Hi Tim, Sorry, I read it as all the sources - not just the test script sources but I don't follow - the CCHIT writes the test scripts - the vendor have to execute them..they are already public or have I missed something?
Obviously automation makes sense - but I suspect the costs of doing this (developing the automation) and of all the transparency you are proposing may make the cost to the vendors prohibitive - sounds like a lot of work to me. I suspect most of the $28,000 goes on the testing process. The fact everyone is so worried about $28K shows we don't have a very serious, broad or deep indigenous Health IT industry - I am sure the price would not worry IBA, HCN and a few others. In fact I believe (and this may not be popular) that we would do much better with 4 or 5 large well resouced providers than the status quo. May be the service levels that people are complaining about could be improved. Anyway it really does not matter - if there was agreement to do something then we can work out the details that suit all the stakeholders. The bottom line is - like it or not - they have a system up and going and evolving - we have diddly squat..that is my point - we need to get going. Cheers David. ---- Dr David G More MB, PhD, FACHI Phone +61-2-9438-2851 Fax +61-2-9906-7038 Skype Username : davidgmore E-mail: [EMAIL PROTECTED] HealthIT Blog - www.aushealthit.blogspot.com On Sun, 25 Feb 2007 11:49:44 +1100, Tim Churches wrote: > David More wrote: >> Hi Tim, >> >> You and I both know no commercial providers will publish their source code - >> so I am sorry your plan does not seem realistic to me. >> > > read what I wrote - they only need to publish the source code for the > the test scripts for their software, not the source code for their > actual software. Such test scripts need reveal nothing about how their > software is actually constructed. > > We can't let the public interest in teh safety of medical software be > over-ridden by software vendor preciousness about never revealing any > source code - especially when it is only test script source code that is > required, not their crown jewels. Surely you don't you want to have poor > quality non-interoperable GP software go on forever (to use your own words)? > >> The CCHIT is functioning as a "trusted" intermediary and as such the fact >> that so many vendors have agreed to certification seems to be doing an reasonable >> job. >> > > A bloody expensive job. The results of what I propose is arguably > superior, due to much greater transparency (in teh name of public > safety), and a lot less costly for everyone involved. > >> I have reviewed the functionality plans and scripts and they seem pretty >> reasonable to me - covering most of the bases and having an improving evolutionary >> path (i.e. continuous improvment). Not perfect but way better than nothing >> in an imperfect world. >> > > They would be a good starting point for Oz accreditation standards, as > per my proposal. > >> The 2006 certification criteria and scripts can all be reviewed - for free - >> at: >> >> http://www.cchit.org/vendors/learn/CCHIT+Ambulatory+EHR+Certification+for+2006.htm >> >> At least they are being pretty open about the goals etc. >> > As they ought to be. > >> I see the CCHIT as a pretty cheap, well thought out, and practical approach >> to improvement of the software available to the health sector and would like >> something similarly practical to be done in Australia - tailored to our >> market etc. >> > > Not cheap, they ignore the possibility and desirabilty of test > automation, they are insufficiently transparent and $28k per test is not > cheap. We can do better than that. > >> We obviously agree on the need - I am just keen to see a path that will work practically to get us there and Government or a surrogate to get on with it! >> > > No need for it to be a govt body - an NGO would be acceptable provided > there was complete transparency, as per my proposal. ACA (Australian > Consumers Association, publisher of CHOICE magazine) might be an good > hosting organisation. And they are technically very competent (their > testing labs in Sydney are very impressive) and very efficient - very > little overhead or bloat. And they are increasingly harnessing consumers > via the Internet to help with testing. They may care to partner with > some medical professional bodies. A govt grant to start it off, as the > US CCHIT got, would be needed, but aim would be self-sufficiency in 3 > years. Sure, there would need to be fees, but *minimal* fees due to the > use of efficient, re-usable automated testing methods, reliance on > vendors demonstrating stuff via screencasts, and leverage of the time > and effort interested third-parties via the Internet. > > No need to make the accreditation mandatory for software vendors, just > make the use of accredited software mandatory for practices (after three > years to establish the process). > > Tim C > >> On Sun, 25 Feb 2007 10:37:26 +1100, Tim Churches wrote: >>> David More wrote: >>>> Hi Tim, >>>> >>>> 3 points: >>>> >>>> 1.. The fees go to allow certification to continue - not anywhere else - >>>> are >>>> >> certification bodies not allowed to recover their costs? >>> Yes, but only the absolute minimum of costs i.e. they need to do their >>> business in the most efficient way, with minimal overheads. And thus no modern >>> offices, no hierarchy of staff, just a Web site and some email >>> accounts in a small back office hosted by an existing organisation. That >>> will do. And