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	<title>Comments on: Towards fair EHR certification</title>
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	<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/</link>
	<description>Hacktivist, coding for social change</description>
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		<title>By: Justin Wilcox</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5215</link>
		<dc:creator>Justin Wilcox</dc:creator>
		<pubDate>Sat, 18 Apr 2009 23:49:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5215</guid>
		<description>Thanks for the great write-up, Fred.  Your comment on AMA’s copyright of CPT codes especially caught my attention.  

As the co-founder of a company building medical coding tools, I am extremely frustrated by the combination of AMA’s copyright on the CPT code set and CMS’s requirement that primary health organizations indirectly purchase multiple copies of an AMA licenses.

This environment clearly stifles to innovation, especially as new high quality &amp; low cost products come to market.  The fact that every system a provider uses that leverages CPT codes must pay a licensing fee (EMR + encoder + billing services = $25 x 3/user/year) means that providers are paying multiple times for precisely the same information.  

I would like to help raise awareness of this issue, be a part of a coalition to address it, and eventually see an equitable system put in place.  Do you know of any efforts to address this issue that I and my organization might be able to contribute our time &amp; voice to?  If not, where would you suggest someone start to build a coalition of interested parties?

Thank you for your time and all of your efforts.</description>
		<content:encoded><![CDATA[<p>Thanks for the great write-up, Fred.  Your comment on AMA’s copyright of CPT codes especially caught my attention.  </p>
<p>As the co-founder of a company building medical coding tools, I am extremely frustrated by the combination of AMA’s copyright on the CPT code set and CMS’s requirement that primary health organizations indirectly purchase multiple copies of an AMA licenses.</p>
<p>This environment clearly stifles to innovation, especially as new high quality &#038; low cost products come to market.  The fact that every system a provider uses that leverages CPT codes must pay a licensing fee (EMR + encoder + billing services = $25 x 3/user/year) means that providers are paying multiple times for precisely the same information.  </p>
<p>I would like to help raise awareness of this issue, be a part of a coalition to address it, and eventually see an equitable system put in place.  Do you know of any efforts to address this issue that I and my organization might be able to contribute our time &#038; voice to?  If not, where would you suggest someone start to build a coalition of interested parties?</p>
<p>Thank you for your time and all of your efforts.</p>
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		<title>By: Open Source Prospect in Healthcare Industry &#124; Intermatik Blog</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5210</link>
		<dc:creator>Open Source Prospect in Healthcare Industry &#124; Intermatik Blog</dc:creator>
		<pubDate>Thu, 16 Apr 2009 02:07:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5210</guid>
		<description>[...] solutions in healthcare, but getting policies in place hasn&#8217;t been easy. Open source advocate Fred Trotter was prepared to do battle when he met recently with representatives of the Certification Commission [...]</description>
		<content:encoded><![CDATA[<p>[...] solutions in healthcare, but getting policies in place hasn&#8217;t been easy. Open source advocate Fred Trotter was prepared to do battle when he met recently with representatives of the Certification Commission [...]</p>
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		<title>By: A Healthy Regard For FOSS &#124; Innovativ Insight</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5208</link>
		<dc:creator>A Healthy Regard For FOSS &#124; Innovativ Insight</dc:creator>
		<pubDate>Tue, 14 Apr 2009 16:49:10 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5208</guid>
		<description>[...] Trotter writes about open source software and medicine, and recently blogged about a meeting he had with the CCHIT regarding their support for open source in their certification program. It&#039;s [...]</description>
		<content:encoded><![CDATA[<p>[...] Trotter writes about open source software and medicine, and recently blogged about a meeting he had with the CCHIT regarding their support for open source in their certification program. It&#8217;s [...]</p>
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		<title>By: Wayne Wilson</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5206</link>
		<dc:creator>Wayne Wilson</dc:creator>
		<pubDate>Tue, 14 Apr 2009 12:15:56 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5206</guid>
		<description>&lt;a href=&quot;#comment-5201&quot; rel=&quot;nofollow&quot;&gt;@Lorie&lt;/a&gt; 
Self certification is a model that a few vendors follow, like VMWare, but it is not really successful without a support organization.  So what you really need in FOSS is an organization that will promise to make the software compliant (a support organization) to the certification objectives (Of course the real objective is to make the software functional to the end users and perhaps somewhat inter-operable with other software that also claims to be functional - one would hope that if one could achieve such functionality and inter-operability, one would also have no problems being certified and thus self-certification is a reasonable approach).</description>
		<content:encoded><![CDATA[<p><a href="#comment-5201" rel="nofollow">@Lorie</a><br />
Self certification is a model that a few vendors follow, like VMWare, but it is not really successful without a support organization.  So what you really need in FOSS is an organization that will promise to make the software compliant (a support organization) to the certification objectives (Of course the real objective is to make the software functional to the end users and perhaps somewhat inter-operable with other software that also claims to be functional &#8211; one would hope that if one could achieve such functionality and inter-operability, one would also have no problems being certified and thus self-certification is a reasonable approach).</p>
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		<title>By: Open Source in Healthcare IT Takes a Baby Step &#124; google android os blog</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5204</link>
		<dc:creator>Open Source in Healthcare IT Takes a Baby Step &#124; google android os blog</dc:creator>
		<pubDate>Tue, 14 Apr 2009 10:24:36 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5204</guid>
		<description>[...] solutions in healthcare, but getting policies in place hasn&#8217;t been easy. Open source advocate Fred Trotter was prepared to do battle when he met recently with representatives of the Certification Commission [...]</description>
		<content:encoded><![CDATA[<p>[...] solutions in healthcare, but getting policies in place hasn&#8217;t been easy. Open source advocate Fred Trotter was prepared to do battle when he met recently with representatives of the Certification Commission [...]</p>
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		<title>By: Lorie</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5201</link>
		<dc:creator>Lorie</dc:creator>
		<pubDate>Mon, 13 Apr 2009 17:36:20 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5201</guid>
		<description>&lt;a href=&quot;#comment-5195&quot; rel=&quot;nofollow&quot;&gt;@Tim Cook&lt;/a&gt; 

