CCHIT meeting FOSS at HIMSS

3 views
Skip to first unread message

fred trotter

unread,
Mar 14, 2009, 2:45:08 PM3/14/09
to openh...@yahoogroups.com, open-ehealth-...@googlegroups.com, Hardhats, Mark Leavitt, Dennis Wilson
Hello,
Recently, I was asked by several community members to
begin 'activating' the community at large against certain threats to
FOSS in healthcare. Dr. Valdes and I have been planning on doing this
for years, and, in our own ways, have both begun to attempt to make
the public aware of the issues that our community (FOSS Health IT)
faces. Dr. Valdes has been publishing several articles on the subject
at http://linuxmednews.com, which have meet with considerable success.
Including slashdotting:
http://science.slashdot.org/article.pl?sid=09/03/10/2055229

While Ignacio has been taking a hard-line Free Software
approach, I have been (in a twist for me) taking an 'Open Source'
approach. The people who approached me at DOHCS were unanimous in
their belief that what FOSS needed from the government was merely a
level playing field, so that we could compete, and win, on our own
merits.

The largest single threat to the future of FOSS in
healthcare in the US is the certification process mandated by the
stimulus act. The language provides funding for -certified- EHR
systems and eventually penalties for not using -certified- EHR
systems.

The best established certification body is CCHIT. They have
not been named as the certification body, but they are likely lobbying
for that role. However, CCHIT has had an anti-open source stance for
years. For years, I and other activists in the community have chosen
to largely ignore this bias. Simply because CCHIT was an optional
certification. Now, things have changed. It is possible that the
government will mandating a certification program that is either CCHIT
or similarly unfriendly to FOSS.

Recently I submitted my complaints to Dennis Wilson
(associated with both FOSS Laika and employed by CCHIT) who put me in
touch with Mark Leavitt. As a main result of that discussion, Mark has
agreed to have a meeting with the community-at-large about this issue
at HIMSS (please see the forwarded message from the CCHIT e-newsletter
below).

Granted, this is like offering to meet with the Rebel
Alliance at the annual Death Star conference. However, Mark has also
agreed to provide some kind of remote access capability for those of
us who cannot afford the time, cost or moral compromise required to
attend HIMSS.

The meeting will be held at HIMSS on Monday, April 6, Room
10d, Session #2 2:00 – 3:00 PM

I have heard from several of the HIMSS 'regulars' in our
community that they will be going. However, it is critical that we
have a show of force within the community from precisely those people
who have the most to lose with regards to the certification issue:
small support companies and individual consultants.

I am going on vacation next week, so I will be silent on
the mailing lists for a while. Would someone else please take the lead
on coordinating the sharing of hotel rooms, etc etc. If you are
already going and you would not mind 'putting someone up' so that they
could attend this conference, please speak up. I have space for one in
my hotel room starting Sunday. If you live in Chicago and you have a
couch to spare, please speak up.

We are becoming more 'organized' as we speak. Please watch
this space for more announcements on how you can participate to keep
the US government from making anti-FOSS blunders now and in the
future.

Best,
-Fred Trotter
http://www.fredtrotter.com

---------- Forwarded message ----------
From: Sue Reber <sre...@cchit.org>
Date: Fri, Mar 13, 2009 at 3:07 PM
Subject: FW: CCHIT eNews: Seeking volunteers, Expansion,
Interoperability and Open Source
To: fred trotter <fred.t...@gmail.com>
Cc: Dennis Wilson <dwi...@cchit.org>


Fred – see below “Commission Hosts Interoperability and Open Source
Roundtables on Certification” in our regular electronic newsletter.

C Sue Reber

Marketing Director, CCHIT

Certification Commission for Healthcare Information Technology

503.288.5876 office | 503.703.0813 cell | 503.287.4613 fax

sre...@cchit.org

--- majority of newsletter removed for brevity ---

Commission Hosts Interoperability and Open Source Roundtables on Certification

In addition to its annual Town Hall at the upcoming  HIMSS09 Annual
Conference in Chicago, the Certification Commission will be  hosting
two technical roundtables, co-located with the conference, for health
IT vendors and developers. The first, “Interoperability 09 and Beyond:
a look  at CCHIT’s roadmap for the future”, will present the
Commission’s  interoperability roadmap and explore the standards and
testing tools with  which developers need to be familiar.

The second, “Open Source  Forum: a dialogue on certification for open
source EHRs”, is designed to  continue the discussion with open source
developers with an interest in  certifying EHRs. This session will
allow an open exchange of the challenges  and opportunities for making
certified open source EHRs available to  providers.

The times and locations of sessions are below. Both Health IT
Technical Roundtables will also be available via free remote access.
Details will be available at cchit.org prior to the date.

CCHIT Town Hall at HIMSS09 Annual Conference
Sunday,  April 5
Room W192b, McCormick Convention Center, Chicago
9:45 - 11:15  AM

Health IT Technical Roundtables at Hyatt McCormick Conference Center
Monday, April 6
Room 10d, Hyatt McCormick Conference  Center, Chicago

Session #1  1:00 – 2:00 PM
Interoperability 09  and Beyond: a look at CCHIT’s roadmap for the future

Session #2  2:00  – 3:00 PM
Open Source Forum: a dialogue on certification for open source  EHRs


--- sections removed for brevity ----

Contact : eN...@cchit.org  | www.cchit.org

Copyright © 2005-2009 Certification Commission for Healthcare
Information Technology
Privacy Policy   |   Terms of Use   |   Contact

________________________________

If you no longer wish to receive these emails, please reply to this
message with "Unsubscribe" in the subject line or simply click on the
following link: Unsubscribe

________________________________

Certification Commission for Healthcare Information Technology
200 S Wacker Dr
Suite 3100
Chicago, Illinois 60606
US

Read the VerticalResponse marketing policy.

