Re: [openhealth] CCHIT biased towards proprietary software??

[David Chan]

Joseph may remember the first time I had to take my
previous EMR product (MUFFIN) through conformance
testing. It took months of planning, documentation,
test server and configuration, and then finally a week
of testing - basically going through point by point of
the system specification. I was also the programmer
then so the cost was primarily my time (hours of
evenings and weekends).

With the OntarioMD certification for OSCAR, I had to
hire a manager level staff for about 6 months to deal
with the documentations and vendor meetings,
coordinate with a dedicated programmer to modify OSCAR
to meet the requirements - which turned out to be
quite extensive, and then to prepare for the week long
testing under a specific testing configuration. I
don't have an accurate cost but we did reserve about
$50,000 for just the programming alone (we also had to
contract out a couple of pieces to work to an outside
programmer).

Conformance testing is expensive. We were able to get
funding from the government for using a certified
product at the end (much more than we had spent on
doing it). It would have been difficult to come up
with the money and energy if we hadn't anticipated the
funding opportunity.

Hope this information helps. Obviously, every
situation is a bit different.

Best regards,
David

--- Joseph Dal Molin <[EMAIL PROTECTED]> wrote:

> In the pilot test of the criteria vendors took
> between roughly 30 and 
> 300 hours to document their solutions.don't know
> to what extent they 
> wentso Tim's estimate sounds reasonable. We
> estimated it will take 
> 300 hours for VistA Officewe will let everyone
> know when we are done 
> how long it took.
> 
> I personally believe certification is
> importantbut it should impose 
> as small a "tax'  as possible, regardless of the
> license, business model 
> etc. Automated scripts would go a long way to
> achieve this.
> 
> Would be interesting to hear from David Chan how
> much effort was 
> required to certify OSCAR in Ontario, Canada?
> 
> Joseph
> WorldVistA, VVSO
> 
> Tim.Churches wrote:
> 
> > Test files?In fact, there is no reason why
> automated test scripts
> > couldn't be used to demonstrate compliance with
> the criteria described
> > by CCHIT - see
> http://www.cchit.org/publiccomment4.htm - but I get
> the
> > feeling that those framing the criteria had human
> actors in mind with
> > respect to their test scripts. I might be wrong.
> > 
> > Either way, it would seem quite feasible for an
> open source project to
> > publish documentation of how it meets the
> certification criteria in the
> > documents on the above Web page. Tedious to
> compile such documentation,
> > but still only person-weeks (or at worst one- o r
> two-person months)of
> > work, I suspect, not person years. Split it up
> between five or six
> > people and its doable without danger of inducing
> madness. If a project
> > did that, then the CCHIT charge for certification
> ought to be minimal,
> > if anything at all.
> > 
> > Tim C
> > 
> >
>

> > YAHOO! GROUPS LINKS
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> > 
> > .
> 


David H Chan, MD, CCFP, MSc, FCFP
Associate Professor
Department of Family Medicine
McMaster University

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Re: [openhealth] CCHIT biased towards proprietary software??

[Nandalal Gunaratne]

Business Readiness Rating™ - Home
 
 Could HIS be included here as well?
 
 NandA

Thomas Beale <[EMAIL PROTECTED]> wrote:Tim.Churches wrote:
 > Will Ross wrote:
 > > Fred,
 > >
 > > I oppose the creation of a separate open source certification
 > > process.   I think it compromises the opportunity for open source
 > > solutions to displace commercial solutions, and it distracts open
 > > source projects from leveraging the collaborative process to create
 > > seriously superior solutions.
 >
 > This is a US matter, but as I set out, my position would be to argue for
 > a reduced-cost certification process of any software which makes all the
 > necessary documentation, source code, unit tests, functional test
 > scripts etc needed to satisfy the certification criteria publicly
 > available for scrutiny by anyone.
 >
 > But the actual criteria to be met should be the same.
 I agree that this should be the basis. Certification should be a case of 
 paying someone to do the same thing you have already done, just without 
 you being there. It should be a $2k or less operation.
 
 - thomas beale
 


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Re: [openhealth] CCHIT biased towards proprietary software??

[Nandalal Gunaratne]

Will Ross <[EMAIL PROTECTED]> wrote:
 
 I too agree. Certification is a matter of standards and quality. ther should 
be no compromise. The FOSS once equally certified maybe able to make stroner 
claims. However because of the collaborative/community type of development, 
there could be a waver of the fee or some consideration given if the software 
or a version of it is to be given free, and the FOSS based company hopes to 
make money by the enterprise edition or by support only. Thus the fee can be
 1. less
 2. full but paid in installments?
 
 NandA
 Fred,
 
 I oppose the creation of a separate open source certification  
 process.   I think it compromises the opportunity for open source  
 solutions to displace commercial solutions, and it distracts open  
 source projects from leveraging the collaborative process to create  
 seriously superior solutions.
 
 With best regards,
 
 [wr]
 
 - - - - - - - -
 
 On Mar 27, 2006, at 10:16 AM, Fred Trotter wrote:
 
 > This is an interesting discussion. However we do have some  
 > decisions to
 > make.
 >
 > 1. Does the different nature free and open source medical software  
 > warrant
 > different consideration than proprietary models for CCHIT  
 > certification
 > pricing. (If a large number of people feel this way then we should  
 > draft our
 > own letter.)
 > Yes/No
 >
 > 2. In NOT should the pricing generally be lowered for everyone so  
 > that small
 > and open source projects will have the opportunity to get  
 > certified. (If you
 > feel this way then you should just sign the emrupdate.com letter)
 > Yes/No
 >
 > Feel free to continue the substance of the discussion by saying why  
 > or why
 > not for your answers. In any case if you feel that a letter should be
 > written or signed... now is the time to do so the review window is  
 > closing.
 > --
 > Fred Trotter
 > SynSeer, Consultant
 > http://www.fredtrotter.com
 > http://www.synseer.com
 > phone: (480)290-8109
 > email: [EMAIL PROTECTED]
 >
 >
 > [Non-text portions of this message have been removed]
 >
 >
 >
 >
 > Yahoo! Groups Links
 >
 >
 >
 >
 >
 >
 >
 
 
 [wr]
 
 - - - - - - - -
 
 will ross
 project manager
 mendocino informatics
 216 west perkins street, suite 206
 ukiah, california  95482  usa
 707.272.7255 [voice]
 707.462.5015 [fax]
 www.minformatics.com
 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Nandalal Gunaratne]

Greg Woodhouse <[EMAIL PROTECTED]> wrote:
 
 Your two questions will have different answers because the usage and business 
models will be different. HIS will be used by differnet people for differnt 
purposes. The government will expect high degree of safety, but will be abale 
to bare the costs. A hospital or a group providing healthcare maybe happy with 
a lesser degree of safety, will expect to spend less. There will be doctors who 
want a system to just to a EMR with bulling and insurance, for research and/or 
audit who may not be too concerned with security so much and will expect 
something affordable and user friendly.
 Certifiction maybe unnecesary for them
 
 If certification is costly, the software and licences will also be costly and 
some end users may not be happy to pay for this. In less developed countries 
when $100 is what a doctor may make for a month, costs will be a serious 
problem. But hey will wnat to keep an EMR too!
 
 In the US, the US government will require the highest level of sfety and 
certification at various levels maybe needed.
 
 DIfferent worlds need different needs. 
 