Along the lines of self-testing suggested by Tim, shouldn&#039;t the Laika project be useful as a standardized tool for certification testing? Perhaps that or something like it could be used for a truly open testing model for verification and validation of EHR testing.

http://laika.sourceforge.net/

-Lorie</description>
		<content:encoded><![CDATA[<p><a href="#comment-5195" rel="nofollow">@Tim Cook</a> </p>
<p>Along the lines of self-testing suggested by Tim, shouldn&#8217;t the Laika project be useful as a standardized tool for certification testing? Perhaps that or something like it could be used for a truly open testing model for verification and validation of EHR testing.</p>
<p><a href="http://laika.sourceforge.net/" rel="nofollow">http://laika.sourceforge.net/</a></p>
<p>-Lorie</p>
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		<title>By: KeithS</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5200</link>
		<dc:creator>KeithS</dc:creator>
		<pubDate>Mon, 13 Apr 2009 17:10:13 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5200</guid>
		<description>logistical question:  This meeting with CCHIT was a very good beginning.  What are we doing to facilitate (formalize?) on-going communications between CCHIT staff and the FOSS community?  Are they subscribing to the appropriate mailing lists or RSS feeds or online asynchronous discussion forums?  Are they aware of these and how to access them?  Will additional synchronous (real-time) discussions  like face-2-face or teleconferences be scheduled?  How do we ensure they learn more about FOSS HIT and it&#039;s concerns, as they admitted they needed to do, and desired to do?  

-keith</description>
		<content:encoded><![CDATA[<p>logistical question:  This meeting with CCHIT was a very good beginning.  What are we doing to facilitate (formalize?) on-going communications between CCHIT staff and the FOSS community?  Are they subscribing to the appropriate mailing lists or RSS feeds or online asynchronous discussion forums?  Are they aware of these and how to access them?  Will additional synchronous (real-time) discussions  like face-2-face or teleconferences be scheduled?  How do we ensure they learn more about FOSS HIT and it&#8217;s concerns, as they admitted they needed to do, and desired to do?  </p>
<p>-keith</p>
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		<title>By: Wayne Wilson</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5198</link>
		<dc:creator>Wayne Wilson</dc:creator>
		<pubDate>Mon, 13 Apr 2009 13:59:14 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5198</guid>
		<description>Fred, your discussion of certification in FOSS mostly fall into the business case sphere.  I would find it interesting for the &#039;need&#039; for certification to also be analyzed.  From the CCHIT&#039;s web site, an Introduction ... http://ehrdecisions.com/2009/01/14/an-introduction-to-health-it-certification/, it is stated that certification is necessary to deliver on the benefits of electronic health records.  Furthermore it is stated that the certification entity is the &#039;trusted advocate for the physician community&quot;.

The close linkages between standards bodies and certifications lead to me to believe that certification has other, business objectives as well that are not explicity stated.

It&#039;s all well and good to declare oneself the protector of all things good but the kind of top down spread of assertions is something that FOSS has always had a problem with.  The very phenomena of &#039;forking&#039;, which has a long cultural history outside of software, especially among societies which value freedom, is more of a bottom up to the middle and then out to side reaction against the inevitable rigidity of top down organization!

FOSS software is, at it&#039;s best, the small upstart business, which exists as a viable niche because of the failures of the larger and more rigid software industry.  

