The KHIT Blog: Draft 2014 CEHRT Certification Testing Stds Issued

Monday, September 10, 2012

Draft 2014 CEHRT Certification Testing Stds Issued

2014 Edition Draft Test Procedures
The Office of the National Coordinator for Health Information Technology (ONC) has posted the first wave of draft Test Procedures and applicable test data files for the 2014 Edition EHR certification criteria. The Test Procedures, once finalized and approved by the National Coordinator, will be used for testing and certifying EHR technology under the ONC HIT Certification Program (formerly referred to as the Permanent Certification Program or PCP). The Test Procedures are being developed in collaboration with the National Institute of Standards and Technology (NIST).

I'm not seeing much new here, conceptually, at first blush. More "user acceptance testing." But, I will review all of the drafts when I get to the office. One fundamental example:

CPOE

This test evaluates the capability for a Complete EHR or EHR Module to enable a user to electronically record, change, and access the following order types, at a minimum:

(i) Medications;
(ii) Laboratory; and
(iii) Radiology/imaging.

The test procedure is not prescriptive about the method [emphasis mine] used to change an order. For example, changing an order does not require changing an existing instance of an order.

Change may be accomplished through discontinuing/canceling an existing order and entering a new order.

This test procedure is organized into three sections:

Record - evaluates the capability to electronically enter orders for medications, laboratory, and radiology/imaging within the EHR system

The Tester enters the ONC-supplied Test Data orders for medications, laboratory, and radiology/imaging

The Tester verifies that the orders are recorded in the EHR

Change - evaluates the capability for a user to electronically change entered orders for medications, laboratory, and radiology/imaging in the EHR

The Tester displays the entered orders for medications, laboratory, and radiology/imaging

Tester changes the medications, laboratory, and radiology/imaging orders

The Tester verifies that the changed orders are accurate and complete

Access - evaluates the capability to access and display the orders that have been previously entered into the EHR

The Tester displays the orders for medications, laboratory, and radiology/ imaging entered during the test

The Tester verifies that the displayed order data are accurate and complete

This is all yet again just about "functionality" in the "capability" sense. If it takes the tester 8 seconds or 80 minutes is irrelevant to certification here (that pesky "usability" thing). After reviewing all 10 pages of this draft cert procedure, I find nothing about grading "ease of use."

I also have to chuckle that they "give you the answers in advance," too (the supplied "test data") for each criterion. Gives me that recurrent Clinic Monkey Moment.

Public Review and Comment Process

The draft Test Procedures and applicable test data files are posted on the ONC website and made available for public review and comment. (If there is no test data link, test data are either not required or supplied by the vendor.) The first wave is posted below; additional waves will be added to this website on a weekly or bi-weekly basis until all have been posted. A two-week comment period will follow each wave [emphasis mine] throughout September and October 2012.

Comments and suggestions should be submitted to ONC.Certification@hhs.gov. All submissions should include "Test Procedure" in the subject line.

After draft Test Procedures have been through the public comment and review process, ONC will revise and finalize them. The final set of Test Procedures is expected to be available for use in testing and certification in early 2013.

That's a pretty small review and comment window. I would exhort everyone working in this area to review the drafts and make your opinions known.
___

"MEDKAZ"?

This is curious. Came my way via Twitter.

A "crowdsourcing" venture capital initiative.

Fuel $10,000 or more:
Any contribution of $10,000 receives: a featured listing on our Web site as a MedKaz Strategic Partner. This tells the world that you support our unique approach to making sure people control their “damn records!” Pick your support level: Silver - $10,000, Gold - $20,000, Platinum - $50,000. Open to corporations, other business organizations, non-profits and individuals.

Wow.
___

BOBBYG GETS A BIT OF HIT PRESS "INK"

Should HIE vendors follow HIPAA rules?

Patrick Ouellette, September 10, 2012

After posting a health information exchange (HIE) security best practices article last week, a reader posed an interesting question: Where do HIE vendors fit into the equation?...

...Bobby Gladd, senior meaningful use adoption support project coordinator and HIPAA staff resource for HealtHIE Nevada, thinks that the requirements need to be in line with what HIEs and healthcare providers have to deal with. He believes that the language in Sec. 13401 of the HITECH Act applies to vendors and they should obey security rules without HIEs requiring them to do so:

“(a) Application of Security Provisions. — Sections 164.308, 164.310, 164.312, and 164.316 of title 45, Code of Federal Regulations, shall apply to a business associate of a covered entity in the same manner that such sections apply to the covered entity. The additional requirements of this title that relate to security and that are made applicable with respect to covered entities shall also be applicable to such a business associate and shall be incorporated into the business associate agreement between the business associate and the covered entity.”

