has certified a number of EHR products under its Preliminary ARRA Certification Criteria. It has also identified seven products that have passed 2011 Comprehensive Certification. Click here to read more.
Although certification is a necessary component of any EHR that a health center might purchase in order to obtain Medicaid Incentive funds, health centers should use caution and not just jump to an EHR that has passed these certifications. Not all products certified by CCHIT through its Comprehensive Certification or its Preliminary ARRA Certification Criteria fully meet the needs of health centers. Health centers require functionality in any EHR that they use that is above the basic CCHIT requirements. Some of these requirements include UDS reporting and population management functions. Some of the vendors that are CCHIT certified do provide this additional functionality, but not all do.
In order to get a better understanding of which systems meet the needs of health centers, there are several options. Review the 2008 NACHC HIT Survey to identify products that most health centers have adopted. Health centers can also contact one of the Health Center Controlled Networks to determine which EHRs are used by their centers. You can find a list of HCCNs or search for a HCCN by name or type of EHR used at the NACHC website. A number of health centers have also volunteered to be available to discuss the EHR they use and also be available for site visits by other health centers.
Certification is important, but it is not the only criteria that health centers need to consider when selecting an EHR vendor.
Comments are always welcome!
CCHIT Workgroups Kick off
By Michael Lardiere
As many of you may know I was selected as a Certification Commission for Health Information Technology (CCHIT) reviewer for Behavioral Health last month. Information and members of the workgroup can be found at http://www.cchit.org/workgroups/behavioral-health.
I am currently attending my first CCHIT meeting where our tasks and goals for the upcoming two years are being discussed. CCHIT is in process of changing its certification process to be more inclusive and nimble (www.cchit.org) . They have increased the numbers of volunteers from approximately 120 last year to over 250 this year. The new process will allow certification for EHRs either as a comprehensive suite of services which is what they had previously, however, CCHIT is also now allowing for the certification of various modules to be certified. This will allow a provider that has certain components of an HER already in place to add additional modules that are CCHIT certified that will make them eligible to meet “meaningful use” criteria and be eligible for ARRA funds. This flexibility will be very useful for providers and allow flexibility in their vendor choice. CCHIT will also allow for individual sites to be certified. This will allow providers that have developed home grown systems to have their systems certified and make them eligible for ARRA funds.
In the behavioral health workgroup in addition to representation for health centers there is representation by outpatient providers, inpatient providers, community behavioral health centers, private consultants, vendors, federal agencies and consumers.
There is a great deal of work to do to ensure that certification requirements are developed that not only meet “meaningful use” criteria and allow providers to be eligible for ARRA funds but also include criteria above and beyond “meaningful use” that make the systems actually useful for providers.
I would like to receive any comments and suggestions you might have on these criteria for behavioral health or other workgroups and will do my best to make sure your issues are addressed by the appropriate workgroup. Current test scripts and criteria can be found at http://www.cchit.org/participate/cts.
How Fast do we go
Now that I received the CIP Funds do I need to Implement Immediately?
The answer is No!!
A number of health centers have expressed the need to move forward with the purchase of an EHR quickly as soon as they receive their CIP funds. Moving quickly is not in and of itself inappropriate, however, moving quickly and forgoing the necessary planning and due diligence that is required for an EHR installation is not a good idea.
Health centers do not need to implement an EHR as soon as they receive their funds. These funds must be obligated within 2 years. It is important that health centers conduct the necessary pre planning and due diligence in selecting an EHR. Health centers are encouraged to ensure that they have board and senior management buy in, provide education to staff about the move to an EHR, conduct staff, infrastructure and organizational assessments, set reasonable goals and expectations for improved patient care and set realistic timeframes and milestones for implementation.
To rush into selecting a EHR because it worked for another health center or to purchase on your own without investigating the benefits of collaborating with a health center controlled network would not be a good use of the CIP funds.
In recent discussions with HRSA OHIT they have asked that we encourage health centers to utilize the CIP funds as soon as possible, however, discourage health centers from taking shortcuts in the implementation of health information technology. The less time you spend in planning for these large projects the more mistakes you will make and your implementation will be less than optimal.
Visit the NACHC HIT Section of the NACHC web site for some helpful information on Getting Started.
Mike
HIT Policy Committee submits proposal for “Meaningful Use” of EHRs
The HIT Policy Committee met yesterday and submitted their proposal to Dr. David Blumenthal the National Coordinator for HIT on “Meaningful Use” of EHRs. There will be an open comment period for 10 days to provide input.
In first review of the Objectives set for 2011 it would seem that health centers that are currently utilizing an HER would be able to meet the requirements for 2011. There may be some challenges from some EHRs in reporting on the Measures for 2011. I would like to hear from health centers if they are using an EHR and are not able to pull the 2011 data for the Measures.
