Certification Retrospective -- Part 1

Note: this blog post will discuss my experiences in CCHIT. The opinions are mine, and do not necessarily reflect the views of CCHIT or Siemens.

It’s been a long time since I blogged, even though there have been many HIT topics to blog about, such as Stage 2 meaningful use, the ONC Standards and Interoperability Framework, the ONC Strategic Plan, the NPRM on Medicare Shared Savings (Accountable Care Organizations), and more. I’m getting back on the wagon. One topic I’ve wanted to blog about for a while, even though it’s not a current “hot topic” in the news, is my experience in the Certification Commission for Health Information Technology (CCHIT) prior to the establishment of the ONC certification program. This bubbled to the surface when I read a HISTalk “Time Capsule” posting. So I’ll write another mini-series (probably two or three parts). This first post will simply introduce the “cast of characters” and how they interacted. The next posts will talk about what the Interoperability Workgroup of CCHIT did, and how its work through 2009 related to the ONC-ATCB certification program as we know it today. There are useful lessons learned.

As a matter of disclosure, I’ve been a CCHIT volunteer for more than five years, and am still officially a co-chair of CCHIT’s Interoperability Workgroup, but this group has been inactive for about a year though it still nominally exists. The reason for its inactivity is that it was chartered as a group to propose certification criteria EHRs, a role that was displaced by ONC and the HIT Standards Committee. CCHIT still offers its branded certification program called “CCHIT Certified®” that is completely distinct from the ONC certification for which CCHIT is an authorized testing and certification body (ATCB). The branded program includes criteria that I and many others worked on until 2009. In interoperability, CCHIT is currently performing testing based on the NIST test scripts and some optional tools, but it is not developing any new interoperability criteria at this time.

Industry collaboration – whether in standards organizations or groups like CCHIT – has been a rewarding and mind-expanding aspect of my career. It’s about the people who work together to benefit many more people (e.g., patients and providers), trying to leave their agendas and “organization hats” at the door. So this first post focuses on some facts about the volunteers of CCHIT interoperability.

I found it fascinating to compile a list of the people I’ve served with on Interoperability workgroups at CCHIT. See this link for a table of volunteer names. It’s a pretty diverse and impressive list, IMHO. The list of CCHIT workgroup members has always been publically posted, though I don’t know if it’s preserved historically, so I had to dig through my archives. My apologies if there are some typos in my list. The organizations listed were as of the time the people were on the workgroup, not necessarily where they are now. And occasionally there were people who had to resign for lack of time and a few were replaced but that may not be reflected in my table.

Each year, the Interop Workgroup had between 13 and 24 members (the 24 divided into two groups). Over 60 members served on the workgroup at some time. Of these, 9 were from EHR vendors (only counting vendors of products subject to certification, not vendors of different product types like e-prescribing, lab systems, or HIE tools). The EHR vendor reps were generally active participants, but they didn’t dominate the workgroup. Of course, there are many other interoperability experts who could have been on CCHIT but weren’t, since there was limited space. In that sense, CCHIT was not open like a Standards Development Organization, but it tried to establish a small committed group of volunteers, selected by an application process according to guidelines for stakeholder balance. Sometimes, we knew what we didn’t know, and invited guests to educate us at our meetings, on topics like e-prescribing, vocabularies, and clinical documents.

Sometimes the group was split into an Inpatient Interop WG and and Ambulatory Interop WG (in which case I was on the Inpatient side). In the last year, it divided into an Advanced Interoperability WG and a “regular” Interoperability WG (I co-chaired the latter). Usually a small subset of volunteers would work on specific subsets of criteria (e.g., Lab, eRx, clinical documents) and the entire WG would review and refine.

I have very positive feelings towards these people. They’re some of the finest I’ve worked with, and I am grateful to them. There was a strong sense of collegiality and teamwork, and the sense that we were doing something important. While there were downsides to the group being selected rather than open, that also helped motivate most members since they couldn’t passively leave the work to “someone else” as tends to happen in larger groups. Collaboration was real across different stakeholders and even among vendor competitors. Sure we wouldn’t always agree. Some members thought criteria should be much more aggressive. Others couldn’t understand why features they regarded as only “nice-to-haves” should be mandatory for certification. Sometimes (as co-chair) I’d feel frustrated if I thought someone wasn’t pulling their weight (e.g., not showing up for meetings). It’s inevitable that in volunteer organizations not everyone contributes equally, but everyone had the opportunity.

In acknowledgments, there’s always a risk of omitting someone important, but I especially want to thank Amit Trivedi and Anita Samarth who alternated as CCHIT staff leads for interoperability. Their support was tireless and outstanding: I still remember 4am e-mails from both of them as they worked towards tight deadlines! And I really appreciated the commitment, passion, and the desire to do the right thing, from my fellow-co-chairs such as Dr. Alan Zuckerman, Dr. Pat Hale, and George Robinson.

The Board of Commissioners was mostly “out of sight” for the workgroup. They respected and endorsed the expertise of the volunteers, but would attend our meetings if we needed them (Dr. Leavitt did this several times), offering guidance but not dictating what we should do. I only remember being “overridden” by the Board on one substantive issue.

In the subsequent post(s), I’ll talk more about the interoperability work products that we developed, how it related to standards organizations, ONC, and what I would have done differently if I could start over.

David