Let’s face it folks, health care software can be a real pain. Not only is it massively complex, infinitely deep, requires 1000 people to run and even more to maintain, but it is often a major slowdown for the practice. Physicians and nurses often have to struggle through inefficient processes set down in a very inflexible manner by unforgiving software.
All of that being said, the EMR / EHR systems of today are absolutely critical to the survival of health care. These electronic systems are absolutely necessary for patient safety and to allow ever shrinking pools of physicians to treat ever growing populations of patients.
Dr. Steve Levinson’s comments regarding the CCHIT certification requirements speak to both sides of an evolving issue with the usability of the EHR and EMR. The following is posted with his permission. We both hope that you will comment on this item so additional pressures can be put upon CCHIT.
Dr. Levinson’s comments:
I am sending this and similar e-mails to my colleagues and acquaintances whom I have met and worked with in pursuing health care quality and compliance, particularly as they relate to electronic health records:
As you know, existing EHRs have created significant barriers both clinically and with relation to compliance. As you also know, I believe these two aspects of care are two sides of the same coin. I am writing to request your review and encourage your response to CCHIT with regard to the attached proposal I made when CCHIT invited input for new criteria. (I would also appreciate your forwarding this e-mail or commenting on this blog to others who you believe would also contribute significant comments on this proposal).
Therefore, this is a request that you participate in an important opportunity to promote a significant improvement in CCHIT’s Certification Criteria. In December, CCHIT issued a call for suggestions to expand their current criteria, particularly for outpatient electronic health records (EHRs). I submitted a formal request to introduce meaningful criteria for “EHR Operability” (i.e., criteria for functionality, which will ensure that certified EHR systems meet the operability and functionality criteria of physicians, compliance experts, IM specialists, and practice management experts: usability, efficiency, data integrity, ensuring compliance, and promoting quality patient care). Please review and scrutinize this proposal seriously. I believe that this proposal reflects AHIMA’s 2007 policy statement on EHRs, and it offers the opportunity to fulfill the requirement I cited in Practical EHR that “EHRs must be operable as well as interoperable.” CCHIT announced its comment period on January 15th, and it is to extend only to February 5th, so we have only 2 more weeks to submit our comments.
[As background information, most currently available EHR systems (including those certified by CCHIT) fail to provide appropriate documentation and coding designs or functionality for E/M compliance, and these systems therefore fail to meet physicians’ needs for individualized high quality patient records (which correlates with compliance). Over the last several years I have personally discussed the potential for adding audit-protected and compliance-enhanced versions of their software with the leaders of numerous EHR vendors. The most frequent response I encounter, especially from the large established vendors, is that they will not modify their existing software unless and until they are required to do so, either by:
1) Insistence on such features by all the medical practices using or seeking to purchase their software; or
2) Inclusion of such features as criteria for CCHIT certification
While “Practical EHR” provides physicians and medical practice managers with the explanations and tools to justify demanding these features of their vendors, it is not likely that 600,000 physicians will have read the book and endorsed these principles within the next one to two years. However, lobbying CCHIT to incorporate a set of compliance-based (and quality care based) EHR Operability Criteria is within the realm of possibility.]
This is an opportunity for the physician, compliance, information management, and practice management communities to unite in support of a proposal that certification include criteria that meet the needs of our specialties and our patients. I very much appreciate your reviewing this proposal and sending in a comment sheet to CCHIT. I believe you will find that the general principles in this proposal match your (and your organization’s) principles for quality medical records. All support is welcome and needed, as CCHIT needs to appreciate that there is a mandate for including operability criteria. In addition to your endorsement of the basic concepts presented in the proposal, I also encourage that you submit any and all constructive suggestions to refine it further and help to make it better.
Please visit the CCHIT web site that contains all these materials: http://cchit.org/expansion/ This site has five downloadable documents (two of which are attached below, along with my proposal itself):
1) The public comment form, which is a WORD document that you download, complete, and send as an attachment to an e-mail back to expansion@CCHIT.org
2) CCHIT Draft expansion roadmap: this PDF describes CCHIT’s current program for expansion of its certification criteria. The “EHR Operability” proposal is identified on page 3 as the third proposal listed under the header “Domain.” This PDF also includes most of the instructions for submitting comments.
3) Appendix A: this PDF is a POWERPOINT presentation of an overview of CCHITs process for expanding its criteria
4) Appendix B: this PDF contains the submissions submitted by various parties (as summarized in the draft expansion roadmap). The detailed submission for EHR Operability appears on pages 24-29 of Appendix B, where you can review it and/or print it
5) Appendix C: this PDF contains extensive supporting documents for a number of the submitted proposals. It has no information related to the “EHR Operability” proposal
In summary, you can read or print this proposal from pages 24-29 of Appendix B, then complete and submit the public comment form as an e-mail attachment to expansion@CCHIT.org by no later than February 5th. I would also appreciate your forwarding this request to all of your colleagues, (and to the organizations to which you belong) who you believe will want to contribute a meaningful and supportive comment to CCHIT as well.
Many thanks for your consideration and anticipated participation in this opportunity to have a significant positive impact on the future design and functionality of electronic records. Please send an e-mail or call me on cell phone with any questions and to let me know your response to this project.
Steve
Stephen R. Levinson, M.D.
ASA, LLC
48 Dogwood Drive
Easton, Connecticut 06612
