The current CCHIT pricing module seems biased against any GPL based system.
Joseph has already written about this, but I would like for us to consider
group action in the issue.

The first issue is pricing. It will cost a $25,000 to $35,000 one-time fee
to perform the test. After certification, an annual fee based on sales will
be required which will be at least $5,000 a year. According to...

This pricing assumes a proprietary business model. The "seal of approval"
model is also problematic. Suppose I pay the fee to have MirrorMed (my
project of choice) certified. There is no way for me to guarentee that only
I benifit from the "seal". My competitors which have full access to the code
that I would have certified would be able to correctly claim that the code
had been certified, and would benifit with me. As with the original pricing
there is no way to fairly spread these kinds of costs across a community. As
a result, FOSS medical software could face an environment where there
products could not compete against "certified" proprietary products.

Free and Open Source EMR vendors are not the only one effected by this. This
will target any small vendor, open source or otherwise. is
writing a group letter for the CCHIT feedback process which points this out.

I think that we should consider also writing a group letter. I would be
willing to author this, if I knew that once it was written and reviewed,
that some of the influential people on this list might sign it. Another
possiblity is to piggy-back on the emrupdate letter. Thoughts?

Fred Trotter
SynSeer, Consultant
phone: (480)290-8109

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