While the Office of the National Coordinator for Health IT (ONC) has been moving at a pretty good clip since December when it released the "meaningful use" notice of proposed rulemaking (NPRM) and certification interim final rule (IFR), right up until the announcement this week of its final temporary certification program, it's apparent just how jammed up its timeline is becoming.
While the Office of the National Coordinator for Health IT (ONC) has been moving at a pretty good clip since December when it released the "meaningful use" notice of proposed rulemaking (NPRM) and certification interim final rule (IFR), right up until the announcement this week of its final temporary certification program, it's apparent just how jammed up its timeline is becoming.The temporary program seems clear enough, as there's minimal departure from the one proposed in the NPRM for the certification process released earlier this year, and by waiving the customary 30-day delay between publication in the Federal Register and enactment, it's also clear ONC is doing everything possible to remove lags in the process. On July 1, or thereabouts, the temporary rule (or something like it) will become law, and organizations can start applying for ONC Authorized Testing and Certification Body (ONC-ATCB) status.
But right off the bat, we see the process creeping into summer and, eventually, fall. ONC, of course, needs time to evaluate the applications, and has given itself at least 30 days to do so. And once organizations start to receive their ONC stripes, they'll then have to develop a process for electronic medical record (EMR) vendors to apply for certification with them. Once the industry understands those requirements, vendors will have to prepare their applications, which could take considerable time when appreciating the complexity of these technologies and the costs of applying (which I'm sure won't be insignificant). Then the ONC-ATCBs will have to evaluate what will certainly be a glut of applications.
And just how many ONC-ATCBs will be on the market to handle the tsunami of applications? By my count, possibly two -- CCHIT and the Drummond Group. After they stamp their imprimaturs on the applications, the vendors will then shout to the market that they've been certified, so you can be sure there will be a glut of advertising and marketing spend to get the word out.
And then it will be time for those physicians (and few hospitals) who've been waiting for a government-approved stamp to hit the market and buy something. When might that happen in earnest? October, November? Of course, the day I bought my iPod I could do little more than turn it on, so how long will it take for those organizations to become meaningful users of the technology? And remember, ONC's meaningful use looks to be of the most serious and intense kind, with all sorts of quality reporting and electronic output of data for patients.
ONC's certification goal has always been to make it easier for the less-savvy buyer to navigate the marketplace. It may be on the road to finally making that vision a reality, but how do the dates jive with its parallel vision to reward those clinicians for meaningfully using the technology? To me, it's clear the whole process is about a year out of whack. If certified products are going to hit the market in fall, why not give clinicians a year to study them before testing what they've learned.
On day one, I could barely turn on my iPod, but today, I've got my podcasts automatically downloading into it. I've come a long way, and the physician community will too. ONC just needs to give them a little more time.
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