Elwell, Tim

unread,
Mar 14, 2009, 3:50:45 PM3/14/09
to open-ehealth-...@googlegroups.com, openh...@yahoogroups.com, Hardhats, Dennis Wilson, Mark Leavitt
Fred -- Thanks for posting this. I have been asked to participate in the CCHIT Meeting at HIMSS during the 2-3pm timeslot. Who else will be participating? Perhaps we could use this forum to collect, aggregate and consolidate concerns representing various OS community stakeholders and reduce to a White Paper for submission. I'd be happy to include the summary in my remarks to CCHIT.

Regards,

Tim Elwell
Misys Open Source Solutions
Tim.e...@misys.com
10d, Session #2 2:00 - 3:00 PM
Fred - see below "Commission Hosts Interoperability and Open Source
Session #1  1:00 - 2:00 PM
Interoperability 09  and Beyond: a look at CCHIT's roadmap for the future

Session #2  2:00  - 3:00 PM
Open Source Forum: a dialogue on certification for open source  EHRs


--- sections removed for brevity ----

Contact : eN...@cchit.org  | www.cchit.org

Copyright © 2005-2009 Certification Commission for Healthcare
Information Technology
Privacy Policy   |   Terms of Use   |   Contact



________________________________

If you no longer wish to receive these emails, please reply to this
message with "Unsubscribe" in the subject line or simply click on the
following link: Unsubscribe

________________________________

Certification Commission for Healthcare Information Technology
200 S Wacker Dr
Suite 3100
Chicago, Illinois 60606
US

Read the VerticalResponse marketing policy.




"Misys" is the trade name for Misys plc (registered in England and Wales). Registration Number: 01360027. Registered office: One Kingdom Street, London W2 6BL, United Kingdom. For a list of Misys group operating companies please go to http://www.misys.com/corp/About_Us/misys_operating_companies.html. This email and any attachments have been scanned for known viruses using multiple scanners. This email message is intended for the named recipient only. It may be privileged and/or confidential. If you are not the named recipient of this email please notify us immediately and do not copy it or use it for any purpose, nor disclose its contents to any other person. This email does not constitute the commencement of legal relations between you and Misys plc. Please refer to the executed contract between you and the relevant member of the Misys group for the identity of the contracting party with which you are dealing.

fred trotter

unread,
Mar 14, 2009, 4:14:06 PM3/14/09
to open-ehealth-...@googlegroups.com, openh...@yahoogroups.com, Hardhats, Dennis Wilson, Mark Leavitt
Tim,
         That is great news!

On Sat, Mar 14, 2009 at 2:50 PM, Elwell, Tim <Tim.E...@misys.com> wrote:

Fred -- Thanks for posting this. I have been asked to participate in the CCHIT Meeting at HIMSS during the 2-3pm timeslot. Who else will be participating?

I know that Medsphere will show up in force, and I think that the other 'usual suspects' (ClearHealth, WebReach, DSS) will be there as well. I would like to see more of the community come out. I am concerned that projects like WorldVistA-Community and OpenEMR, who have large communities but not very much corporate presence will be under-represented. This invitation is to try and get more of them in the room. I am also not sure what the "call-in" capability will look like and I am concerned that people who call-in will have a substantially less good experience...

 
Perhaps we could use this forum to collect, aggregate and consolidate concerns representing various OS community stakeholders and reduce to a White Paper for submission.

Anytime I hear the word 'stakeholder' I cringe. What that often means is 'listening to the most well-funded'. This is the mistake that makes CCHIT assume that they have already been working with us as a community. The Medspheres and ClearHealths of the world can take care of themselves. Significant community members like Webreach, Misys Open Source Software, OpenMRS, Open Health Tools and OpenClinica might be sympathetic but do not have a direct interest in FOSS EHR systems in the U.S. I really hope that the WorldVistA-Community shows up in force, since they are a large community and they have the only certified FOSS system I know of. (Are there others? That's a question I have not been able to get answered, and is very relevant now) So I think we will have to not only have to be inclusive with regards to stakeholders but find a way to fairly differentiate between interests.

Still I think a white-paper is at least in part the way to go. I think it is something that we should consider sending not only to CCHIT but to the government. I also think we need to find a way to extend the opportunity to weigh in to people who are not there.

I am glad that CCHIT is reaching out to people like you that are listening in the right places (and in the right way!!) that is a very good sign that this could work out.

 



--
Fred Trotter
http://www.fredtrotter.com

Neil Cowles

unread,
Mar 14, 2009, 4:44:09 PM3/14/09
to open-ehealth-...@googlegroups.com, openh...@yahoogroups.com, Hardhats, Mark Leavitt, Dennis Wilson
Fred,

I will be attending the meeting with CCHIT in person on April 6, 2009 at
HIMSS.

