1. Slow down the certification definition process. There’s absolutely no hurry – the price of getting it wrong is far higher than any potential benefits of certification.
2. Do not define certification language until meaningful use is fully defined. Meaningful use must drive certification and not the other way around.
3. Certify the minimal things possible – focus on data, not software, technology, requirements, or functionality. Data sharing alone is the maximum that certification should go.
4. Certification of data interoperability is good because information exchange is important. We should rally around NIST’s Laika tool as the maximum certification requirement and could be even less than that. Laika is open source, created by NIST and Mitre, approved by ONCHIT, and is supported by CCHIT.
5. Certification of application functionality is very dangerous because it stifles innovation and writes into law software requirements that should be decided by the marketplace.
6. If the full CCHIT certification requirements are written into the federal regulations it will mean the death of innovative healthcare information technology and will mean Physicians will end up paying for unneeded functionality and large, bloated systems.

I wish that – collectively, as an industry – we had the knowledge to say “yes, this is exactly what we need.” But we don’t, and we won’t. Certification has been historically successful  when you’re certifying something that can be effectively automated. Interoperability certification meets this criteria. Functionality and feature sets don’t.