NACHC will be submitting comments, however, we believe that this is a good first step. We may find that health centers are in a position to provide leadership and assistance to non health center providers with their meeting this criteria. Please send me any of your concerns on this proposal and identify areas where you believe health centers using an EHR would not be able to meet the Objectives or provide reports to meet the measures.
Information on the how to provide comments and the Matrix of Meaningful Use can be found on the NACHC web site.
NACHC 2008 HIT Survey
The NACHC 2008 HIT Survey is complete. No small feat. I really do want to express my appreciation to the health centers and their staff that responded and to the PCAs and HCCNs that assisted in obtaining as many response as we did.
There are some interesting results. When you review the NACHC 2008 HIT Survey you may note that there is an oversampling of health centers that have EHRs. Of the 362 health centers that responded to the survey (37% of what we sent out) over 45% identified that they had an EHR and self identified that their use of the EHR was “all electronic” or that it was “part paper and part electronic”. The results to the other questions, however, are very telling.
You will note that very few (less than 2%) of the health centers that responded would actually meet the criteria for a “fully functional” EHR. This is very important as very soon, possibly by June 16, 2009, we may see the HIT Policy Committee’s recommendations for “meaningful use” which they will forward to Dr. Blumenthal the National Coordinator for HIT. Meaningful use will be built upon the criteria of a fully functional EHR. We are watching this very closely.
Please review the survey and feel free to send in comments. I will be writing more on the results of the survey in the next few weeks.
Recap of the National eHealth Collaborative (NeHC) Board Meeting
I attended the National eHealth Collaboprative (NeHC) Board meeting yesterday. I am on the board as a consumer representative with emphasis on the underserved. There is one other consumer representative on the board and that seat is filled by Steve Findlay of Consumers Union. NeHC is a multi stakeholder public-private partnership which focuses on interoperability and the health and well being of all citizens.
During the meeting it was reported that many NeHC Board members have recently been selected to the two Federal Advisory Committees. Three Board members are on the HIT Policy Committee and six Board members are on the HIT Standards Committee. Health centers have a significant voice in the HIT Policy and Standards Committees through my participation in NeHC.
As usual the board meeting was interesting and informative. There was a presentation by John Halamka of the Health Information Technology Standards Panel (HITSP)where he outlined how HITSP has changed its focus to be more in alignment with ARRA. There are many constructs that are currently in place to guide the transfer of data from provider to provider and HITSP has developed a tool that can be used to guide this process. There are over 20 basic service capabilities that have been standardized from electronic prescription and lab ordering to requesting referrals. HITSPs realignment will help to speed up the process of interoperability. To find out more about these constructs and HITSP please go to http://www.hitsp.org/
Dr. Paul Tang a NeHC Board member and now a member of the HIT Policy Committee led a panel discussion regarding implementing EHRs in small practices. Presentations by Michael S. Barr, MD, MBA, Vice President, AmericanCollege of Physicians, Will Ross, Project Manager, Redwood MedNet, Robert Steffel, President & CEO, HealthBridge, Micky Tripathi, PhD, President and CEO,Massachusetts eHealth Collaborative were all very informative providing insight to some of the barriers and success in implementation in small practices.
Steve Findlay led a discussion on Consumer Involvement in EHRs. Presentations were made by Christine Bechtel, Vice President, National Partnership for Women & Families, Dave deBronkart, Co-Chairman, Society for Participatory Medicine, and Director of Marketing Analytics, TimeTrade Appointment Systems (Blogs as “e-Patient Dave”), Deven McGraw, Director, Health Privacy Project, Center for Democracy & Technology and Jody Pettit, MD, Health IT Consultant. The focus of this panel was ensuring that consumers are involved in their healthcare, have access to their electronic records and the use of security and privacy as an enabler vs a barrier in the adoption of EHRs. All agreed that in order for consumers to have confidence in EHRs, interoperability and its benefits consumers will need to trust the systems and know that they can review their records at any time.
The NeHC Board then met in private session with Dr. David Blumenthal the National Coordinator for HIT to discuss issues related to NeHC and its ongoing involvement with ONC. More will be forthcoming on this issue in the next several weeks. I did discuss with Dr. Blumenthal’s staff the development of “listening teleconference sessions” specifically targeted towards health centers and I will be coordinating these with ONC over the next several months.
NeHC board meetings are open and transparent. They are open to the public for in-person and teleconference attendance, are audio taped and now videotaped. The public private and broad stakeholder involvement of NeHC is unique in the HIT space and the only organization that is organized in this manner.
To find out more about NeHC please go to http://www.nationalehealth.org/
Public Comment Period Opens for ATA TMH Evidence Based Practice Document
The American Telemedicine Association (ATA) has opened a public comment period on their Evidenced Based Guidelines for telementalhealth. This is a significant step towards providing basic guidelines for the practice of telementalhealth services. With the growing need to provide behavioral health services in health centers using this guide can assist health centers in developing their telementalhealth program. It is increasingly important to note that telementalhealth services are needed in urban as well as rural areas. We expect some movement this year in addressing the current restrictions on receiving payment for telemedicine services in urban areas. The ATA is very active on this issue and NACHC may join in their efforts to mover this along. In the meantime please review the ATA guidelines and provide any comment. We will also post the final guidelines once they are published.