Neil Cowles
Tolven
www.tolven.org
 
-----Original Message-----
From: open-ehealth-...@googlegroups.com
[mailto:open-ehealth-...@googlegroups.com] On Behalf Of fred
trotter
Sent: Saturday, March 14, 2009 11:45 AM
To: openh...@yahoogroups.com; open-ehealth-...@googlegroups.com;
Hardhats; Mark Leavitt; Dennis Wilson
Subject: CCHIT meeting FOSS at HIMSS


Elwell, Tim

unread,
Mar 14, 2009, 11:07:05 PM3/14/09
to open-ehealth-...@googlegroups.com, openh...@yahoogroups.com, Hardhats, Dennis Wilson, Mark Leavitt

Main Entry: stake·hold·er           Listen to the pronunciation of stakeholder

Pronunciation: \ˈstāk-ˌhōl-dər\

Function: noun

Date: 1708

1 : a person entrusted with the stakes of bettors 2 : one that has a stake in an enterprise 3 : one who is involved in or affected by a course of action

 

Anyone who has concern about OS and the impact of CCHIT on the development, distribution, promotion and use of OS EHRs, especially as it pertains to being a “certified” EHRs, falls under stakeholder definition 3.

 

Relative to your comment that ‘significant community members’ don’t have an interest in FOSS EHRs in the US is <blatantly> incorrect. [I am using hyperbole here because it appears that this is the only way to discuss such matters in this forum – as if all things relative to a purist view of OS are either black or white.] And I am speaking as one of your noted ‘significant community members’ – whatever that means.

 

Again Fred, you have gone out of your way to divide the various OS constituents. WHY? I am gratified that you are now beginning to use the ‘inclusive’ word in your discussions here. I think this is very important and although there may be differences of opinions, we need to find the things that we can agree on first. No organization can be all things to all groups but there appears to be a symbolic ‘olive branch’ that is being offered by CCHIT and instead of making this a religious argument, can we agree to be pragmatic and look on real ways to ‘level the playing field’ and insure that OS interests are not extinguished or hampered. I believe that OS represents another channel to introduce innovation into an industry that is starved for a better way. I, like you, believe that anything that stands in the way of OS development and distribution and use should be stopped and our reasons for feeling this way may be different – and that’s ok. So if we are concerned that CCHIT may represent a threat to ultimate use and adoption of OS technologies (in this case EHRs), why do we feel that way and what needs to be changed?

 

A couple of arguments that I have heard include:

 

Smaller EHR proprietary companies have raised the certification cost as a major concern. (It used to be $28K for Year 1 and then $4.5K for years 2 and 3 – pretty hefty for an OS community project or even a small proprietary company). Is this the major issue for OS development? Might a regressive pricing structure or a proportional pricing based be more appropriate?

 

OS Projects and contributions are made all the time. OS could not possibly be expected to have to be subjected to ongoing certification costs. Might the governance of the project include version control mechanisms that can track changes and demonstrate that significant re-engineering of the core code has not been made and that re-certification is not required? If recertification is required, might it be contained to the major re-engineering element(s) and charges would be made on a prorated basis.

 

Others have argued that the criteria needed for certification is overkill for the smaller provider market. Having to include features and functionality into a product that customers don’t want seems to be orthogonal to good product design.  Might there be a recommendation that there be appropriate certification requirements based on various market segments and that the market segments have different certification costs? This might be justifiable since it would appear that the cost to certify less requirements is less than a larger, more complex feature and function set.

 

 

BOTTOM LINE: What is CCHIT doing that is getting in the way of developing, distributing and using OS EHR solutions? And what do we want them to do to remove the impediment?

 

CCHIT’s stated mission is to “accelerate the adoption of robust, interoperable health information technology by creating a credible, efficient certification process.” On face value, CCHIT sees value in OS or they wouldn’t be giving us the forum to discuss the matter. OS EHR provides good products and solutions to the market that need to be offered as equal options to providers if there is any sincere desire to accelerate EHR adoption. Certification, by itself, does nothing to accelerate HIT adoption. However, certification that impedes access to these technologies is bad. Let’s work pragmatically to identify the issues and offer reasonable solutions.

 

Tim Elwell

Misys Open Source Solutions

Gregory Woodhouse

unread,
Mar 14, 2009, 11:59:40 PM3/14/09
to open-ehealth-...@googlegroups.com, <open-ehealth-collaborative@googlegroups.com>, <openhealth@yahoogroups.com>, Hardhats, Dennis Wilson, Mark Leavitt
Certification is a reality I think we all need to accept. Indeed, I wouldn't want it any other way.

That being said, I think the focus really needs to be on developing an approach that can accomadate open source. I think CM and governance is the key. The Linux kernel may actually be a good model.

Sent from my iPhone

On Mar 14, 2009, at 8:07 PM, "Elwell, Tim" <Tim.E...@misys.com> wrote:

Main Entry: stake·hold·er <image001.gif>

--~--~---------~--~----~------------~-------~--~----~
You received this message because you are subscribed to the Google Groups "Open eHealth Collaborative" group.
To post to this group, send email to open-ehealth-...@googlegroups.com
To unsubscribe from this group, send email to open-ehealth-collab...@googlegroups.com
For more options, visit this group at http://groups.google.com/group/open-ehealth-collaborative?hl=en
-~----------~----~----~----~------~----~------~LS1+LS0tPGJyPg0KPC9ib2R5Pg0KDQo8L2h0bWw+DQo8YnI+DQo=ICZxdW90O09wZW4gZUhlYWx0aCBDb2xsYWJvcmF0aXZlJnF1b3Q7IGdyb3VwLiA8YnI+IFRvIHBv st to this group, send email to open-ehealth-...@googlegroups.com
To unsubscribe from this group, send email to open-ehealth-collab...@googlegroups.com
For more options, visit this group at http://groups.google.com/group/open-ehealth-collaborative?hl=en
-~----------~----~----~----~------~----~------~LS1+LS0tPGJyPg0KPC9ib2R5Pg0KDQo8L2h0bWw+DQo8YnI+DQo=nI+DQo=

Jeffrey Soble

unread,
Mar 15, 2009, 8:04:31 AM3/15/09
to open-ehealth-...@googlegroups.com
I agree with much of what you have to say, particularly that there is not a single point of view within the OS community (which is OK). However, I think you left out another crucial problem in the current CCHIT process. The OS model is naturally oriented toward component integration (technology stacks from different sources). CCHIT is inherently oriented toward certification of comprehensive (some might say bloated), monolithic systems. Are there any examples of systems with have been certified recently based on integration of components from different code bases?