 NandA
 Aren't we missing the larger issue? Proper certification of health
 information systems is going to be expensive, and that is probably
 unavoidable. Moeover, someone is going to have to bear the burden of
 that cost. I'm not sure that this question should really be tied to the
 certification model, though. One issue is primarily technical: How do
 we determine that this device or system is safe? The other is a
 business question: Who's going to pay for it?
 
 ===
 Gregory Woodhouse  <[EMAIL PROTECTED]>
 
 "It is foolish to answer a question that
 you do not understand."
 --G. Polya ("How to Solve It")


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Re: [openhealth] CCHIT biased towards proprietary software??

[Maury Pepper]

It worries me when a single organization is in a position to set the criterion 
for certification and set the price.  If being certified is required as entry 
to some markets, then the organization is in a position similar to a government 
regulator.  To break up this monopoly, I would suggest that others must be 
allowed to compete for your certification dollars -- all following the same 
standard criterion.  They can compete based on price, service and whatever else 
appeals to the customer.
-mlp-

- Original Message - 
From: "Fred Trotter" <[EMAIL PROTECTED]>
To: 
Sent: Monday, March 27, 2006 5:29 PM
Subject: Re: [openhealth] CCHIT biased towards proprietary software??


> It sounds like there is little consensus for having any special status for
> open source software. Certainly not enough to warrant a group letter. Are
> there any more thoughts on how much a certification should cost?
> 
> -FT
> 


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

Greg Woodhouse wrote:
> It seems to me that there are two threads of discussion here that are
> not at all merging. One issue is whether testing can and should be made
> cheaper. Maybe it can, but testing is the last line of defense in
> software quality, and is highly problematic, relying essentially on
> chance to hit upon the right combination of conditions to cause a
> defect in the software to manifest itself. It may be that extensive

H.. I see what you mean, but I believe it's possible to use the 
testing and certification process as the _first_ line of defense in a 
good quality control program.  The actual certification from say, CCHIT 
would occur last, but high marks on certification should indicate that 
testing, overall was an integral part of development.

> testing (in the form of clinical trials) is the state of the art in
> medicine, too. But in software we can and should do better. Every
> computer science student learns in his or her first semester that the
> halting problem is insoluble, and so we all throw up our hands and say:

Gregory is right on this count. One of the first things I learned in 
computer science school was "If houses were built like software, they 
would all fall down."  I've always tried to do better than that in my 
designs.


Richard Schilling



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

Fred Trotter wrote:
> This is an interesting discussion. However we do have some decisions to
> make.
> 
> 1. Does the different nature free and open source medical software warrant
> different consideration than proprietary models for CCHIT certification
> pricing. (If a large number of people feel this way then we should draft our
> own letter.)
> Yes/No

No. In fact it doesn't matter.  And, the pricing model should not 
change.  Open Source stimulates more ECONOMIC development overall than 
proprietary software does. So, I believe successful open source projects 
will ultimately have more money to spend on certification than 
proprietary companies.


> 
> 2. In NOT should the pricing generally be lowered for everyone so that small
> and open source projects will have the opportunity to get certified. (If you
> feel this way then you should just sign the emrupdate.com letter)
> Yes/No

No. I'm actually expecting the price to go up at some point.  If the 
price gets lower, I would expect more proprietary companies to seek 
certification.


Richard


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

Greg Woodhouse wrote:
> Aren't we missing the larger issue? Proper certification of health
> information systems is going to be expensive, and that is probably
> unavoidable. Moeover, someone is going to have to bear the burden of
> that cost. I'm not sure that this question should really be tied to the
> certification model, though. One issue is primarily technical: How do
> we determine that this device or system is safe? The other is a
> business question: Who's going to pay for it?

This gets back to the statement I just made about open source software 
development always being part of a business process.

Some "personal business processes" won't support certification (e.g. you 
develop health care software as a hobby, but are poor).

Other "personal business processes" will support certification through 
"passion"(you have a really good job, develop health care software as a 
hobby, and can pay for it).

Some real business processes will support certification just fine.  IBM 
or Sun Microsystems might justify certificaton costs, for example to 
sell more hardware.

And other business processes will excell at certification (your company 
is a pure services open source development company).


Richard




> 
> ===
> Gregory Woodhouse  <[EMAIL PROTECTED]>
> 
> "It is foolish to answer a question that
> you do not understand."
> --G. Polya ("How to Solve It")
> 
> 
>  
> Yahoo! Groups Links
> 
> 
> 
>  
> 
> 
> 
> 



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

I understand Rod's point, and I believe that if you choose to restrict 
your activities to a purely altruistic ideal, then what Rod talks about 
and what Eric Rayomond talks about is just fine.  But, I argue that at 
any point you invest time into open source (as a user,developer, etc.) 
it is always part of a business model.  It's just a matter of degrees.

For the benefit of open source, it can no longer, especially in the case 
of health care software, remain "garage at-home projects."  Capital 
needs to be fed to those individuals doing the work, AND it's important 
to make sure those individuals are always associated with the project in 
the public's eye.  Otherwise progress will become stagnate.

The question is, which business model accelerates open source 
development faster?

Richard




Rod Roark wrote:
> On Saturday 25 March 2006 03:08 am, Thomas Beale wrote:
> 
>>Rod Roark wrote:
>>
>>>The point is, open source (as in Free Software) is NOT a business
>>>model.  It's a method and end result of collaboration among users.
>>>I make good money at it only because some of those users are willing
>>>to pay me to do the techie work for them.
>>
>>if someone is paying you something, then there is a business model. It's 
>>better to be aware of what it is than pretend that it isn't there
> 
> 
> My business is just work for hire, and I can assure you that I'm aware
> of it.  :-)  This has nothing to do with my point.
> 
> For a better understanding of the nature of Free Software, see Eric
> Raymond's classic work at:
> 
> http://www.catb.org/~esr/writings/cathedral-bazaar/cathedral-bazaar/
> 
> and as an interesting exercise, count how many times the word
> "business" appears.
> 
> -- Rod
> www.sunsetsystems.com
> 
> 
>  
> Yahoo! Groups Links
> 
> 
> 
>  
> 
> 
> 



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Fred Trotter]

It sounds like there is little consensus for having any special status for
open source software. Certainly not enough to warrant a group letter. Are
there any more thoughts on how much a certification should cost?

-FT


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Re: [openhealth] CCHIT biased towards proprietary software??

[Thomas Beale]

Greg Woodhouse wrote:
> It seems to me that there are two threads of discussion here that are
> not at all merging. One issue is whether testing can and should be made
> cheaper.
I didn't think we were talking about testing; we were talking about 
certification. Certification is about getting a tick for being able to 
correctly process e.g. 10 XML files, and respond correctly to 20 API 
calls (all published criteria). This isn't done to test the product but 
to ascertain what it can do, and whether it does what it claims.

Testing has to have happened long before that, and is likely to involve 
an order of magnitude more test cases and data.

- thomas beale



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Thomas Beale]

Tim.Churches wrote:
> Will Ross wrote:
> > Fred,
> >
> > I oppose the creation of a separate open source certification
> > process.   I think it compromises the opportunity for open source
> > solutions to displace commercial solutions, and it distracts open
> > source projects from leveraging the collaborative process to create
> > seriously superior solutions.
>
> This is a US matter, but as I set out, my position would be to argue for
> a reduced-cost certification process of any software which makes all the
> necessary documentation, source code, unit tests, functional test
> scripts etc needed to satisfy the certification criteria publicly
> available for scrutiny by anyone.
>
> But the actual criteria to be met should be the same.
I agree that this should be the basis. Certification should be a case of 
paying someone to do the same thing you have already done, just without 
you being there. It should be a $2k or less operation.

