Legislation is a funny thing. Sometimes one individual word snuck in here or there takes on a life of its own. This has certainly been the case with the Health Information Technology for Economic and Clinical Health (HITECH) provisions within the American Recovery and Reinvestment Act (ARRA – aka the stimulus bill).
Two key phrases within the bill have garnered a lot of attention: “Meaningful Use” and “Certified Electronic Health Record”.
Discussion of certification has taken an interesting path. The Certification Commission for Healthcare Information Technology (CCHIT) has always been presumed to be one of the options that would be available for certification. While ONCHIT has left the door open for competing certification options, they are currently the only entity that is ready to begin certifying software for HITECH.
One area of concern from the onset with CCHIT had been their approach to certification. CCHIT certified comprehensive enterprise systems in their entirety. As such their process was expensive, placing it out of reach of smaller vendors and open source solutions, and is only appropriate for a small number of HIT solution providers. CCHIT has been responsive to criticism and has revamped their process for certifying HIT solutions for HITECH. In addition to their comprehensive certification approach, updated to focus exclusively on the Meaningful Use criteria, they have added Modular Certification that will allow vendors to certify solutions covering individual Meaningful Use requirements.
I see where certification can be useful in some scenarios, but for HITECH, I don’t get the point. Certifications are now based on the Meaningful Use criteria, as they should be, but Meaningful Use isn’t just ‘require the acquisition’ or ‘implementation of tools’. In order to qualify for HITECH funding, providers need to demonstrate that they are actually using the software and will need to provide metrics relating to its use (hence the term “Meaningful use”).
So, the CCHIT certifies that a piece of software does some designated piece of functionality that we’ll call “X”. (Do you define the ‘Provider’ too?) The Provider buys the software and implements it so that they are getting the desired number of X-type transactions. Then the Provider measures, tracks and reports that they’re doing that number of X-type transactions.
If the provider needs to demonstrate meaningful use, what’s the point of them having to do it with certified software?