ONC: A Call to Action

As our readers know, EHR Bloggers has been a constant supporter of David Blumenthal and the Office of the National Coordinator for Health IT (ONC) generally. Nothing in this post changes that.

We wish to express concern however, about the pace with which ONC’s good work is unfolding, and the relative timing of its many initiatives, especially when considered against the January, 2011 deadline after which time providers supposedly can begin collecting bonus payouts from Medicare if they demonstrate meaningful use of a certified EHR.

In a nutshell, 16 months before that go-live date, ONC has yet to nail down a definition of meaningful use, and has barely begun to establish a certification process for EHRs.

For the second matter in particular, that’s a lot to do in not a lot of time.

ONC had planned to have finalized meaningful use criteria by this January, but after receiving far more public feedback than expected, ONC punted the sign-off date all the way to spring.

In itself, the delay appears innocuous, but seen in the context of ONC’s complex agenda and recent developments in the marketplace, the delay could spell trouble (as we describe below).

Meanwhile, the EHR vendor certification process remains in a planning stage. ONC’s HIT Policy Committee announced a few weeks back that would recommend that 10-12 entities be empowered to certify EHR systems but so far as we know, ONC has not signed off on this, much less begun to screen and select the entities.

Entity selection itself will take time, yet it is a relatively small step in the deployment of a full-blown certification process. Among other things, certification entities will have to:

1. Hire or retrain people to perform EHR certification. No one knows how easy this will be, how much and what kind of supervision these people will require, or how well they will perform in their new role. And of course, certifying entities can’t finalize training procedures until ONC has signed-off on those meaningful use criteria.

2. Schedule certification reviews with EHR vendors. The day these entities open for business is going to be a madhouse. EHR vendors will descend on them like pigeons in St. Mark’s Square.

3. Implement high quality customer-support and help-desk functions. EHR vendors believe that time is of the essence; they must be certified by on ONC-designated entity well before January, 2011 so that providers can be assured they will qualify for bonus payouts from Medicare. Since the certification process is likely to be bumpy and inefficient early-on, entities must be prepared to provide exceptional service, particularly with respect to follow-up after the initial vendor review.

(NOTE: A key strategic issue for ONC—or possibly NIST—is to decide whether certification entities should include a “provisional certification” category, as is offered by the JCAHO in its hospital accreditation process. Provisional certification would be reserved for vendors that meet most, but not all meaningful use criteria. And if there is such a category, ONC/NIST must then decide whether providers who use provisionally certified EHRs qualify for bonus payouts.)

ONC’s punt on finalizing meaningful use criteria, and its seeming tardiness in firing-up the certification program seems likely to create confusion on several fronts.

Take for example, ONC’s recent announcement that it will soon begin distributing $600 million in grants to help create a national network of training centers that helps providers select, implement and meaningfully use certified EHRs.

ONC wants 100,000 PCPs to have demonstrated meaningful use of a certified EHR by December, 2013—an aggressive target—so it plans to begin awarding grants to so-called Regional Extension Centers (RECs) as soon as Q1, 2010.

But ONC’s above-mentioned delays means the newly christened RECs will face, at least temporarily, the unenviable task of recommending EHRs without knowing what meaningful use means, much less which EHRs are certified.

This could result in political fallout for ONC since taxpayer money used to support RECs before meaningful use criteria are established and EHRs are certified can be perceived as having been wasted or at best, used inefficiently.

And then there’s the Certification Commission for Healthcare Information Technology (CCHIT), which remains to this day the only game in town when it comes to EHR certification.

This is lamentable since the Commission has no track-record in promulgating outcomes-oriented certification criteria of the sort contemplated by ONC, much less certifying against them, and since it has done quite a good job of muddying the waters and scaring the bejesus out of EHR vendors hither and yon.

The sooner ONC finalizes meaningful use criteria and sanctions certification entities and processes, the better. Until it does, there’s going to be a lot fear and loathing out there. And if ONC isn’t careful, the angst will eventually find a resting place right on its lap.

Glenn Laffel, MD, PhD
Sr. VP Clinical Affairs, Practice Fusion