That is why I believe the emphasis for a "certified" EHRs should, and could be much simpler than the large list of feature-functionality outlined by CCHIT today. Namely, certified systems should be interoperable and allow for the elimination of paper records - specific implementation details (and associated price/performance) should be governed by the marketplace.

I also think it is positive that CCHIT is interested in dialog with the OS community. Perhaps there is common ground out there somewhere.

Jeff Soble

David Kibbe

unread,
Mar 15, 2009, 10:35:25 AM3/15/09
to open-ehealth-...@googlegroups.com
Colleagues:  I'd like to interject some of the new thinking about HITECH certification that is circulating in DC, and which could shift the paradigm from the application layer to the data layer, and perhaps from certification to something more like validation.   Put simply, people are discussing a "thin certification" process that could apply to the ability of many different kinds of EHR technology (including OS) to accept, manage, and transfer a modest set of standards-based content designed for exchange purposes.  This would include specs for clinical content (diagnoses, medications, allergies, lab results, vital signs); its packaging in XML (either CCR standard or CDA CCD); the use of specific coding sets (e.g. ICD-9), and the security of transmission (https and digital signatures).  Think minimal data set expressed in XML whose secure and integral exchange can be validated, and starting with data that are already mostly available in electronic format, e.g. medications and lab results, and you're close.  For the most part, the discussion is around ambulatory data exchanges as a starting place, and because this is where the most care is delivered.

A number of reasons for changing the certification paradigm have been brought up at this point. First, in the new landscape for health IT under the Obama administration there appears to be a determination to emphasize and reward the outcomes of the uses of health IT, rather than merely the deployment of specific products or classes of products.  Chief among these outcomes is coordination of care, and in particular the handing off of data related to the care of patients with chronic illnesses.  There is some imperative felt in DC for parsimony and focus in order to achieve the biggest bang from the HITECH dollars: multiplication of goals and objectives might prolong implementation beyond 2011. 

If coordination of care is primum inter pares  among the "meaningful uses" of health IT as interpreted by the new team at HHS/CMS/ONC, then the specification for exchange of health data across the network in a manner that can be handled by a large assortment of EHR technologies makes sense.  These technologies may include what we now refer to as PHRs, e.g. Google Health and HealthVault, as well as innovative and newer, lighter-weight web apps for providers and patients which I've referred to as Clinical Groupware.  Heretofore the emphasis has been on EHR technology as products, with little or no attention paid to EHR technology as data exchange methodology.   It may be the case that a focus on the data exchange layer gets data moving more quickly, and thus moves the nation faster toward the goals of care coordination and continuity.  This is the new thinking as I understand it.

Secondly, the timeframe is very, very short.   The federal government is in an urgent mode with respect to the regulatory phase of the HITECH Act, and needs to set specifications quickly such that the market can accommodate them and permit providers to achieve success in less than a year.  As a practical matter, it may take until the end of 2009 before full regulations are issued, depending on how quickly new HHS personnel can be hired, the new HIT Committees impanelled, and their recommendations tested by NIST.  This would then give physicians, hospitals, and the vendors fewer than 18 months to implement and demonstrate meaningful uses of health IT.   So the work product coming out of ONC may be surprisingly specific, focused on a limited goal of health data exchange capability, and set at a bar which would seem low compared to all the complexity associated with HITSP's many use cases and dozens of standards or CCHIT's hundreds of certification criteria. 

Thirdly, certification of products at the multi-feature level now done by CCHIT is problematic to this scenario, because it creates a significant bottleneck.  It's possible that HHS may choose several entities to do the certification to move things along more quickly, once the new Committees have agreed on this approach and NIST has tested the standards involved.   This option does not exclude CCHIT as a certifier, nor does it prohibit CCHIT from continuing to perform its multi-functions certification of EHR products within the private sector.  It may, however, remove CCHIT from its monopoly position as a certifier of "EHR technology" within the contours of the HITECH Act where there is the need for expediency and the need for freedom from special interests of the established vendors.   

Finally, there is a new and practical awareness within Congress and the administration of the complexity associated with the implementation of EHR technology at the small and medium size medical practice level, where most care is delivered in the US.  People are aware that care coordination via health data exchange is not possible with the majority of EHR applications on the market currently, and they are also cognizant of the fact that purchase and implementation of comprehensive EHR applications in small medical practices can take many months and be interruptive to practice work flows, leading to counterproductive drops in revenue.  The passage of the financial incentives for e-Prescribing was an explicit acknowledgement by the feds that an incremental strategy for health IT adoption focused on clinical data transfers might be more successful for physicians in small and medium practices than a "big bang" approach.  This is an administration that is committed to what works, and not ideologically inclined to follow paths or projects that don't work.

