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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 22 Apr 2009 11:13:33 -0400
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>I understand your concerns, but this has been going on for quite
>sometime in the world of federal regulations. for example just look at the
>mandated use of ethanol in our fuel supply.
>
>In your opinion who should be establishing the requirements for
>certification. Yes the DOD requirements really only apply to products for
>use in the federal sector more specifically within DOD, but they have become
>the de facto requirements for better or for worse.


I'd prefer to see a more open process to establish the baseline for systems,
not one being directed by a limited number of firms paying for the
opportunity to select the tune everyone else has to dance to, or be forced
to sit out and watch... especially if what's being developed is also
collaboratively funded with Federal funds!

The difference with DOD 5015 was the requirements document was intended for
military applications ONLY to begin with and then as time went along (as you
correctly point out) it became a de facto standard (small 's' intended) that
others accepted, simply because there was none.

In this case, the requirements are non-existent and being developed for
managing medical records for the general public, but will also be used for
others such as the military, Federal employees, etc.   

So because this IS being developed chiefly for a commercial venture, I'd
prefer to see a consortium of companies collaboratively develop consensus
based Standards (with a capital 'S') that require a public review,
resolution of any negative ballots, and allow all players the ability of
participation in the process.

The greatest concerns I have for what's happening is finding a way to
eliminate all of the proprietary formats coming from medical devices and
equipment that don't allow for EDI (electronic data interchange) and don't
support the potential for long term access to information.  

I'd like to see the possibility for an open source alternative that all of
the parties involved are required to work with to allow for persistent
access to information generated from any/all devices and equipment which
will assist in ensuring all citizens will have a greater opportunity of
their medical information remaining available and accessible throughout
their lives.

There are opportunities for IEEE or ANSI or even ISO to engage with others
to collaboratively establish open, consensus based Standards for these
systems and it won't take any longer to develop them under these guidelines,
especially since all of these organizations have established processes and
procedures.  And the impetus is definitely there.

Larry
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