EHR Certification - Should CCHIT be "it"?

I posted this comment a couple of days ago on the ONC blog here. They finally moderated the comment and posted it this morning, so here it is again. I will have more on the ONC NPRM later....

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OK, I can’t believe I’m typing this, but I am.
As anybody that reads things I write, or listens to things I say, knows, I had lots of isrues with the way CCHIT operated in the past and the effects it had on the EHR industry. However, currently CCHIT has a complete certification infrastructure in place ready to service both comprehensive EHRs and EHR modules immediately. No other organization is even remotely close to such capabilities.
I do believe your long term accreditation plan is good and much needed.
However, I would like to suggest that the entire temporary certification program needs to be scratched and that CCHIT be awarded ONC-ATCB status so certification processes can begin now. I don’t really see the value of engaging in a formal lengthy process just to create temporary bodies of certification. I also don’t see how submitting a bunch of forms and documentation to ONC and taking a quiz can provide assurance to both vendors and physicians that these newly accredited temporary bodies really know what they are doing, considering they have never tested an EHR before.
I believe ONC is underestimating the complexity of certification and the infrastructure required for a successful program, even a temporary one. Please remember that if all goes well, there will be a tremendous wave of adoption in the coming year and it will all be done under temporary certification bodies. In order to sustain future expansion of HIT, it is imperative that physicians have a good experience in 2010-2011.
I can easily envision horror stories, particularly regarding EHR modules, created by small underfunded vendors, getting temporary certification and providing nothing but disappointment and financial loss to customers.
In the engineering world, reinventing the wheel is not considered a worthy endeavor. CCHIT is there. It is experienced. It is up to date in it’s infrastructure and readiness. It has created a pared down ARRA certification and kept up with all ONC/CMS changes.
So why not let CCHIT start working on a temporary basis, while ONC begins the long term accreditation process for all applicants? Wouldn’t it serve the market and all our goals better?
It’s the simplest, cheapest, fastest and least risky solution and it’s the right thing to do.