I readily admit that my comments here are speculative, and reflect ideas, talk and debate, rather than clear cut actions by our government.  For that, we'll have to wait at least until Secretary of HHS Sebelius and her new colleagues at CMS and ONC have been named and given time to formalize their policies.    However, I do sense that some very significant change of the kind I've related here is being contemplated and thought through carefully and deliberately by the Obama health team now in place.   All of this may augur well for innovation and for open-source, too. 

With kind regards, DCK


David C. Kibbe, MD MBA
Senior Advisor, American Academy of Family Physicians
Chair, ASTM International  E31Technical Committee on Healthcare Informatics
Principal, The Kibbe Group LLC 
___________
___________

CONFIDENTIALITY: This e-mail message (including attachments, if any) is confidential and is intended only for the addressee. Any unauthorized use or disclosure is strictly prohibited. Disclosure of this e-mail to anyone other than the intended addressee does not constitute waiver of privilege. If you have received this communication in error, please notify me immediately and delete this. Thank you for your cooperation.  This message has not been encrypted.  Special arrangements can be made for encryption upon request.





On Mar 15, 2009, at 8:04 AM, Jeffrey Soble wrote:

I agree with much of what you have to say, particularly that there is not a single point of view within the OS community (which is OK). However, I think you left out another crucial problem in the current CCHIT process. The OS model is naturally oriented toward component integration (technology stacks from different sources). CCHIT is inherently oriented toward certification of comprehensive (some might say bloated), monolithic systems. Are there any examples of systems with have been certified recently based on integration of components from different code bases?

That is why I believe the emphasis for a "certified" EHRs should, and could be much simpler than the large list of feature-functionality outlined by CCHIT today. Namely, certified systems should be interoperable and allow for the elimination of paper records - specific implementation details (and associated price/performance) should be governed by the marketplace.

I also think it is positive that CCHIT is interested in dialog with the OS community. Perhaps there is common ground out there somewhere.

Jeff Soble

On Sat, Mar 14, 2009 at 10:07 PM, Elwell, Tim <Tim.E...@misys.com> wrote:

Main Entry: stake·hold·er <image001.gif>

Elwell, Tim

unread,
Mar 15, 2009, 10:52:17 AM3/15/09
to open-ehealth-...@googlegroups.com

Good comments Jeff. Are you thinking that there might be a place for ‘certified components’? If I am tracking with your recommendation, if previously certified components are used, then it will be a matter of ‘certifying’ the integration. Correct?

 

Frankly, I am of the opinion that certification should only concentrate on the interoperability, safety (including secure handling of information) and integration of components and systems anyway and the ‘customer’ should determine what features are needed in the application. Certifying the chosen components certainly makes the overall argument much more palatable. But, I don’t think that the components should be mandated by anyone. Kinda like buying a car. There are many choices of cars and features. It shouldn’t be mandated that I get the air conditioning and power windows if I don’t want them. However, if I go to the aftermarket to upgrade my headlights to halogens, I want to rest assured that 1.) they will work in my car, and 2.) they won’t create a hazard (i.e. catch on fire), and 3.) it will pass state inspection.

 

Certainly organizations like CCHIT (and others) can make recommendations on what the optimal ‘stack’ looks like with recommended specified features and functions so that the dizzying array of options are manageable and providers can concentrate on what they are getting reimbursed to do. But at the end of the day, like the UL (Underwriters Laboratories) label, I want to make sure that the integrated product 1.) does what I want it to do, and 2.) is safe.

 

Tim Elwell

 


Elwell, Tim

unread,
Mar 15, 2009, 11:16:23 AM3/15/09
to open-ehealth-...@googlegroups.com

Thanks David for a great overview of what you are hearing. The debate appears to be quite pragmatic indeed. Concentrating on the exchange of information makes a ton of sense. I, for one, am encouraged by the approach and think you are correct that this bodes well for OS and associated innovations. With this as a backdrop for what is going on in Washington, does the discussion we are having CCHIT change?

 


David Kibbe

unread,
Mar 15, 2009, 11:26:24 AM3/15/09
to open-ehealth-...@googlegroups.com
I believe as a practical matter the OS community would be wise to join the group that is advocating a certification paradigm shift, of the kind both you and I have described.   This keeps thing simple and may do more for opening the doors to OS than fighting CCHIT itself.

My sense is that Mark Leavitt is in a very precarious situation, and making himself vulnerable to a lot of criticism.  He's trying to be all things to all people, to protect the proprietary vendors at the same time as put a HITECH-friendly face on CCHIT.  My epiphany this past week has been that the key players inside the Obama administration with respect to IT are already in another space, one in which the network is the application and data exchange is the really important issue.

Like all things, there's likely to be many compromises.   But my advice to the OS community is to support the exchange/interoperability emphasis, because this may open doors fairly quickly.  

Talking directly to CCHIT and HIMSS, on the other hand, is not going to be very fruitful.  

DCK


David C. Kibbe, MD MBA
Senior Advisor, American Academy of Family Physicians
Chair, ASTM International  E31Technical Committee on Healthcare Informatics
Principal, The Kibbe Group LLC 
___________
___________

CONFIDENTIALITY: This e-mail message (including attachments, if any) is confidential and is intended only for the addressee. Any unauthorized use or disclosure is strictly prohibited. Disclosure of this e-mail to anyone other than the intended addressee does not constitute waiver of privilege. If you have received this communication in error, please notify me immediately and delete this. Thank you for your cooperation.  This message has not been encrypted.  Special arrangements can be made for encryption upon request.





