As I’m planning the rollout stage of my project to interested developers and physicians, I am pondering the implications of certification for the NOSH ChartingSystem. As a background, an electronic health record system has to be certified by one of 5 Authorized Testing and Certification Bodies approved by the Office of the National Coordinator for Health Information Technology (ONC-ATCB) so that a user (physician, practice, or hospital) of the system can claim for monetary incentives from Medicare or Medicaid when the system has demonstrated “meaningful use”.
These ONC-ATCB’s (the largest being CCHIT) ask for pretty hefty fees to test your system to get the certification, ranging between $20,000-$40,000. Furthermore, as I understand it, the certification applies to the specific version of the software only, so if you have continued updates and modifications, you’ll have to re-certify your product. No wonder most EMRs cost so much to the doctor – the costs likely get passed down to the doctor for the certification.
Furthermore, based on the HITECH Act that was passed in 2009, physicians who see Medicare patients and who do not use a certified EMR by 2015 will see a gradual reduction in payments (1% per year) as a penalty for not using a certified EMR.
In my own personal experience as a solo family doc, I used an EMR ever since I began my practice in 2004. Unfortunately, I had a version of an EMR that was not certified and I wasn’t able to upgrade due to the significant increased cost for a certified product (being a primary care physician). Looking at all the core standards that attest to meaningful use, my practice and system met all the standards, but I would not be able to claim incentives due to my EMR being uncertified. Knowing that I was going to see reduced payments (with already reduced payments across the board from Medicare and insurance companies by not keeping up with inflation), I felt that the system was somehow rigged against me even though I “did the best thing” with electronic health records.
CCHIT then came out with a separate program (called the EACH program) for people with “legacy” systems that did not qualify for certification but if all the technology that was used in the entity met “meaningful use”, then they could alternatively certify the system. Unfortunately, I got a heart attack with the price tag of “gasp!” $40,000 (that was more than 50% of my income!!!).
And so, regrettably to my patients, I opted-out of Medicare as I saw no light at the end of the tunnel. (More about that at my other blog). So now that I have my electronic health record system waiting in the wings, an open-sourced product with the aim of being low-cost to the physician, does it even make any sense to be certified? Is the risk of Medicare payment reductions worth it for physicians wanting to use a low-cost system? I also think (but I can’t confirm) that most physicians would rather buy a certified product just because it is. But if an uncertified product was incredibly intuitive to use and that it would actually help their productivity so that they can spend more quality time with their patients and improve outcomes, would it offset the risk?
At this stage in the game, I obviously cannot afford to certify my product. Even if I could afford to certify it one time (I was thinking of Kickstarting my project for the aim of certification), the whole concept of this type of certification is antithesis to the open-source way (updates, modifications, improvements, low cost). But I think if there was a growing community of doctors along with like-minded computer programmers and developers who stand in solidarity against this rigged game and somehow these rules were reversed through political means or by sheer mass protest, I’m all for it!
What are your thoughts?