rely on modern, automated testing methods - see below. >>> >>>> Is Standards Australia meant to do it all for >>>> free? (They a'int! and we are all being ripped off as best I can tell) >>>> >>> No argument there. >>> >>>> Frankly you need to >>>> recognize this is the way our Government and the US seem to insist things >>>> are organised >>>> >> these days... >>> The recognition that Bush and Howard want to screw up the world doesn't >>> make it right, or that we should just roll over and acquiesce. If something is >>> wrong or stupid, we have a duty to say so. >>> >>>> my preference would have been for a totally government funded body to do >>>> all >>>> >> this...but..when was the last time any government entity did this sort of >> >>>> stuff for free (think TGA and its fees etc) >>>> >>> And NGO or QUANGO is fine for accreditation, but an efficient, lean and >>> mean one, which leverages modern technology and the power of the network to >>> achieve its ends (which are to ensure software quality, not to build its >>> own little empire). >>> >>>> 2. This, very inexpensive effort in national US terms, is so far ahead of >>>> what is >>>> >> happening here (in OZ) is it grumpifying as far as I am concerned. >>> Yes but they spend $450 billion each year on the military in the US, and >>> everything else there looks cheap by comparison. >>> >>>> 3. Note - At least one open-source solution is going for it..sorry it has >>>> to pay but >>>> >> that is the world a majority of us (under Howard and Bush) voted for - >> >>>> so what can I do.? I sure didn't vote for it! >>>> >>>> The CCHIT is happening, its working and there is 'stuff all' happening in >>>> OZ along the >>>> >> same - very important - lines. Ostrich all you like - this is >>>> fundamentally good stuff CCHIT are doing and it is being done on the >>>> 'smell or an oily >>>> >> rag' in a relative sense. >>> I am told that the US govt happily pays Haliburton and other contractors >>> $5000 each for oily rags to be delivered to Iraq to help with the reconstruction. >>> >>>> Seems you want to have poor quality non-interoperable GP software to go on >>>> forever in >>>> >> OZ - or have I got it wrong and you really would like some decent >>>> quality control etc? >>>> >>> No, I am absolutely in favour of formal quality assurance programmes >>> and/or accreditation for health-related software - more the former than the >>> latter but they start to merge if done correctly - iff (if and only if) the >>> process is both effort and financially efficient and completely transparent. >>> >>> Here is how you achieve that: >>> >>> a) establish a *small* unit to develop the accreditation standards in a >>> consultative and transparent fashion, using email and the Internet >>> (wikis etc), and not endless secretive meetings in capital cities with >>> people who don't really have much of a clue, or who have a barrow to push (or >>> both). Allow one year to develop Version 1.0 accreditation standards. >>> >>> b) Design the accreditation standards/tests to be automatable wherever >>> possible - and this is most places - so the software vendors/producers can write >>> automated, scripted tests to demonstrate the conformance of >>> new versions of their code with minimal re-testing overhead. In places where automation is not possible, then "screencast" movies, made by the vendor, of >>> the software performing some specified set of actions or tasks or >>> demonstrating a required feature should be able to be >>> submitted. software to record screencasts (eg Camtasia) only costs a few >>> hundred dollars. Any cheating by the vendor in such screencasts will be obvious, >>> because end users can replicate the steps shown in the screencast >>> themselves and call teh vendor's bluff. >>> >>> c) All automated test scripts, other test code, test data, the test >>> results and screencasts etc must all be submitted to the accreditation >>> body, which runs the tests, views the screencasts, checks the >>> documentation and then publishes the lot on their Web site for public >>> scrutiny. This allows end users, public interest groups, competitors,, busy-bodies >>> and do-gooders to independently verify that the tests are correct and >>> legitimate and that no cheating has occurred. There is a >>> formal complaints process by which the accreditation body can be asked to >>> investigate evidence of cheating or anomalies or mistakes given some prima >>> facie evidence that such has occurred. >>> >>> Given the modest size of the Australian health software market, all of the >>> above should only require a handful of staff to run. It leverages >>> the power which the Internet brings to consumer groups and end users to >>> help the accreditation body do its work. >>> >>> Of course, software vendors may object to having their testing source >>> code published on the Internet, but to such an objection the answer has to >>> be that only test source code is required to be published - there is *no* >>> requirement to publish the source code of the actual software. If they >>> object that even such test code may reveal trade secrets, then the response has to >>> be that we are talking about health and medical software here, malfunctions >>> of which can have serious impacts on patient's lives, and thus the public >>> interest must override any commercial concerns over possible exposure of >>> trade secrets, so tough! >>> >>> That's the way to do medical software accreditation. >>> >>> Tim C >>> >>>> On Sat, 24 Feb 2007 20:32:16 +1100, Tim