- thomas beale



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Greg Woodhouse]

It seems to me that there are two threads of discussion here that are
not at all merging. One issue is whether testing can and should be made
cheaper. Maybe it can, but testing is the last line of defense in
software quality, and is highly problematic, relying essentially on
chance to hit upon the right combination of conditions to cause a
defect in the software to manifest itself. It may be that extensive
testing (in the form of clinical trials) is the state of the art in
medicine, too. But in software we can and should do better. Every
computer science student learns in his or her first semester that the
halting problem is insoluble, and so we all throw up our hands and say:
Software is just too complicated. We can't understand it. At best, we
can test what we have and see if it behaves as we expect. Whatever its
merit, that's a defeatist attittude. There is a LOT we can do to
improve the reliability and safety of software systems. To me, the key
to making reliability cost effective is to come up with better
solutions, not just put more money into testing.

===
Gregory Woodhouse  <[EMAIL PROTECTED]>

"It is foolish to answer a question that
you do not understand."
--G. Polya ("How to Solve It")


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Tim.Churches]

Will Ross wrote:
> Fred,
> 
> I oppose the creation of a separate open source certification 
> process.   I think it compromises the opportunity for open source 
> solutions to displace commercial solutions, and it distracts open 
> source projects from leveraging the collaborative process to create 
> seriously superior solutions.

This is a US matter, but as I set out, my position would be to argue for
a reduced-cost certification process of any software which makes all the
necessary documentation, source code, unit tests, functional test
scripts etc needed to satisfy the certification criteria publicly
available for scrutiny by anyone.

But the actual criteria to be met should be the same.

Tim C

> On Mar 27, 2006, at 10:16 AM, Fred Trotter wrote:
> 
>  > This is an interesting discussion. However we do have some 
>  > decisions to
>  > make.
>  >
>  > 1. Does the different nature free and open source medical software 
>  > warrant
>  > different consideration than proprietary models for CCHIT 
>  > certification
>  > pricing. (If a large number of people feel this way then we should 
>  > draft our
>  > own letter.)
>  > Yes/No
>  >
>  > 2. In NOT should the pricing generally be lowered for everyone so 
>  > that small
>  > and open source projects will have the opportunity to get 
>  > certified. (If you
>  > feel this way then you should just sign the emrupdate.com letter)
>  > Yes/No
>  >
>  > Feel free to continue the substance of the discussion by saying why 
>  > or why
>  > not for your answers. In any case if you feel that a letter should be
>  > written or signed... now is the time to do so the review window is 
>  > closing.
>  > --
>  > Fred Trotter
>  > SynSeer, Consultant
>  > http://www.fredtrotter.com
>  > http://www.synseer.com
>  > phone: (480)290-8109
>  > email: [EMAIL PROTECTED]
>  >
>  >
>  > [Non-text portions of this message have been removed]
>  >
>  >
>  >
>  >
>  > Yahoo! Groups Links
>  >
>  >
>  >
>  >
>  >
>  >
>  >
> 
> 
> [wr]
> 
> - - - - - - - -
> 
> will ross
> project manager
> mendocino informatics
> 216 west perkins street, suite 206
> ukiah, california  95482  usa
> 707.272.7255 [voice]
> 707.462.5015 [fax]
> www.minformatics.com
> 
> - - - - - - - -
> 
> "Getting people to adopt common standards is impeded by patents."
>  Sir Tim Berners-Lee
> 
> - - - - - - - -
> 
> 
> 
> 
> 
> YAHOO! GROUPS LINKS
> 
> *  Visit your group "openhealth 
> "
>   on the web.
>
> *  To unsubscribe from this group, send an email to:
>[EMAIL PROTECTED]
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>
> *  Your use of Yahoo! Groups is subject to the Yahoo! Terms of Service
>   . 
> 
> 
> 
> 



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Greg Woodhouse]

--- Will Ross <[EMAIL PROTECTED]> wrote:


-
Fred,

I oppose the creation of a separate open source certification  
process.   I think it compromises the opportunity for open source  
solutions to displace commercial solutions, and it distracts open  
source projects from leveraging the collaborative process to create  
seriously superior solutions.

With best regards,

[wr]

[GJW]
I agree that certirfication should be the same for all software: open
source or not. After all, we don't want open source to be reduced to a
second class status, considered less desirable and less safe than
proprietary options.

===
Gregory Woodhouse  <[EMAIL PROTECTED]>

"It is foolish to answer a question that
you do not understand."
--G. Polya ("How to Solve It")


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Rod Roark]

On Monday 27 March 2006 09:46 am, Will Ross wrote:
> Rod,
> 
> In general, I think it is unhelpful to imagine that Free Software has  
> a nature entirely separate from commercial activity.   Eric Raymond's  
> meta-analysis is a useful historical document, but is not relevant to  
> this discussion.   We are discussing the relationship between open  
> source business models and CCHIT fees, not the sociology of  
> collaboration, which is Mr. Raymond's sphere of emphasis.   I suggest  
> instead considering the works Steven Weber or Eric Von Hippel, where  
> "open source" and "business model" are the point of the analysis.
> 
>http://web.mit.edu/evhippel/www/democ.htm

Thanks for the link.  This is a long document.  Is there any particular
part of this that you'd like me to consider?

On Monday 27 March 2006 09:43 am, Greg Woodhouse wrote:
> Aren't we missing the larger issue?

Each of us has our own idea of what the larger issue is.  For me as
an OpenEMR developer, the underpinnings of open source philosophy
are paramount.  Raymond's essay is not a "meta-analysis", it is a
specific case study.  And if we are talking about certification of
open source software and how it will be paid for, how can we
possibly ignore the fundamental motivations that create and sustain
open source projects?

I think it's fair in this discussion to question even the value of
certification.  Who gets to decide if a software solution is a worthy
one if not those who actually use it and also happen to drive its
development?  Frankly I think a lot of people would love to be in such
a position of power without having earned it.

Consider other mission critical applications such as mail servers,
web servers, desktop environments, operating systems, SQL databases,
compilers and Java application servers.  Open source is well
represented, very popular and highly trusted in all of these areas,
yet nobody is screaming for certification bodies to oversee them.

I'm not saying that certification should or should not happen.  I'm
just saying that some very fundamental issues are not being
considered, at least not openly.

I understand that these thoughts may not be popular in this forum.
However I think somebody needed to express them.

-- Rod
www.sunsetsystems.com


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Will Ross]

Fred,

I oppose the creation of a separate open source certification  
process.   I think it compromises the opportunity for open source  
solutions to displace commercial solutions, and it distracts open  
source projects from leveraging the collaborative process to create  
seriously superior solutions.

