Yesterday, the CCHIT released the draft (warning PDF) for PHR certification for public comment. I have never been a fan of this effort by CCHIT as the PHR market is simply too immature for any prescriptive certification process. Honestly, I’m not so sure CCHIT certification of EMR is of any value either. Having come from the manufacturing sector, one never saw such certification processes for any critical enterprise software, be it Enterprise Resource Planning (ERP), Customer Relationship Mgmt (CRM), Supply Chain Mgmt (SCM), Product Lifecycle Mgmt (PLM), you name it – Nothing! So again, why do we need one here?
But I digress.
Getting back to the CCHIT PHR Draft, took a quick scan and can take some comfort in what they have done, despite my misgivings, for a couple of reasons:
1) They chose not to be too expansive on this first round and are focusing certification efforts on fundamental and important issues of Security, Privacy and of course, (afterall this is CCHIT), Interoperability.
2) They did not try to re-invent the wheel and are instead relying heavily on the work of others, most notably, Markle Foundation (Connecting for Health) and HL7’s PHR Functional Model and framework.
But I do have some concerns.
1) Clearly, the roadmap for future certification (most importantly, interoperability) is being heavily influenced by HL7 proponents. This is not a good thing as HL7 standards, and even the functional model are not exactly easy to work with and will drain precious development resources away from more pertinent activities.
2) CCHIT has all sorts of plans for adding additional certification requirements on their roadmap. Why they felt they needed to even go there, I haven’t a clue, unless it is simply to guarantee future employment.
3) Proposed criteria mandates CCD/HITSP standards for interoperability on “Registration, Allergies, Medications and Immunizations”. Now that is very prescriptive! Actually stating only one specific standard, especially when there is currently a dearth of EMR adoption among physicians, seems ludicrous. Is this really warranted at this time? Bet Google isn’t too keen about this either since they are using a modified version of the CCR, and have no plans to accept unstructured data, e.g. advance directives. But then again, Google doesn’t seem to be to worried about anything in the healthcare space as of late (see yesterday’s post below).
Wrap-up:
Sure, the PHR vendors can put a team on it, hire some consultant(s) etc. to address and comply with the CCHIT certification criteria, but this is not what the market needs right now. Rather, the market has far more basic needs, like just getting consumers to adopt and use a PHR. Will CCHIT certification encourage adoption? Unlikely.
What is really needed is the devotion of those precious development resources to create applications that provide some real, compelling end-user value. CCHIT certification will be of little use in creating that compelling consumer value proposition. Distracting vendors from tackling that problem and instead having them chase this one is unfortunate.
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