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

2006-03-30 Thread 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
  
 


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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??

2006-03-28 Thread 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??

2006-03-28 Thread 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??

2006-03-28 Thread 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: openhealth@yahoogroups.com
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??

2006-03-28 Thread 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??

2006-03-28 Thread 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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  Sir Tim Berners-Lee
 
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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-28 Thread 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??

2006-03-27 Thread 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??

2006-03-27 Thread 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??

2006-03-27 Thread 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??

2006-03-27 Thread 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??

2006-03-27 Thread 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??

2006-03-27 Thread 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
 
 - - - - - - - -
 
 
 
 
 
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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-27 Thread 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??

2006-03-27 Thread 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??

2006-03-27 Thread 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??

2006-03-25 Thread 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??

2006-03-25 Thread 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??

2006-03-25 Thread 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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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-25 Thread 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]


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

2006-03-25 Thread 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??

2006-03-25 Thread 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??

2006-03-25 Thread 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??

2006-03-25 Thread 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??

2006-03-25 Thread 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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[openhealth] CCHIT biased towards proprietary software??

2006-03-24 Thread 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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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-24 Thread 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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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-24 Thread 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.
 
 
 
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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-24 Thread 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??

2006-03-24 Thread 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.

emrupdate

If you agree with these then you should sign there letter.

So here is what I would propose regarding FOSS software.

1. Reduce by 90% the costs associated for certifying any product that is
published under an Open Source (as defined by OSI) or Free Software License
(As defined by the Free Software Foundation). Software released under these
licenses contribute directly to the public good, unlike proprietary
software. Since there is no profiting party like a proprietary software
company, there is no source of funds from which to pay the standard fees.

2. Instead of certifying software alone, vendors-software pairs should be
certified. So B-Mas supporting FreeMED would be a Open Source CCHIT
certified instead of just FreeMED. That encourages B-Mas to pay the fees,
and gives them specific benifits once those fees are payed. Also it means
that the same software can be certfied by different vendors several times.
This benifits projects with multiple vendors, like VistA and
MirrorMed/ClearHealth. It gives us a way to pool resources as a community to
get multiple certifications that benifit individual vendors but does not
break the bank for each vendor. This also serves to supply the cash needed
for the CCHIT process (which is very person intensive).

Does this sound like a reasonable proposal? If it does then I will write a
formal version and then request signatures

-FT






On 3/24/06, Greg Woodhouse [EMAIL PROTECTED] 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 

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

2006-03-24 Thread 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]
 
 
 
  
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Re: [openhealth] CCHIT biased towards proprietary software??

2006-03-24 Thread 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??

2006-03-24 Thread 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




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

2006-03-24 Thread 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??

2006-03-24 Thread 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 reviewed,
 that some of the 

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

2006-03-24 Thread 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 
government regulations.

Richard