With best regards,

[wr]

- - - - - - - -

On Mar 27, 2006, at 10:16 AM, Fred Trotter wrote:

> This is an interesting discussion. However we do have some  
> decisions to
> make.
>
> 1. Does the different nature free and open source medical software  
> warrant
> different consideration than proprietary models for CCHIT  
> certification
> pricing. (If a large number of people feel this way then we should  
> draft our
> own letter.)
> Yes/No
>
> 2. In NOT should the pricing generally be lowered for everyone so  
> that small
> and open source projects will have the opportunity to get  
> certified. (If you
> feel this way then you should just sign the emrupdate.com letter)
> Yes/No
>
> Feel free to continue the substance of the discussion by saying why  
> or why
> not for your answers. In any case if you feel that a letter should be
> written or signed... now is the time to do so the review window is  
> closing.
> --
> Fred Trotter
> SynSeer, Consultant
> http://www.fredtrotter.com
> http://www.synseer.com
> phone: (480)290-8109
> email: [EMAIL PROTECTED]
>
>
> [Non-text portions of this message have been removed]
>
>
>
>
> Yahoo! Groups Links
>
>
>
>
>
>
>


[wr]

- - - - - - - -

will ross
project manager
mendocino informatics
216 west perkins street, suite 206
ukiah, california  95482  usa
707.272.7255 [voice]
707.462.5015 [fax]
www.minformatics.com

- - - - - - - -

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 Sir Tim Berners-Lee

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Re: [openhealth] CCHIT biased towards proprietary software??

[Fred Trotter]

This is an interesting discussion. However we do have some decisions to
make.

1. Does the different nature free and open source medical software warrant
different consideration than proprietary models for CCHIT certification
pricing. (If a large number of people feel this way then we should draft our
own letter.)
Yes/No

2. In NOT should the pricing generally be lowered for everyone so that small
and open source projects will have the opportunity to get certified. (If you
feel this way then you should just sign the emrupdate.com letter)
Yes/No

Feel free to continue the substance of the discussion by saying why or why
not for your answers. In any case if you feel that a letter should be
written or signed... now is the time to do so the review window is closing.
--
Fred Trotter
SynSeer, Consultant
http://www.fredtrotter.com
http://www.synseer.com
phone: (480)290-8109
email: [EMAIL PROTECTED]


[Non-text portions of this message have been removed]



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Greg Woodhouse]

Aren't we missing the larger issue? Proper certification of health
information systems is going to be expensive, and that is probably
unavoidable. Moeover, someone is going to have to bear the burden of
that cost. I'm not sure that this question should really be tied to the
certification model, though. One issue is primarily technical: How do
we determine that this device or system is safe? The other is a
business question: Who's going to pay for it?

===
Gregory Woodhouse  <[EMAIL PROTECTED]>

"It is foolish to answer a question that
you do not understand."
--G. Polya ("How to Solve It")


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Will Ross]

Rod,

In general, I think it is unhelpful to imagine that Free Software has  
a nature entirely separate from commercial activity.   Eric Raymond's  
meta-analysis is a useful historical document, but is not relevant to  
this discussion.   We are discussing the relationship between open  
source business models and CCHIT fees, not the sociology of  
collaboration, which is Mr. Raymond's sphere of emphasis.   I suggest  
instead considering the works Steven Weber or Eric Von Hippel, where  
"open source" and "business model" are the point of the analysis.

   http://web.mit.edu/evhippel/www/democ.htm

With best regards,

[wr]

- - - - - - - -

On Mar 27, 2006, at 8:37 AM, Rod Roark wrote:

> On Saturday 25 March 2006 03:08 am, Thomas Beale wrote:
>> Rod Roark wrote:
>>> The point is, open source (as in Free Software) is NOT a business
>>> model.  It's a method and end result of collaboration among users.
>>> I make good money at it only because some of those users are willing
>>> to pay me to do the techie work for them.
>>
>> if someone is paying you something, then there is a business  
>> model. It's
>> better to be aware of what it is than pretend that it isn't there
>
> My business is just work for hire, and I can assure you that I'm aware
> of it.  :-)  This has nothing to do with my point.
>
> For a better understanding of the nature of Free Software, see Eric
> Raymond's classic work at:
>
> http://www.catb.org/~esr/writings/cathedral-bazaar/cathedral-bazaar/
>
> and as an interesting exercise, count how many times the word
> "business" appears.
>
> -- Rod
> www.sunsetsystems.com
>
>
>
> Yahoo! Groups Links
>
>
>
>
>
>
>


[wr]

- - - - - - - -

will ross
project manager
mendocino informatics
216 west perkins street, suite 206
ukiah, california  95482  usa
707.272.7255 [voice]
707.462.5015 [fax]
www.minformatics.com

- - - - - - - -

"Getting people to adopt common standards is impeded by patents."
 Sir Tim Berners-Lee

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Re: [openhealth] CCHIT biased towards proprietary software??

[Rod Roark]

On Saturday 25 March 2006 03:08 am, Thomas Beale wrote:
> Rod Roark wrote:
> > The point is, open source (as in Free Software) is NOT a business
> > model.  It's a method and end result of collaboration among users.
> > I make good money at it only because some of those users are willing
> > to pay me to do the techie work for them.
>
> if someone is paying you something, then there is a business model. It's 
> better to be aware of what it is than pretend that it isn't there

My business is just work for hire, and I can assure you that I'm aware
of it.  :-)  This has nothing to do with my point.

For a better understanding of the nature of Free Software, see Eric
Raymond's classic work at:

http://www.catb.org/~esr/writings/cathedral-bazaar/cathedral-bazaar/

and as an interesting exercise, count how many times the word
"business" appears.

-- Rod
www.sunsetsystems.com


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Gregory Woodhouse]

On Mar 25, 2006, at 9:01 PM, Tim.Churches wrote:

> Certainly formal quality assurance mechanisms for health-related
> software should be used where possible and reasonable, but it must  
> also
> be remembered that the practice of medicine itself is, at worst,  
> guided
> by a tradition of what seems to work as recorded in textbooks and  
> handed
> down by traditional teaching, and at best by "evidence based practice"
> which relies on meta-analyses of observational studies which have all
> sorts of design and execution flaws, or on (hopefully double-blind)  
> RCTs
> (randomised controlled trials) which typically have very limited
> generalisability to wider populations.
>
> Tim C

Ultimately, isn't the issue here whether we are concerned primarily  
with computer science, medicine (or perhaps both)? to be honest, the  
computer industry has not exactly done a stunning job in the quality  
department, but does that mean we can only respond with defeatism? In  
view, overemphasis on testing and process, to the exclusion of  
engineering principles is a major factor in our failure to develop  
reliable systems at a reasonable cost.

===
Gregory Woodhouse
[EMAIL PROTECTED]

"Design quality doesn't ensure success, but design failure can ensure  
failure."

--Kent Beck




 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Tim.Churches]

Gregory Woodhouse wrote:
> On Mar 25, 2006, at 5:01 PM, Joseph Dal Molin wrote:
> 
>  > and...at the risk of stating the obvious there should be some
>  > mechanism for evaluating the certification authority and the 
>  > criteria...
>  >
> 
> Sadly, I don't know how many people are even thinking in those terms. 
> What we are discussing here is software quality (meaning fitness for 
> a particular purpose), and it may well be that people with the 
> appropriate expertise are not well represented in this process. 
> Worse, the current standard (in medicine, one might say "standard of 
> care") in this area is heavily biased towards testing and informal 
> (if any) requirements definition. Formal methods, automated proof 
> systems, rigorous specifications, and so forth are all thought of as 
> rather esoteric or "academic" (purposely using what Guy L. Steele 
> perceptively called horror quotes in his thesis!) I know I've written 
> correctness proofs for no reason but to satisfy myself that an 
> algorithm I developed was correct. It's not such a terrible thing. 
> Perhaps medicine is an area where we ought to start thinking about 
> setting aside industry standard practice and thinking in terms of 
> more rigorous methods of validating softwares -- which, after all is 
> used in patient care!