Churches wrote: >>>>> David More wrote: >>>>>> Hi Oliver, >>>>>> >>>>>> They are about 2 years into the program. >>>>>> >>>>>> They are also about 1 year into certifying hospital systems. >>>>>> >>>>>> Now that they have 40+ systems certified (at $US28,000 per time) >>>>>> >>>>> There has been much discussion of these fees on the international open >>>>> health list - >>>>> >> fees of such magnitude effectively exclude open source and community- >>>>> based >>>>> >>>> solutions. Not only that, they want the US$28k for every new version >>>>> to be re-tested. So, if a vendor puts out a minor point release, ka-ching >>>>> (sound of >>>>> >> cash >>>> register), another $28k please. And their justification is that it >>>>> takes person-time to re-do the tests. Seems they've never heard of an >>>>> automated test - >>>>> >>>> write the tests once, re-run at the push of a button, which is how all >>>> >>>>> software should be tested as it is built these days. Thus, CCHIT is a >>>>> farce in >>>>> >> practice >>>> (Horst can supply some suitably colourful epithets here). A bit like >>>>> accreditation of general practices here in Oz, perhaps? >>>>> >>>>> Tim C >>>>> >>>>>> On Sat, 24 Feb 2007 17:10:27 +1030, Oliver Frank wrote: >>>>>>> David More wrote: >>>>>>>> Hi Oliver, >>>>>>>> >>>>>>>> If you want to know how it can be done properly for ambulatory care >>>>>>>> (i.e. GP and >>>>>>>> >>>>>> specialists) I suggest you browse www.cchit.org. They have it sorted for >>>>>> >>>>>>>> the US and it is pretty impressive how they plan to move forward I >>>>>>>> reckon. >>>>>>>> >>>>>>>> Pity GP systems is not a focus for NEHTA so this could be replicated >>>>>>>> here. Imagine >>>>>>>> >> if >>>>>> there was a decent standard for functionality and interoperability >>>>>>>> that Australian providers had to meet. They might not be all that >>>>>>>> supportive of >>>>>>>> >> such >>>> a >>>>>> sensible move I fear as it might cost a few $$ and so on. >>>>>>> http://www.cchit.org/physicians/overview.htm >>>>>>> >>>>>>> tells us: >>>>>>> >>>>>>> "CCHIT is the recognized certification authority in the United States >>>>>>> for EHR >>>>>>> >> products >>>> - >>>>>> an independent, private-sector organization that sets the Gold >>>>>>> Standard for EHRs." >>>>>>> >>>>>>> I hope that I never hear that overworked expression 'gold standard' >>>>>>> used again, >>>>>>> >>>> because >>>>>> its orginal meaning is no longer known by most people. >>>>>>> Their PDF: "Physician's Guide: CCHIT Certification for Ambulatory >>>>>>> Electronic Health >>>>>>> >>>>>> Records 2006" >>>>>>> tells us: >>>>>>> >>>>>>> "CCHIT was founded by the American Health >>>>>>> Information Management Association, >>>>>>> the Healthcare Information and Management >>>>>>> Systems Society and the National Alliance >>>>>>> for Health Information Technology. >>>>>>> The U.S. Department of Health and Human >>>>>>> Services (HHS) awarded CCHIT a three-year >>>>>>> contract to develop and test certification >>>>>>> criteria and manage an inspection process >>>>>>> for certifying EHRs. At the end of the >>>>>>> contract, CCHIT will transition to a selfsustaining >>>>>>> certification agency." >>>>>>> >>>>>>> So they have three years of federal government money to kick start the >>>>>>> process, then >>>>>>> >>>> it >>>>>> has to become self-funding. David, do you know when their three >>>>>>> years of government funding will be up? >>>>>>> >>>>>>> "CCHIT works in collaboration with the >>>>>>> American Health Information Community, >>>>>>> the Department of Commerce's National >>>>>>> Institute of Standard and Technology, and >>>>>>> with several other organizations awarded >>>>>>> HHS contracts to harmonize standards, >>>>>>> develop prototypes for a national health >>>>>>> information network architecture, and assess >>>>>>> privacy and security laws and practices. >>>>>>> The work of CCHIT has been endorsed by a >>>>>>> number of physician professional organizations, >>>>>>> including: >>>>>>> - The American Academy of Family Physicians" >>>>>>> >>>>>>> OK, so their equivalent of the RACGP is supporting it. Good. >>>>>>> >>>>>>> Let's also go for three years of government funding for an organisation indepenedent >>>>>>> >>>> of >>>>>> government, run by the profession and software industry jointly. >>>>>>> Maybe we can save some time and money by using or adapting some of the >>>>>>> standards >>>>>>> >> that >>>>>> CCHIT has developed for GP computer systems in the US, keeping in mind >>>>>> >>>>>>> the very different way that medical practice is organised and funded >>>>>>> there. >>>>>>> >>>>>> ------------------------------------------------------------------------ >>>>>> >>>>>> _______________________________________________ >>>>>> Gpcg_talk mailing list >>>>>> [email protected] >>>>>> http://ozdocit.org/cgi-bin/mailman/listinfo/gpcg_talk >>>>>> >>>>> _______________________________________________ >>>>> Gpcg_talk mailing list >>>>> [email protected] >>>>> http://ozdocit.org/cgi-bin/mailman/listinfo/gpcg_talk >>>>> >>>>> __________ NOD32 2078 (20070223) Information __________ >>>>> >>>>> This message was checked by NOD32 antivirus system. >>>>> http://www.eset.com >>>>> >>> __________ NOD32 2079 (20070224) Information __________ >>> >>> This message was checked by NOD32 antivirus system. >>> http://www.eset.com > > > __________ NOD32 2079 (20070224) Information __________ > > This message was checked by NOD32 antivirus system. > http://www.eset.com
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