On Mar 15, 2009, at 11:16 AM, Elwell, Tim wrote:

Thanks David for a great overview of what you are hearing. The debate appears to be quite pragmatic indeed. Concentrating on the exchange of information makes a ton of sense. I, for one, am encouraged by the approach and think you are correct that this bodes well for OS and associated innovations. With this as a backdrop for what is going on inWashington, does the discussion we are having CCHIT change?

"Misys" is the trade name for Misys plc (registered in England and Wales). Registration Number: 01360027. Registered office: One Kingdom Street,London W2 6BL, United Kingdom. For a list of Misys group operating companies please go tohttp://www.misys.com/corp/About_Us/misys_operating_companies.html. This email and any attachments have been scanned for known viruses using multiple scanners. This email message is intended for the named recipient only. It may be privileged and/or confidential. If you are not the named recipient of this email please notify us immediately and do not copy it or use it for any purpose, nor disclose its contents to any other person. This email does not constitute the commencement of legal relations between you and Misys plc. Please refer to the executed contract between you and the relevant member of the Misys group for the identity of the contracting party with which you are dealing.





"Misys" is the trade name for Misys plc (registered in England and Wales). Registration Number: 01360027. Registered office: One Kingdom Street, London W2 6BL, United Kingdom. For a list of Misys group operating companies please go to http://www.misys.com/corp/About_Us/misys_operating_companies.html. This email and any attachments have been scanned for known viruses using multiple scanners. This email message is intended for the named recipient only. It may be privileged and/or confidential. If you are not the named recipient of this email please notify us immediately and do not copy it or use it for any purpose, nor disclose its contents to any other person. This email does not constitute the commencement of legal relations between you and Misys plc. Please refer to the executed contract between you and the relevant member of the Misys group for the identity of the contracting party with which you are dealing.

 
 

Jeffrey Soble

unread,
Mar 15, 2009, 11:48:56 AM3/15/09
to open-ehealth-...@googlegroups.com
On Sun, Mar 15, 2009 at 9:52 AM, Elwell, Tim <Tim.E...@misys.com> wrote:

Good comments Jeff. Are you thinking that there might be a place for ‘certified components’? If I am tracking with your recommendation, if previously certified components are used, then it will be a matter of ‘certifying’ the integration. Correct?

That all depends. If the certification standard is onerous (as I would characterize the current CCHIT requirements), then certifying components that can handle large chunks of the requirement set "out of the box" might be appropriate. If the certification process is "thin" (as David's post this morning describes), than certification of the integrated system (which utilizes components that may or may not be certified in their own right) makes more sense

Frankly, I am of the opinion that certification should only concentrate on the interoperability, safety (including secure handling of information) and integration of components and systems anyway and the ‘customer’ should determine what features are needed in the application.

 Hallelujah! This is so common sense it almost defies argument (in my view). However, certifications (like any human undertaking) tend to take on a life of their own, particularly if the criteria are written by the same people who are charged with enforcing them.

Certifying the chosen components certainly makes the overall argument much more palatable. But, I don’t think that the components should be mandated by anyone. Kinda like buying a car. There are many choices of cars and features. It shouldn’t be mandated that I get the air conditioning and power windows if I don’t want them. However, if I go to the aftermarket to upgrade my headlights to halogens, I want to rest assured that 1.) they will work in my car, and 2.) they won’t create a hazard (i.e. catch on fire), and 3.) it will pass state inspection.

Well, again I think the certification of components vs. systems boils down to the scope of the certification process. The larger it gets, the more it makes sense to certify components to handle specific parts.

Certainly organizations like CCHIT (and others) can make recommendations on what the optimal ‘stack’ looks like with recommended specified features and functions so that the dizzying array of options are manageable and providers can concentrate on what they are getting reimbursed to do. But at the end of the day, like the UL (Underwriters Laboratories) label, I want to make sure that the integrated product 1.) does what I want it to do, and 2.) is safe.

I think we're on the same page.


Best-
Jeff

Jeffrey Soble

unread,
Mar 15, 2009, 12:08:10 PM3/15/09
to open-ehealth-...@googlegroups.com
Thanks - sounds promising.

It would be very helpful to have a page in the forum devoted to sharing contact info on the most important people for us to lobby on this topic. It may have minimal impact, but I for one would be interested in sending letters to the key players.

-Jeff

fred trotter

unread,
Mar 15, 2009, 1:01:12 PM3/15/09
to open-ehealth-...@googlegroups.com
>
> 1 : a person entrusted with the stakes of bettors 2 : one that has a stake
> in an enterprise 3 : one who is involved in or affected by a course of
> action
>

Do not worry Tim, I know when you say it, it has its normal meaning
and is used for good!
But so far CCHIT and HIMSS have both embraced all of the
"stakeholders" except for us. So when they say it, I am not sure what
it means.

Also, our culture is not based around "stakeholders", it is a
meritocracy. I do not respect you or Alesha because you are simply
here on this list. I know exactly what kind of excellent work that you
have done and are doing. MOSS has -earned- a seat at the table in our
community. The idea that all voices are equal is simply not the way we
work.

>
>
> Anyone who has concern about OS and the impact of CCHIT on the development,
> distribution, promotion and use of OS EHRs, especially as it pertains to
> being a “certified” EHRs, falls under stakeholder definition 3.
>

I can agree that there are more groups with a legitimate concern. But
at breakfast, it is different to be the pig vs. the chicken. I am
primarily concerned with those in our community that might end up as
'bacon' during this process.