Certainly formal quality assurance mechanisms for health-related
software should be used where possible and reasonable, but it must also
be remembered that the practice of medicine itself is, at worst, guided
by a tradition of what seems to work as recorded in textbooks and handed
down by traditional teaching, and at best by "evidence based practice"
which relies on meta-analyses of observational studies which have all
sorts of design and execution flaws, or on (hopefully double-blind) RCTs
(randomised controlled trials) which typically have very limited
generalisability to wider populations.

Tim C



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Gregory Woodhouse]

On Mar 25, 2006, at 5:01 PM, Joseph Dal Molin wrote:

> and...at the risk of stating the obvious there should be some
> mechanism for evaluating the certification authority and the  
> criteria...
>

Sadly, I don't know how many people are even thinking in those terms.  
What we are discussing here is software quality (meaning fitness for  
a particular purpose), and it may well be that people with the  
appropriate expertise are not well represented in this process.  
Worse, the current standard (in medicine, one might say "standard of  
care") in this area is heavily biased towards testing and informal  
(if any) requirements definition. Formal methods, automated proof  
systems, rigorous specifications, and so forth are all thought of as  
rather esoteric or "academic" (purposely using what Guy L. Steele  
perceptively called horror quotes in his thesis!) I know I've written  
correctness proofs for no reason but to satisfy myself that an  
algorithm I developed was correct. It's not such a terrible thing.  
Perhaps medicine is an area where we ought to start thinking about  
setting aside industry standard practice and thinking in terms of  
more rigorous methods of validating softwares -- which, after all is  
used in patient care!

===
Gregory Woodhouse
[EMAIL PROTECTED]

"And the end of all our exploring
will be to arrive where we started
And know the place for the first time"
-- T.S. Eliot






 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Joseph Dal Molin]

It's a non-profit that won a Health and Human Services Tender to 
implement the ONCHIT EHR criteria.

 > I agree, but certifying authorities such as CCHIT (is CCHIT a govt
 > certification authority or is it a certifying business set up to make
 > money or is it an "industry" non-profit set up to perform a service?)
 > need to to be told to concentrate on making their validation criteria as
 > automatable and repeatable as possible

and...at the risk of stating the obvious there should be some 
mechanism for evaluating the certification authority and the criteria...



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Tim.Churches]

Will Ross wrote:
> On Mar 24, 2006, at 9:44 PM, Rod Roark wrote:
> 
>  > I repeat: NOBODY will pay thousands for certification of Free
>  > Software.  They will use it because they already believe in it.
> 
> Rod,
> 
> I have been following the CCHIT process.   I do not consider CCHIT to 
> be biased against open source.   I think competing on a level playing 
> field for a fair, tough, industry standard certification is good 
> idea.   The cost is trivial.   If an open source project cannot 
> produce a coherent release candidate and collectively finance its 
> certification by CCHIT, then that open source project has not scaled 
> up to be a credible package for real clinical situations where lives 
> may hang in the balance.
> 
> I also think it is a disservice to the open source definition to 
> propose a dumbed down parallel open source certification process.   I 
> have no plans to pitch physicians on on software they can "believe" 
> in.   I want solid open source code that can be equally certified by 
> CCHIT alongside NextGen, Centricity, Allscripts, et. al.   I see a 
> huge marketing advantage for open source to stand up, get certified, 
> and start taking business away from the proprietary vendors.

I agree, but certifying authorities such as CCHIT (is CCHIT a govt
certification authority or is it a certifying business set up to make
money or is it an "industry" non-profit set up to perform a service?)
need to to be told to concentrate on making their validation criteria as
automatable and repeatable as possible. Not all criteria can be
automated, but those that can't still need to be specified in a manner
which maximises re-usability - in particular, the form of the vendor's
response. Having a human validator with a clipboard and a tick list,
laboriously working through each test script on each occasion of testing
is not the way it ought to be done. Automated testing tools are the way
to go, and organisations like CCHIT should be prepared to accept scripts
for such testing tools as evidence that criteria are met. Sure they
still need to validate that the test script actually demonstrates that
the criterion in question is met - but they need only do that once.
Repeat testing is then a) check the script is the same as last time b)
click a button. The mantra for testing of all types - unit tests,
regression tests, functional and integration tests - is automate and
then do it often. I can't see why certification criteria can't be guided
by that same principle.

Tim C



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Will Ross]

On Mar 24, 2006, at 9:44 PM, Rod Roark wrote:

> I repeat: NOBODY will pay thousands for certification of Free
> Software.  They will use it because they already believe in it.

Rod,

I have been following the CCHIT process.   I do not consider CCHIT to  
be biased against open source.   I think competing on a level playing  
field for a fair, tough, industry standard certification is good  
idea.   The cost is trivial.   If an open source project cannot  
produce a coherent release candidate and collectively finance its  
certification by CCHIT, then that open source project has not scaled  
up to be a credible package for real clinical situations where lives  
may hang in the balance.

I also think it is a disservice to the open source definition to  
propose a dumbed down parallel open source certification process.   I  
have no plans to pitch physicians on on software they can "believe"  
in.   I want solid open source code that can be equally certified by  
CCHIT alongside NextGen, Centricity, Allscripts, et. al.   I see a  
huge marketing advantage for open source to stand up, get certified,  
and start taking business away from the proprietary vendors.

With best regards,

[wr]

- - - - - - - -

will ross
project manager
mendocino informatics
216 west perkins street, suite 206
ukiah, california  95482  usa
707.272.7255 [voice]
707.462.5015 [fax]
www.minformatics.com

- - - - - - - -

"Getting people to adopt common standards is impeded by patents."
 Sir Tim Berners-Lee

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Re: [openhealth] CCHIT biased towards proprietary software??

[Fred Trotter]

Before I contributed to the opinions raised I would like to point out
several things that my recent investigations have pointed out. First, the
proposed fees are "straw man" fees CCHIT wants feedback on these prices.
They are not at all set in stone.

They also have some mechanisms in place to handle version issues. That is
why the certification only lasts three years and is associated with a
particular version.

Now for the sake of argument, lets assume that these mechanisms work and the
rapidly changing versions that Rod has pointed out will not be a problem.

Rods other point is very signifigant. He sees no benifit for himself as a
developer. In fact Rod is a case study in what I consider to be the heart of
this and several other problems in "open source medicine". That is the
freeloader problem. Most of the people who use OSS do not pay anything for
it. RedHat and other companies do very well but their income is trivial
compared to Microsofts because Microsofts customers either pay or break the
law.

Lets imageine that 100 practices use Epic. How many of the paid epic for it?
probably 100. Say 100 people use OpenEMR how many people would pay Rod. My
guess is 5. Rods ok with that, and so am I. But that does mean that there is
a substantive difference between Rod and Epic. Linus does pretty well except
when you compare him to Bill. That does not mean that OpenEMR is not as
ligitimate as Epic, all it means is that EPIC business model is well-suited
towards paying for certifications.

My personal opinion is that using proprietary licenses is a kind of
profiteering. It seems trivial to me that no software for medical purposes
should be published without an opensource license. After all, is not a
source code review the most telling examination of a codebase? The idea of
certification seems to be a way to get around openess.

