In light of GE Healthcare’s recent announcement of potential errors in their certified EHR’s reporting functions, it seems reasonable to expect that more hospitals will be re-evaluating their own EHR’s reports…

and in some cases, self-certifying that capability. And we recently had an interesting question from one of our subscriber hospitals that just finished a broader self-certification initiative of their overall EHR technology inventory. This group didn’t build their own, but assembled best-of-breed tools from multiple vendors. By picking and choosing components, they satisfied clinical staff and managed costs, but were unable to take advantage of all the vendor-provided certifications. This forced them into “self” certifying a select number of modules to meet the requirement of using a “complete” certified EHR.

We wondered about how many other hospitals were seeking self-certification, and for what functionality. A little research into the CMS web site ( listing organizations that have certified EHR software, answered some of those questions. Here’s what we found (as of 11/05/11):

1. How Prevalent is Self-Certification?

Only 18 hospitals (or hospital systems) have completed any level of self-certification.

2. What Self-Certification Strategies are Hospitals devising?

Those 18 hospitals have certified 28 unique “product bundles”. Most are certifying “Modular” rather than “Complete” EHR functionality with only 5 of 18 pursuing Complete Certification. Of those 5, we know a couple personally. In several cases, hospitals have their own internally-developed custom EHR’s, but in others, self-certification comes from a strategy of purchasing best-of-breed components. In some of these cases, the hospital has purchased a subset of a Vendor’s certified product, and by purchasing less than the Vendor’s full suite, invalidates the Vendor’s certification.

3. What Functionality is being Self-Certified?

What we expected to see, was a preponderance of hospitals self-certifying reporting functions of Clinical Quality Measures, and Automated Measure Calculation. While there is certainly a significant amount of self-certification of reporting involved, almost every Measure is represented in hospitals seeking modular (partial) self-certification.

4. How Successful are Certification Efforts?

Of those achieving modular certification, some appear to be attempting certification as complete EHR, and accepting partial certification when some components don’t pass … then re-submitting for additional testing at a later date. Of course, we don’t see those who have attempted and failed, but some hospitals show multiple certified versions of the same product, with earlier products containing less certified functionality.

5. What is the ATCB mix (Which certifying bodies)?

16 by CCHIT, 9 by Drummond and 3 by InfoGuard. Percentage-wise, this is almost identical to the mix of ATCB’s used by the vendor community. In other words, no single ATCB has emerged as the entity of choice for self-certification activities. CCHIT has two hospitals who appear to have been through multiple iterations to meet their certification goals, and Drummond has one. Based on this limited data, but it appears all ATCB’s are equally rigorous. It might be interesting to get some anecdotal or other data to learn a bit more.

So, to summarize there’s not been much self-certification yet, there is little “pattern” in what content is self-certified, and it is being done by about the same mix of ATCB’s as what is being certified by vendors. If you are considering self-certification, and want to talk to someone who has done it, scan the CHPL site, looking for hospital names and give the CIO a call. There are not many!