Monday Musings

-- ONC has transformed an entire industry with the stroke of a pen. Its Interim Final Rule should be subtitled “A Vision of the Future State.” Step back for a moment from any short-term implementation challenges you see and imagine what health care would look like if this thing actually worked.

-- As we speak, every EHR vendor in America is knee-deep reviewing their capabilities against the ONC criteria. Those who tell you they're not, or who sound nonchalant about it, I have a problem with that.

-- I don’t think the $44K HITECH incentive is big enough to drive the EHR uptake numbers ONC predicts in its Regulatory Impact Statement (page 94). I’d double it, at least for 2011.

-- KLAS, a consultancy, released a study last week that predictably, played things down the middle: on one hand, the study found that CCHIT-certified EHR venders might have a leg-up on competitors in the race for the HHS Gold Star for reasons X, Y and Z. Then again, the study also found that many of these vendors are woefully lacking in health data exchange, quality reporting and patient access to medical records, among other things.

-- By the way, I couldn’t determine from the information available from KLAS for free whether any EHR actually passed all 25 certification criteria. Guess I’d have to pay for that. Then again, I think I already know the answer.

KLAS: Accurate. Honest. Impartial. For a Fee.

-- Quote of the Week: “Despite its apparent similarities with meaningful use requirements, CCHIT certification is not a guarantee that an EHR system will enable users to qualify for incentive payments, according to federal officials.” (iHealthBeat)

-- Look, it isn’t about how many issues an EHR vendor needs to solve before qualifying for a Gold Star from HHS. It’s about how quickly a vendor can pull it off. One would think a nimble organization with a well-designed platform could move pretty quickly in this regard. Then again, one would think a well-managed big company can do the same using an aggressive acquisition strategy and just generally throwing its weight around.

-- By the way, is it true the term “regulatory capture” was invented to describe CCHIT?

-- Speaking of ONC and CCHIT, I thought “frosty” was a word that describes the weather, but are they even talking right now? When Blumenthal recently reiterated that ONC’s Interim Final Rule “would have to be (implemented) by some certifying body,” and that ONC will have to create a process to recognize that body, he wasn’t talking about your mother’s mince pie, after all.

-- Oh, and I haven’t heard a peep from the billing vendors. You know, the ones who we assume are gearing up to get certified as “EHR Modules?” It’s either that or they integrate with 50 EHR vendors in no time flat. That's some choice right there. Reminds me of my college roommate Jim Buckley saying “Heads I win, tails you lose!”

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