Now many of you would view the opinions stated there as very radical. (Thats
the rsponse that I get when I say things like this on emrupdate.com) but
this is just the counter position to the current CCHIT pricing scheme which
only a proprietary business model can afford. They are essentially saying
that unless you profit from a proprietary license then your product is not
legitimate. This is not the first time this has happend...

Take a close look at the HIMSS EHRVA effort. At first it looks like a worthy
effort for vendors to work towards interoperability. But a close read of the
application shows that only proprietary vendors can apply.

http://www.himssehrva.org/ASP/index.asp


--
Fred Trotter
SynSeer, Consultant
http://www.fredtrotter.com
http://www.synseer.com
phone: (480)290-8109
email: [EMAIL PROTECTED]


[Non-text portions of this message have been removed]



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Joseph Dal Molin]

In the pilot test of the criteria vendors took between roughly 30 and 
300 hours to document their solutions.don't know to what extent they 
wentso Tim's estimate sounds reasonable. We estimated it will take 
300 hours for VistA Officewe will let everyone know when we are done 
how long it took.

I personally believe certification is importantbut it should impose 
as small a "tax'  as possible, regardless of the license, business model 
etc. Automated scripts would go a long way to achieve this.

Would be interesting to hear from David Chan how much effort was 
required to certify OSCAR in Ontario, Canada?

Joseph
WorldVistA, VVSO

Tim.Churches wrote:

> Test files?In fact, there is no reason why automated test scripts
> couldn't be used to demonstrate compliance with the criteria described
> by CCHIT - see http://www.cchit.org/publiccomment4.htm - but I get the
> feeling that those framing the criteria had human actors in mind with
> respect to their test scripts. I might be wrong.
> 
> Either way, it would seem quite feasible for an open source project to
> publish documentation of how it meets the certification criteria in the
> documents on the above Web page. Tedious to compile such documentation,
> but still only person-weeks (or at worst one- o r two-person months)of
> work, I suspect, not person years. Split it up between five or six
> people and its doable without danger of inducing madness. If a project
> did that, then the CCHIT charge for certification ought to be minimal,
> if anything at all.
> 
> Tim C
> 
> 
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> 
> .


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Tim.Churches]

Thomas Beale wrote:
> Rod Roark wrote:
>  >
>  >
>  > The point is, open source (as in Free Software) is NOT a business
>  > model.  It's a method and end result of collaboration among users.
>  > I make good money at it only because some of those users are willing
>  > to pay me to do the techie work for them.
> if someone is paying you something, then there is a business model. It's
> better to be aware of what it is than pretend that it isn't there
>  >
>  > I repeat: NOBODY will pay thousands for certification of Free
>  > Software.  They will use it because they already believe in it.
> If the accreditation process and procedures are transparent and do
> indeed show that anyone claiming to have an XYZ-compliant product really
> does have such, then it is in the interests of the users. Put yourself
> in the shoes of a purchaser (especially a health authority or
> government). Let's say you are interested in DICOM software. Let's say
> there are two products on the market that do what you want, but only one
> is certified. You find out about the certification process, you discover
> that the test cases are published as are the procedures for doing the
> certification. You know that the certified product correctly processes
> say 50 published test files, and does 65 other things described in the
> process. Finally, let's say that the prices are within 30% of each
> other. Which one do you buy?

Test files?In fact, there is no reason why automated test scripts
couldn't be used to demonstrate compliance with the criteria described
by CCHIT - see http://www.cchit.org/publiccomment4.htm - but I get the
feeling that those framing the criteria had human actors in mind with
respect to their test scripts. I might be wrong.

Either way, it would seem quite feasible for an open source project to
publish documentation of how it meets the certification criteria in the
documents on the above Web page. Tedious to compile such documentation,
but still only person-weeks (or at worst one- o r two-person months)of
work, I suspect, not person years. Split it up between five or six
people and its doable without danger of inducing madness. If a project
did that, then the CCHIT charge for certification ought to be minimal,
if anything at all.

Tim C


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Thomas Beale]

Rod Roark wrote:
>
>
> The point is, open source (as in Free Software) is NOT a business
> model.  It's a method and end result of collaboration among users.
> I make good money at it only because some of those users are willing
> to pay me to do the techie work for them.
if someone is paying you something, then there is a business model. It's 
better to be aware of what it is than pretend that it isn't there
>
> I repeat: NOBODY will pay thousands for certification of Free
> Software.  They will use it because they already believe in it.
If the accreditation process and procedures are transparent and do 
indeed show that anyone claiming to have an XYZ-compliant product really 
does have such, then it is in the interests of the users. Put yourself 
in the shoes of a purchaser (especially a health authority or 
government). Let's say you are interested in DICOM software. Let's say 
there are two products on the market that do what you want, but only one 
is certified. You find out about the certification process, you discover 
that the test cases are published as are the procedures for doing the 
certification. You know that the certified product correctly processes 
say 50 published test files, and does 65 other things described in the 
process. Finally, let's say that the prices are within 30% of each 
other. Which one do you buy?

- thomas beale



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

Tim.Churches wrote:
> 
> I think that the key question is: what does certification involve? How
> is it done? Is the $25000 certification fee required in order to employ
> a team of High Priests who use magical incantations and crystal balls to
> determine whether a particular software product should be certified, or
> is there an objective list of criteria which products must meet or
> fulfil? Hopefully the latter. Clearly these criteria should be

I think in CCHIT's case it's the latter.  They're very open about their 
criteria.  I haven't reviewed it all, but it seems reasonable.  I don't 
see how the fees can be gotten around in any case.  It's really a matter 
of a group's ability to financially absorb the cost.

Certification is not magic.  Real work that involves cost is involved to 
run tests and validate that an application conforms to specific 
standards.  There are legal implications by certification as well, which 
I would not want to take on as a certification body without a sizeable 
fee.  So, I would say $25,000 is quite reasonable.  They may have to 
raise the rate though.

Software certification in some form is already done, BTW, in the U.S. by 
JACHO.  It's just that the USE of a system in a healthcare organization 
is certified, but not the system itself.  So, CCHIT's program could 
lower the cost of JACHO compliance depending on the criteria.

For example, with OpenEMed, we're quickly running up against the 
requirement to demonstrate that the product running out of the box is 
HIPAA compliant.  CCHIT's costs can be cheaper to demonstrate that than 
going it alone.

Furthermore, I believe if a group is developing any kind of software for 
the ENTIRE health care market and they havent' figured out how to recoup 
enough money to cover CCHIT (or similar) certification, then perhaps the 
development effort isn't meant produce software to manage real health 
care data anyway.

I hate to be the antagonist on this point ... but the world doesn't 
expect to get open source software for $0 total investment. And health 
care Open Source development groups have a responsibility to ensure 
their work lives up to some standard.


> published, and publishers of medical software should be encouraged to
> document how their product meets these criteria. The cost of certifying
> a product for which its vendor/publisher has done all the hard work for
> the certifying agency by documenting how it meets the certification
> criteria should cost a lot less to have certified than system without
> such documentation. The vendor/publisher-provided certification
> documentation might comprise things like reference to design documents,
> automated tests to demonstrate compliance with certain prescribed or
> proscribed behaviours, or reference to the source code for the product.

You bring up a good point.  Certification of proprietary products is 
also probably more costly than an open source certification.

Just using documentation only though to certify products assumes that 
the documentation accurately and truthfully describes a product's 
compliance.  Defeats the purpose of an independent review, really.  This 
makes open source certification by a CCHIT-like organization that much 
more attractive to me as a developer.