Public Comment Period now Open for ATA Document:
Evidence-Based Practice for Telemental Health
Deadline for Comments: June 11, 2009
The ATA Evidence-Based Practice for Telemental Health document is now open for public comment Click Here to access the document from the ATA home page. Confidential comments and views will be accepted through June 11, 2009. Please submit your comments directly via email to Jordana Bernard at jbernard@americantelemed.org. When providing a comment relative to a specific section in the document, please include the respective document page and section.
American Psychological Association and Opportunities for Health Centers
I just came back from spending three days with the American Psychological Association Senior Leadership on their “Future of Psychology Summit”. The APA brought in senior leaders and guests from across the country to discuss where psychology is going and/or should go in order to remain an integral part of health, healthcare and healthcare reform in the future.
There are great opportunities for psychologist to provide behavioral health services in community health centers and the APA is very enthusiastic about fostering relationships with NACHC and health centers. They are considering reevaluating their training requirements to make health centers more accessible as APA accredited training sites, joint training initiatives and activities with the A.T. Still Hometown Program and other initiatives.
Of particular importance to Health Center Controlled Networks are opportunities for HCCNs to be the hosting site for the many psychologists that will need to implement EHRs. This can be a tremendous opportunity for HCCNs. There are over 62,000 licensed psychologists who are in private practice that will need to be using EHRs.
More to come on these opportunities in the future.
Visit the APA at www.apa.org
Michael Lardiere, LCSW
Director HIT; Sr. Advisor Behavioral Health
EHR Vendor Pricing
Over the last few weeks I have begun to receive several examples of EHR vendors pricing their products to the exact amounts that are identified as the Incentive Payments under the Medicaid Incentives.
It is important for health centers to check out the vendor pricing with other health centers to determine if they are indeed in the same ballpark as others. We do need to recognize that the services that the vendor may provide to one health center may be different than those provided to another health center, however, the basic pricing for provider licenses should be relatively the same. Add on services will make the pricing different from center to center.
It just seems strange to learn of a pricing quote that comes exactly to what the ARRA will reimburse eligible providers under the Medicaid Incentives when in the past the numbers have been different. Different as in lower.
As is always the case health centers should discuss their needs with each other, with other health centers that have purchased products that health centers are considering and with Health Center Controlled Networks in order to determine the best pricing and product combination.
Health centers should be aware that under the Medicaid Incentives any costs associated with the implementation of an EHR that the health center does not pay the vendor health centers will be able to keep in house and use those funds for other enhancements or for other services the health center may provide.
Michael Lardiere, LCSW
Director HIT; Sr. Advisor Behavioral Health
“Meaningful Use” of HIT
I attended the National Committee on Health and Vital Statistics public hearing on the “meaningful use” of HIT on April 28 and 29, 2009.
Over the two days of the hearing several panels presented information to the Committee and provided various perspectives on what to consider as “meaningful use”. No clear determination was made at the meeting, however, there were several themes that emerged.
Recurring Themes
Most all participants were in agreement that the end goal is improved individual health and improved population health and well being. In order for this to occur systems must be interoperable i.e. systems must share data and information. This includes state level systems such as state immunization registries and federal systems. The technology is here. The national will to grapple with some of the issues around sharing data across states and other data sharing issues need to be addressed. Standards are in place which are good enough to move forward on these issues. More work needs to be done but there is enough of a structure to move forward now. ePrescribing is an integral component of “meaningful use” and was identified as a starting point for many providers. Clinical Decision Support, Reporting on Clinical Measures and Sharing Data with Public Health agencies for bio surveillance are other components that were addressed by many of the speakers.
Include All and Move Incrementally
Two other areas that were identified as crucial to “meaningful use” by many speakers were the need require all providers to participate and to allow providers to move incrementally to the full “meaningful use” requirement no matter what definition is finally fashioned.
Quality Improvement Networks
Quality Improvement Networks were suggested as a structure to be utilized to study different interventions and uses of EHRs. Many PCAs and Health Center Controlled Networks are in an excellent position to become these networks. Look for more information on the development of these QI Networks coming from AHRQ in the near future.
I also provided comment to the Committee encouraging them not to solely rely on administrative data i.e. claims data, to measure “meaningful use”. Since so many health center patients are uninsured claims data would not adequately measure health centers “meaningful use” of EHRs.
Lastly many of the speakers identified the need for hands on SWAT teams to assist providers prior to, during and after implementation of an EHR. Just providing a web site and tools is not sufficient to move EHR adoption quickly. Look for more information from NACHC on this issue in the future.
Michael Lardiere, LCSW
Director HIT; Sr. Advisor Behavioral Health