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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 14 Jul 2009 10:49:45 -0400
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> My sense is that the
>current legislative process is aimed at identifying standards for
>implementation, in particular, standards setting bodies (such as the
>CCHIT). This would make sense as one of the principle goals is data
>portability. 

Interestingly enough, after reviewing CCHIT's site again, I STILL don't see
anything that identifies then as an authorized standards setting body.  No
link to IEEE, ANSI, ASTM, ISO or any other Standards producing body.  Until
this happens, they're producing practices and procedures, NOT Standards.

http://www.cchit.org/about/organization

The only one that is accredited is HL7, and I even have to question how they
work

http://www.hl7.org/ehr/documents/faq.asp

Their activity has been sporadic since 2003-4, working on a limited number
of initiatives, with data interchange being one, but their most recent work
indicates members need to be in a 'paying status' to cast ballots, which is
completely against the principle of openness.  

http://www.hl7.org/ehr/documents/Documents.asp

In a recent past life, I spent many hours as both a committee member and
Chair involved in the development, writing and editing of Standards for a
certain association (which will remain nameless) and I'm still involved in
those efforts for another three organizations... but in all cases, they are
accredited Standards producing bodies.  

All of the work product and principles of development are based on achieving
consensus, working in an open environment, involvement of a balanced group
of participants, elimination of dominance by any party or interest group,
public balloting, and resolution of comments.

Unfortunately all of the work being done thus far in the field of
EMR/EHR/EHIT has been done in a closed environment, and most of it on a "pay
to play" basis, which essentially results in eliminating all but the largest
players and more of a Golden Rule than a standard, even one with a lower
case 's'.

This is a large part of the problem with how the ARRA (stimulus) funding is
setup- the requirement that any party receiving the funds be identified as a
"meaningful user" (MU), which includes many hospitals, but NOT many private
practices.  This requires any physician who wants to receive funding to be
associated with an identified MU, and these MUs are using this as a carrot
to attract physicians to align themselves with ONE (and only one) MU, which
is the stick that accompanies the carrot.

In addition, the funding is presently only planned to be available from 2011
until 2016, and projected costs to maintain an EMR/EHR system  post
implementation are staggering. http://shrinkster.com/17ql   And this doesn't
include any of the long-term issues of conversion, migration, access
controls, or other known issues related to electronic format records.

ONCE AGAIN, I'll say I'm not throwing cold water on the adoption of EMR/EHR,
but I am STILL suggesting that the process is slowed down until meaningful
Standards for capture, control, management, persistent access, data
protection, and an elimination of proprietary formats for content can be
developed.

Larry
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