> Now, one can see why vendors of proprietary medical software would not
> want to make such certification documentation publicly available - it
> would reveal a great deal to their competitors about the engineering of
> their product and would probably require access to source code and a
> working copy of the product in order to be useful anyway - neither of
> which would be publicly available - so there would be little point.

I will allow that it's possible to validate the functioning of a 
software product without looking at the source code, assuming there are 
no "hidden features."  But, certification of an open source product 
could set a higher standard, too.

> Obviously there is still a high cost to certification for proprietary
> vendors and open source projects alike, but at least with the model
> described above, or variations on it, those costs can be distributed
> across a community of users and developers, and the certification can
> evolve and be maintained alongside the open source software itself,
> rather than having to be redone from scratch by behind-doors certifiers
> for each new release or version.

I agree, but the cost needs to be collected and paid for somehow... and, 
  (deep breath) an official certification needs to be sought by some 
real entity with real money that can version lock a real product and 
manage a real release - not just a nebulous group who doesn't expect to 
get paid.

Certification is just one cost.  Constantly updating applications of any 
kind to meet changing regulations is another cost many open source 
developers don't take into account.  CCHIT, fees and all, can help 
communicate to the public where an open source project complies with 
go

Re: [openhealth] CCHIT biased towards proprietary software??

[Tim.Churches]

Fred Trotter wrote:
> The current CCHIT pricing module seems biased against any GPL based system.

Fred, you don't think that the CCHIT pricing is biased against software
released under other types of free, open source licenses?

> 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...
> 
> http://www.healthcareitnews.com/story.cms?id=4639
> 
> 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.

This is of interest because certification of medical and health software
is a debate which we are about to have here in Australia.

I think that the key question is: what does certification involve? How
is it done? Is the $25000 certification fee required in order to employ
a team of High Priests who use magical incantations and crystal balls to
determine whether a particular software product should be certified, or
is there an objective list of criteria which products must meet or
fulfil? Hopefully the latter. Clearly these criteria should be
published, and publishers of medical software should be encouraged to
document how their product meets these criteria. The cost of certifying
a product for which its vendor/publisher has done all the hard work for
the certifying agency by documenting how it meets the certification
criteria should cost a lot less to have certified than system without
such documentation. The vendor/publisher-provided certification
documentation might comprise things like reference to design documents,
automated tests to demonstrate compliance with certain prescribed or
proscribed behaviours, or reference to the source code for the product.

Now, one can see why vendors of proprietary medical software would not
want to make such certification documentation publicly available - it
would reveal a great deal to their competitors about the engineering of
their product and would probably require access to source code and a
working copy of the product in order to be useful anyway - neither of
which would be publicly available - so there would be little point.
Hence, the certification documentation would need to be checked in
secret by the certification authority or a trusted agent appointed or
engaged by it. Secrecy costs money, hence the proposed certification
charges.

But there are no such impediments to publication of the certification
documentation for open source health and medical software. Thus, in the
case of open source software, the certifying authority could just
require the publication of the certification documentation, and publicly
call for objections to it. If no objections are received, the
certification should be issued. This would be predicated on two (valid,
I think) assumptions: a) that there are extremely strong disincentives
for open source projects to cheat with respect to this certification
documentation; and b) competitors to an open source product have an
incentive to check the adequacy of the documentation and complain to the
certification authority if they can show that the certification criteria
are not met, or that the certification documentation is wrong in some way.

Obviously there is still a high cost to certification for proprietary
vendors and open source projects alike, but at least with the model
described above, or variations on it, those costs can be distributed
across a community of users and developers, and the certification can
evolve and be maintained alongside the open source software itself,
rather than having to be redone from scratch by behind-doors certifiers
for each new release or version.

And it is transparent. Transparency of certification and other quality
assurance mechanisms is crucial for all health and medical software, I feel.

> Free and Open Source EMR vendors are not the only one effected by this. This
> will target any small vendor, open source or otherwise. www.emrupdate.com is
> writing a group letter for the CCHIT feedback process which points this out.
> 
> http://www.emrupdate.com/forums/thread/46564.aspx
> 
> 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 

Re: [openhealth] CCHIT biased towards proprietary software??

[Rod Roark]

On Friday 24 March 2006 05:27 pm, Richard Schilling wrote:
> Rod Roark wrote:
...
> > Nobody is going to pay thousands of dollars for certification of
> > free software -- not to mention that such software by its nature will
> > be continually evolving and so quickly rendering any given
> > certification obsolete.
> 
> And why not? I'm not being flippant.  It's a serious question.  What's 
> wrong with doing that?  What's wrong with going to the expense to show 
> that your open source product meets the same quality controls as the big 
> vendor products?

It's not MY open source product.  It's not even a product.  See below
for more about that.  And I would not say that anyone would be "wrong"
for doing it.  I am just saying that nobody WILL do it.

> If open souce leads to a viable business model, the money will be there.

The point is, open source (as in Free Software) is NOT a business
model.  It's a method and end result of collaboration among users.
I make good money at it only because some of those users are willing
to pay me to do the techie work for them.

I repeat: NOBODY will pay thousands for certification of Free
Software.  They will use it because they already believe in it.

-- Rod
www.sunsetsystems.com


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

Rod Roark wrote:

> This is equivalent to ignoring the practical issues that Fred raised.

I disagree. The practical issues Fred raised are real concerns, but the 
software companies we're competing against throw a *lot* of money into 
validation and certification - especially HIPAA compliance (in the 
U.S.).  You may find that CCHIT's costs are insignficant in that light.

Perhaps the problem isn't the cost of any certification, but rather the 
lack of a solid business that is able to properly support open source 
development.

 > As an OpenEMR developer and supporter, there's no way that such a
 > model would do anything useful for me.

Well, if you're volunteering I think you have a point.  But, you might 
agree with me if your sole job were to develop OpenEMR as an open source 
product and you were being paid US$70,000 per year.

> Nobody is going to pay thousands of dollars for certification of
> free software -- not to mention that such software by its nature will
> be continually evolving and so quickly rendering any given
> certification obsolete.

And why not? I'm not being flippant.  It's a serious question.  What's 
wrong with doing that?  What's wrong with going to the expense to show 
that your open source product meets the same quality controls as the big 
vendor products?

If open souce leads to a viable business model, the money will be there.


Richard




> 
> -- Rod
> www.sunsetsystems.com
> 
> 
>  
> Yahoo! Groups Links
> 
> 
> 
>  
> 
> 
> 
> 



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Rod Roark]

On Friday 24 March 2006 04:48 pm, Richard Schilling wrote:
...
> I maintain open souce software is a path toward stimulated economies and 
> innovation ..  CCHIT doesn't owe anything to open source software 
> and shouldn't be required to lower their fees.  It's up to us to 
> demonstrate that open source solutions compete on all fronts.
...

I've been just lurking here for quite a while, but this assertion I
cannot ignore.

This is equivalent to ignoring the practical issues that Fred raised.
As an OpenEMR developer and supporter, there's no way that such a
model would do anything useful for me.

Nobody is going to pay thousands of dollars for certification of
free software -- not to mention that such software by its nature will
be continually evolving and so quickly rendering any given
certification obsolete.