> Relative to your comment that ‘significant community members’ don’t have an
> interest in FOSS EHRs in the US is <blatantly> incorrect. [I am using
> hyperbole here because it appears that this is the only way to discuss such
> matters in this forum – as if all things relative to a purist view of OS are
> either black or white.] And I am speaking as one of your noted ‘significant
> community members’ – whatever that means.

Well said and point taken.

> Again Fred, you have gone out of your way to divide the various OS
> constituents. WHY?

pig vs chicken.

> I am gratified that you are now beginning to use the
> ‘inclusive’ word in your discussions here. I think this is very important
> and although there may be differences of opinions, we need to find the
> things that we can agree on first. No organization can be all things to all
> groups but there appears to be a symbolic ‘olive branch’ that is being
> offered by CCHIT

CCHIT has not offered -anything-, they are merely continuing to talk
to us. There is a very real danger here of being "heard and ignored".
That does not mean I am not thrilled that they are meeting with us,
but that is -only- the first step.

> and instead of making this a religious argument, can we
> agree to be pragmatic and look on real ways to ‘level the playing field’ and
> insure that OS interests are not extinguished or hampered. I believe that OS
> represents another channel to introduce innovation into an industry that is
> starved for a better way. I, like you, believe that anything that stands in
> the way of OS development and distribution and use should be stopped and our
> reasons for feeling this way may be different – and that’s ok. So if we are
> concerned that CCHIT may represent a threat to ultimate use and adoption of
> OS technologies (in this case EHRs), why do we feel that way and what needs
> to be changed?

We need some kind of mechanism to have fundamental compatibility with
the business, people and process of the FOSS community. We need the
flexibility to not have to live with the limitations of a black-box
process. Will Ross in particular has been adamant about fundamentally
improving the process. In short the entire certification process needs
to be subject to the same meritocracy that everything else is in FOSS.


>
>
>
> Smaller EHR proprietary companies have raised the certification cost as a
> major concern. (It used to be $28K for Year 1 and then $4.5K for years 2 and
> 3 – pretty hefty for an OS community project or even a small proprietary
> company). Is this the major issue for OS development? Might a regressive
> pricing structure or a proportional pricing based be more appropriate?

Sounds like an important component for being compatible with our
business community.

>
> OS Projects and contributions are made all the time. OS could not possibly
> be expected to have to be subjected to ongoing certification costs. Might
> the governance of the project include version control mechanisms that can
> track changes and demonstrate that significant re-engineering of the core
> code has not been made and that re-certification is not required? If
> recertification is required, might it be contained to the major
> re-engineering element(s) and charges would be made on a prorated basis.
>

Sounds like respecting our process!!


>
> Others have argued that the criteria needed for certification is overkill
> for the smaller provider market. Having to include features and
> functionality into a product that customers don’t want seems to be
> orthogonal to good product design.  Might there be a recommendation that
> there be appropriate certification requirements based on various market
> segments and that the market segments have different certification costs?
> This might be justifiable since it would appear that the cost to certify
> less requirements is less than a larger, more complex feature and function
> set.

One of many-many good ideas about how to really overhaul things in a
positive way!!

> BOTTOM LINE: What is CCHIT doing that is getting in the way of developing,
> distributing and using OS EHR solutions? And what do we want them to do to
> remove the impediment?

I have suggested two entirely different ideas to them, so far..
silence on both.

> CCHIT’s stated mission is to “accelerate the adoption of robust,
> interoperable health information technology by creating a credible,
> efficient certification process.” On face value, CCHIT sees value in OS or
> they wouldn’t be giving us the forum to discuss the matter.

I see no justification for this. I would conjecture that they either
respect us as you suggest or fear us. Either of which I am satisfied
with. Much better than apathy which is how I have been treated in the
past.


> OS EHR provides
> good products and solutions to the market that need to be offered as equal
> options to providers if there is any sincere desire to accelerate EHR
> adoption. Certification, by itself, does nothing to accelerate HIT adoption.

I would argue that -good- certification can improve trust, and
improved trust can accelerate adoption.


> However, certification that impedes access to these technologies is bad.
> Let’s work pragmatically to identify the issues and offer reasonable
> solutions.

Agreed.

Mike

unread,
Mar 15, 2009, 1:44:54 PM3/15/09
to open-ehealth-...@googlegroups.com

 
This whole discussion is predicated on the assumption that certification serves some purpose. Has there been any study that has shown that CCHIT certification has had any effect on "accelerating the adoption" of EHR's which is CCHIT's mission? One could argue that it has had the opposite effect by forcing companies to spend resources on the certification process that could have gone into product development. Or giving buyers a false sense of security that their certified system will meet their interoperability needs, for example, as I have seen quoted in one article.

Certification doesn't absolve the EHR purchaser from due diligence. Caveat emptor!

And it is so kind of the self appointed CCHIT to deign to meet with the rabble of the OS community at HIMSS. Now that their monopoly is being threatened, they need all the friends that they can get!

Mike Ginsburg

Edmund Billings

unread,
Mar 16, 2009, 7:53:24 AM3/16/09
to open-ehealth-...@googlegroups.com, open-ehealth-...@googlegroups.com, openh...@yahoogroups.com, hard...@googlegroups.com, Dennis Wilson, Mark Leavitt
I and others from Medsphere will be participating.

