Re: [openhealth] CCHIT biased towards proprietary software??
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 * Visit your group openhealth http://groups.yahoo.com/group/openhealth on the web. * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] mailto:[EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to the Yahoo! Terms of Service http://docs.yahoo.com/info/terms/. . David H Chan, MD, CCFP, MSc, FCFP Associate Professor Department of Family Medicine McMaster University __ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 - - - - - - - - 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] Your use of Yahoo! Groups is subject to the Yahoo! Terms of Service. - - Talk is cheap. Use Yahoo! Messenger to make PC-to-Phone calls. Great rates starting at 1cent;/min. [Non-text portions of this message have been removed] Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 SPONSORED LINKS Software distribution Salon software Medical software Software association Software jewelry Software deployment - YAHOO! GROUPS LINKS Visit your group openhealth on the web. To unsubscribe from this group, send an email to: [EMAIL PROTECTED] Your use of Yahoo! Groups is subject to the Yahoo! Terms of Service. - - Yahoo! Messenger with Voice. Make PC-to-Phone Calls to the US (and 30+ countries) for 2¢/min or less. [Non-text portions of this message have been removed] Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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) Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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] Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 - - - - - - - - Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 http://groups.yahoo.com/group/openhealth on the web. * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] mailto:[EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to the Yahoo! Terms of Service http://docs.yahoo.com/info/terms/. . Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
[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 * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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 Yahoo! Groups Links * To visit your group on the web, go to: http://groups.yahoo.com/group/openhealth/ * To unsubscribe from this group, send an email to: [EMAIL PROTECTED] * Your use of Yahoo! Groups is subject to: http://docs.yahoo.com/info/terms/
Re: [openhealth] CCHIT biased towards proprietary software??
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