So, to the extent that certification does have a business model, and uses money to create a &#039;trade association&#039; of the status quo, there will always be a tension between FOSS and certification.</description>
		<content:encoded><![CDATA[<p>Fred, your discussion of certification in FOSS mostly fall into the business case sphere.  I would find it interesting for the &#8216;need&#8217; for certification to also be analyzed.  From the CCHIT&#8217;s web site, an Introduction &#8230; <a href="http://ehrdecisions.com/2009/01/14/an-introduction-to-health-it-certification/" rel="nofollow">http://ehrdecisions.com/2009/01/14/an-introduction-to-health-it-certification/</a>, it is stated that certification is necessary to deliver on the benefits of electronic health records.  Furthermore it is stated that the certification entity is the &#8216;trusted advocate for the physician community&#8221;.</p>
<p>The close linkages between standards bodies and certifications lead to me to believe that certification has other, business objectives as well that are not explicity stated.</p>
<p>It&#8217;s all well and good to declare oneself the protector of all things good but the kind of top down spread of assertions is something that FOSS has always had a problem with.  The very phenomena of &#8216;forking&#8217;, which has a long cultural history outside of software, especially among societies which value freedom, is more of a bottom up to the middle and then out to side reaction against the inevitable rigidity of top down organization!</p>
<p>FOSS software is, at it&#8217;s best, the small upstart business, which exists as a viable niche because of the failures of the larger and more rigid software industry.  </p>
<p>So, to the extent that certification does have a business model, and uses money to create a &#8216;trade association&#8217; of the status quo, there will always be a tension between FOSS and certification.</p>
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		<title>By: Tim Cook</title>
		<link>http://www.fredtrotter.com/2009/04/11/towards-fair-ehr-certification/comment-page-1/#comment-5195</link>
		<dc:creator>Tim Cook</dc:creator>
		<pubDate>Mon, 13 Apr 2009 00:50:58 +0000</pubDate>
		<guid isPermaLink="false">http://www.fredtrotter.com/?p=124#comment-5195</guid>
		<description>Hmmmm,
I&#039;m still not certain what the &quot;FOSS community&quot; that you are speaking of really wants.  Due to the nature (as you well describe above) of FOSS development; and the fact that the scripts and requirements from CCHIT are publicly available.  Then why isn&#039;t it sufficient (and in fact natural) for the MyFOSSEMR&quot; community to do their own testing using the CCHIT protocols (isn&#039;t this kind of like unit/functional testing anyway?) and then individuals/companies can run these tests and certify themselves.

This PROVES the validity of the FOSS process.  

There will be those that claim self-certification via CCHIT but they won&#039;t last long.  They will easily be discovered through functionality defects and lack of interoperability.  Their lack of integrity will be well noted in blogs and on mailing lists. 

Maybe the one thing that CCHIT attorney&#039;s could do is draft a provision for self-certification that will give the individual/company the right to claim that they have self-certified but they they can be held liable to customers and maybe even patients?

This is starting to sound better as I think out loud here.  The FOSS application is available, the test scripts are available.  The potential customer can do their own verification on all or selected sections of the application.

Let the big commercial vendors spend their money on the CCHIT seal. Small and FOSS vendors can self-certify and put their integrity where the mouth is.

--Tim</description>
		<content:encoded><![CDATA[<p>Hmmmm,<br />
I&#8217;m still not certain what the &#8220;FOSS community&#8221; that you are speaking of really wants.  Due to the nature (as you well describe above) of FOSS development; and the fact that the scripts and requirements from CCHIT are publicly available.  Then why isn&#8217;t it sufficient (and in fact natural) for the MyFOSSEMR&#8221; community to do their own testing using the CCHIT protocols (isn&#8217;t this kind of like unit/functional testing anyway?) and then individuals/companies can run these tests and certify themselves.</p>
<p>This PROVES the validity of the FOSS process.  </p>
<p>There will be those that claim self-certification via CCHIT but they won&#8217;t last long.  They will easily be discovered through functionality defects and lack of interoperability.  Their lack of integrity will be well noted in blogs and on mailing lists. </p>
<p>Maybe the one thing that CCHIT attorney&#8217;s could do is draft a provision for self-certification that will give the individual/company the right to claim that they have self-certified but they they can be held liable to customers and maybe even patients?</p>
<p>This is starting to sound better as I think out loud here.  The FOSS application is available, the test scripts are available.  The potential customer can do their own verification on all or selected sections of the application.</p>
<p>Let the big commercial vendors spend their money on the CCHIT seal. Small and FOSS vendors can self-certify and put their integrity where the mouth is.</p>
<p>&#8211;Tim</p>
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