-- Rod
www.sunsetsystems.com


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Richard Schilling]

I'd prefer to assume that the CCHIT pricing model is simply biased 
toward software companies that can produce a viable product.  And by 
that I mean a software product that stimulates revenue for a company at 
some point - which in our case is not through the sale of software licenses.

Nothing wrong with that bias.  CCHIT is obviously trying to stand as a 
self-contained, objective certification body.  It can't do that unless 
it charges fees.  It's up to people seeking a certification to determine 
if the investment into the certification will bring enough returns in 
the long run.

I maintain open souce software is a path toward stimulated economies and 
innovation ..  CCHIT doesn't owe anything to open source software 
and shouldn't be required to lower their fees.  It's up to us to 
demonstrate that open source solutions compete on all fronts.

As for "giving other companies an edge" if you release certified CCHIT 
software a open source, I maintain that risk can be managed.

CCHIT fees, whatever they are, get back to the question at hand: can an 
open source software company produce a viable healthcare product?


Richard


Fred Trotter wrote:
> 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...
> 
> http://www.healthcareitnews.com/story.cms?id=4639
> 
> 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. www.emrupdate.com is
> writing a group letter for the CCHIT feedback process which points this out.
> 
> http://www.emrupdate.com/forums/thread/46564.aspx
> 
> 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
> http://www.fredtrotter.com
> http://www.synseer.com
> phone: (480)290-8109
> email: [EMAIL PROTECTED]
> 
> 
> [Non-text portions of this message have been removed]
> 
> 
> 
>  
> Yahoo! Groups Links
> 
> 
> 
>  
> 
> 
> 



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Fred Trotter]

You are right we should not receive a "by" we do need to make concrete
suggestions as to how the same organization can accomplish open source
evaluations...

Here are the suggestions from emrupdate.com

>>emrupdate

   1. Markedly decrease your up-front fees and eliminate the percent
   royalties provisions. In most other certification arenas, the cost is
   usually ranges from about $150-$300 (Verisign-like certificates) to slightly
   over $1000 (Board certification for physicians). The government should pick
   up any shortfall in revenue since they stand to gain through future Medicare
   cost savings.
   2. Eliminate the "all or nothing" certification process. Consider a
   tiered certification process, s.a. "Gold", "Silver" and "Bronze".
   Alternatively, EMRs can be certified as having certain listed features,
   s.a. "150/328" features, allowing the buyer to know exactly what they
   are purchasing. EMRs should be verified that the EMR pricing is truthfully
   represented, eliminating the element of surprise in delivery of purchased
   goods and services.
   3. The certification features should be pared down to a dozen of the
   most important features, especially those features that deal with
   interoperability and the making of the CCR universal. All other
   features would be suggested, but optional.
   4. Self-testing should be reassessed. The EMR products should be
   independently tested for the items that are advertised. Consideration
   should be made for running speed and reliability. Does the software even
   work outside of the laboratory?
   5. Certify financial responsibility and exit strategy to make sure
   that no user will ever be at risk of losing his medical data due to lack of
   same.
   6. Vendors should not in any capacity be involved in the certification
   process as evaluators.
   7. This initiative introduces us to a slippery slope of arbitrary item
   inclusion, all of which should be removed or made optional. Today, that
   decision to include peds-specific content effectively removes those EMR's
   going after internal medicine, geriatric, adult endo, gastro, uro, and other
   specialty markets.
   8. CCHIT should define criteria for a lab interface so that every EMR
   did not need a separate interface for every lab vendor. We need to define a
   set a lab names/codes so that a CBC is a CBC on both coasts and in between.

< wrote:
>
> [I hope you don't mind if I copy this to Hardhats. I think it is a
> topic of interest to both communities.]
>
> I have mixed feelings here. It seems completely reasonable to want to
> have an accreditation/certification process for health information
> systems (though the jurisdiction issue is certainly a tricky one), but
> I believe you are right that the current model is problematic for open
> source software. The issue is controversial, but it doesn't seem right
> that open source software should essentially receive a "by" in this
> area. After all, such systems are used for the same types of safety
> critical applications as proprietary software. Sure, there is community
> review, but is tht really enough?
>
> What seems logical for is for some organization (perhaps OSHCA, but
> more likely an independent entity) to establish criteria for certifying
> open source systems. How would it all be funded? Good question. I don't
> think I really have any good answers, but one possibility is that
> vendors that support open source product suites would pay for
> accreditation (albeit using a different model and/or provcing
> criteria). Another possibility is to formalize the review process and
> make all relevant artifacts publicly available. The problem here, of
> course, is that there is no real incentive for an official agency to
> review (or audit) that process and provide accreditation for the
> software.
>
> Tough one.
>
> ===
> Gregory Woodhouse  <[EMAIL PROTECTED]>
>
> "It is foolish to answer a question that
> you do not understand."
> --G. Polya ("How to Solve It")
>
>
>
> Yahoo! Groups Links
>
>
>
>
>
>
>


--
Fred Trotter
SynSeer, Consultant
http://www.fredtrotter.com
http://www.synseer.com
phone: (480)290-8109
email: [EMAIL PROTECTED]


[Non-text portions of this message have been removed]



 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Joseph Dal Molin]

This is a US initiative...

[EMAIL PROTECTED] wrote:
>  >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...
>  >
>  >  http://www.healthcareitnews.com/story.cms?id=4639
>  >
> 
> I couldn't tell from your message or the article which jurisdiction is
> proposing this certification plan.
> 
> 
> 
> YAHOO! GROUPS LINKS
> 
> *  Visit your group "openhealth
>   " on the web.
>
> *  To unsubscribe from this group, send an email to:
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> 
> 
> .


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[Greg Woodhouse]

[I hope you don't mind if I copy this to Hardhats. I think it is a
topic of interest to both communities.]

I have mixed feelings here. It seems completely reasonable to want to
have an accreditation/certification process for health information
systems (though the jurisdiction issue is certainly a tricky one), but
I believe you are right that the current model is problematic for open
source software. The issue is controversial, but it doesn't seem right
that open source software should essentially receive a "by" in this
area. After all, such systems are used for the same types of safety
critical applications as proprietary software. Sure, there is community
review, but is tht really enough?

What seems logical for is for some organization (perhaps OSHCA, but
more likely an independent entity) to establish criteria for certifying
open source systems. How would it all be funded? Good question. I don't
think I really have any good answers, but one possibility is that
vendors that support open source product suites would pay for
accreditation (albeit using a different model and/or provcing
criteria). Another possibility is to formalize the review process and
make all relevant artifacts publicly available. The problem here, of
course, is that there is no real incentive for an official agency to
review (or audit) that process and provide accreditation for the
software.

Tough one.

===
Gregory Woodhouse  <[EMAIL PROTECTED]>

"It is foolish to answer a question that
you do not understand."
--G. Polya ("How to Solve It")


 
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Re: [openhealth] CCHIT biased towards proprietary software??

[syd]

>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...
>
>  http://www.healthcareitnews.com/story.cms?id=4639
>

I couldn't tell from your message or the article which jurisdiction is
proposing this certification plan.



 
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[openhealth] CCHIT biased towards proprietary software??

[Fred Trotter]

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...

http://www.healthcareitnews.com/story.cms?id=4639

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. www.emrupdate.com is
writing a group letter for the CCHIT feedback process which points this out.

http://www.emrupdate.com/forums/thread/46564.aspx

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
http://www.fredtrotter.com
http://www.synseer.com
phone: (480)290-8109
email: [EMAIL PROTECTED]


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