Edmund

__________________
Edmund Billings MD
415.505.8953

On Mar 14, 2009, at 12:51 PM, "Elwell, Tim" <Tim.E...@misys.com>
wrote:

>
The information contained in this email may be confidential and/or may be covered under the Privacy Act, 5 USC 552(a), and/or the Health Insurance Portability and Accountability Act (PL 104-191) and its various implementing regulations and must be protected in accordance with those provisions.. It has been sent for the sole use of the intended recipient(s). If the reader of this message is not an intended recipient, you are hereby notified that any unauthorized review, use, disclosure, dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please contact the sender by reply email and destroy all copies of the original message. To contact our email administrator directly, send to an email message to help...@medsphere.com. Thank you.

Vipen Mahajan

unread,
Mar 16, 2009, 12:14:22 PM3/16/09
to Hard...@googlegroups.com, open-ehealth-...@googlegroups.com, openh...@yahoogroups.com, Dennis Wilson, Mark Leavitt, Vipen Mahajan
Hi All,

As Health care is no longer a nation-wide concern, germs, SAARS, polio
etc. respect no national boundaries. An FOSS Health care and EHR is
VITAL for this small plane Earth. The same system globally, would
prevent the Tower of Babel. Can VistA and our community rise to meet
the challenge?
For those who cannot make it for the meeting, can anyone, web
conference it, or atleast record it, and possibly put it on YouTube,
or use DimDim (, Open Source web conferencing), if it is possible.
Thanks
Vipen mahajan
Skype ID vmahajan

Currently in New Delhi, but always on the Internet.
--
Vipen Mahajan

Principal
Leo Systems
Chicago/Boston/Munich/New Delhi.

Skype - vmahajan
US +1-630-303- 9881. with voice mail facility
EMail/Skype/US Phone numbers are the best way to contact me. I travel
a lot but check the Internet every 12 hours atleast!.

JSS

unread,
Mar 16, 2009, 12:15:15 PM3/16/09
to Open eHealth Collaborative
David-

I'm wondering if we can synthesize your observations with the response
to HIMSS proposal (http://groups.google.com/group/open-ehealth-
collaborative/web/response-to-himss-call-to-action-interoperability-
first?hl=en) to create a concise position paper to send to HHS,
Congress, etc. (as is, or modified to better represent any individuals
particular point of view).

-Jeff
> kibbeda...@mac.com
> > On Sat, Mar 14, 2009 at 10:07 PM, Elwell, Tim <Tim.Elw...@misys.com>  
> > wrote:
> > Main Entry: stake·hold·er <image001.gif>
>
> > Pronunciation: \ˈstāk-ˌhōl-dər\
>
> > Function: noun
>
> > Date: 1708
>
> > 1 : a person entrusted with the stakes of bettors 2 : one that has a  
> > stake in an enterprise 3 : one who is involved in or affected by a  
> > course of action
>
> > Anyone who has concern about OS and the impact of CCHIT on the  
> > development, distribution, promotion and use of OS EHRs, especially  
> > as it pertains to being a “certified” EHRs, falls under  
> > stakeholder definition 3.
>
> > Relative to your comment that ‘significant community members’  
> > don’t have an interest in FOSS EHRs in the US is <blatantly>  
> > incorrect. [I am using hyperbole here because it appears that this  
> > is the only way to discuss such matters in this forum – as if all  
> > things relative to a purist view of OS are either black or white.]  
> > And I am speaking as one of your noted ‘significant community  
> > members’ – whatever that means.
>
> > Again Fred, you have gone out of your way to divide the various OS  
> > constituents. WHY? I am gratified that you are now beginning to use  
> > the ‘inclusive’ word in your discussions here. I think this is  
> > very important and although there may be differences of opinions, we  
> > need to find the things that we can agree on
>
> ...
>
> read more »

J. Bendor

unread,
Mar 20, 2009, 5:44:52 PM3/20/09
to Open eHealth Collaborative
I'd like to point out that, informally, we've heard some of the same
things David mentioned about Washington and certification, and that
NIST was included in the legislation for this reason. However, it is
unknown what direction the new people at HHS will take when they get
started.

J. Bendor
ClearHealth Inc.
> kibbeda...@mac.com
> > On Sat, Mar 14, 2009 at 10:07 PM, Elwell, Tim <Tim.Elw...@misys.com>  
> > wrote:
> > Main Entry: stake·hold·er <image001.gif>
>
> > Pronunciation: \ˈstāk-ˌhōl-dər\
>
> > Function: noun
>
> > Date: 1708
>
> > 1 : a person entrusted with the stakes of bettors 2 : one that has a  
> > stake in an enterprise 3 : one who is involved in or affected by a  
> > course of action
>
> > Anyone who has concern about OS and the impact of CCHIT on the  
> > development, distribution, promotion and use of OS EHRs, especially  
> > as it pertains to being a “certified” EHRs, falls under  
> > stakeholder definition 3.
>
> > Relative to your comment that ‘significant community members’  
> > don’t have an interest in FOSS EHRs in the US is <blatantly>  
> > incorrect. [I am using hyperbole here because it appears that this  
> > is the only way to discuss such matters in this forum – as if all  
> > things relative to a purist view of OS are either black or white.]  
> > And I am speaking as one of your noted ‘significant community  
> > members’ – whatever that means.
>
> > Again Fred, you have gone out of your way to divide the various OS  
> > constituents. WHY? I am gratified that you are now beginning to use  
> > the ‘inclusive’ word in your discussions here. I think this is  
> > very important and although there may be differences of opinions, we  
> > need to find the things that we can agree on
>
> ...
>
> read more »
Reply all
Reply to author
Forward
0 new messages