The wording in this section of the act certainly looks like it should apply to both vendors and HIEs. Gladd, as an HIE and EHR consultant, works with vendors all the time that don’t need to follow HIPAA rules by the book. He said that vendors have access to ePHI and should adhere to the same standards as HIEs, which don’t even store data. What if a vendor’s employee is unhappy with his job or wants to steal information? He said that while vendors aren’t the sole reason for data breaches, there should be HIPAA audits for these companies as well to reduce risk...

Thanks, Patrick. I would just add that a close read of my prior post shows that I support making all EHR vendors submit to 45 CFR 164.3, not simply HIE vendors.
___

INTERESTING TWITTER FIND TODAY

I just signed up with this site. Ran across it via a tweet. Maybe nothing will ever come of it. But, one the other hand, perhaps there will be some good EHR "usability" nuggets here and there.

Boxes and Arrows is devoted to the practice, innovation, and discussion of design; including graphic design, interaction design, information architecture and the design of business. Since 2001, it’s been a peer-written journal promoting contributors who want to provoke thinking, push limits, and teach a few things along the way.

If you’re interested in improving the way information architecture is done, if you find yourself sparking provocative conversation on interaction design topics in your spare time, and if you go out of your way to help everyone in your office think differently about everything from the design process to software, we want to work with you.

See their latest post "Designing Screens Using Cores and Paths. Designing from the inside out." It just might be that HIT interfaces are simply too necessarily cognitive-load heavy to lend themsleves wholly to principles appropriated from other business spaces. Dunno.

ONC USABILITY UPDATE

___

IT'S NATIONAL HEALTH IT WEEK!

www.healthitweek.org

I'd have liked to have been in DC this week. Lots of cool events going on. Hope I can get to catch a few of the online events. Our REC is not doing any local stuff in support of it. We dropped the ball on that, IMO.
___

Hashtag #VDTnow

Mostashari calls for vendors to add Blue Button quickly
September 11, 2012 | Mary Mosquera, Government Health IT

Farzad Mostashari, MD, the national health IT coordinator, has challenged vendors to make it easy for consumers by early 2013 to view, download and transmit to another party their health information in the form of a Blue Button feature.
The Office of the National Coordinator for Health IT has established a Twitter hashtag of #VDTnow for companies and organizations to post their commitment to establishing the feature.

Implementing the functionality for view, download and transmit (VDT) to a third party, “I think, is underappreciated for how significant that’s going to be to the concept of consumer-mediated health information exchange,” Mostashari said at a Sept. 10 ONC summit on consumer health IT...

___

More to come...

No comments:

Brave New Health

Commonwell Health Alliance

Another important read (pdf)

I love this kind of stuff. It sustains and humbles me. "As politicians, advertisers, salesmen, and propagandists for various political, economic, moral, religious, psychic, environmental, dietary, and artistic doctrinaire positions know only too well, fallible human minds are easily tricked, by clever verbiage... Common language—or at least, the English language—has an almost universal tendency to disguise epistemological statements by putting them into a grammatical form which suggests to the unwary an ontological statement. A major source of error in current probability theory arises from an unthinking failure to perceive this."

Quotes

"An economist is a person who sees something that works in practice and tries to figure out whether it will work in theory."

- J.D. Kleinke, medical economist
___

"The only person who enjoys change is a baby with a wet diaper."

"Every misspent dollar in our health care system is part of somebody's paycheck.

- Brent James, M.D., M.Stat

“We could do healthcare, at markedly higher quality, for everyone in this country, without rationing or denying anybody the care that they need, without having the government dictate how doctors practice or whether hospitals could expand, at half the cost we do it now.”

- Health Care Futurist Joe Flower

Most of the sciences, unlike parts of medical science, are not concerned with the impossible. There is not complementary and alternative physics, or chemistry, or biochemistry, or engineering. These disciplines compare their ideas against reality, and, if the ideas are found wanting, abandoned."

- Mark A. Crislip, MD

"Q: How much alcohol is too much?
A: More than your doctor drinks."

- a physician I once heard speak during a CME presentation

“Just because science doesn’t know everything, doesn’t mean you get to fill in the gaps with whatever fairy tale most appeals to you.”

- Dara O’Briain

'[I]t is one small step from using the computer for "helping" doctors to monitoring them, judging them, dictating to them what to do, and withdrawing payment for computer non-compliance. The use of computer data is a multi-edged sword. It can be used for the "good," facilitating diagnosis and treatment and making it more accurate and up-to-date, and for “evil,” invading privacy, inviting security breechs, and making decisions based on the opinions of remote authorities rather than those present at the patient-doctor encounter.'

- Richard Reece, MD

“[T]here ARE statistics which are non-political. Just because The Washington Post/Fox News reports the temperature is 75 degrees doesn’t mean it’s really snowing and sunscreen is a liberal/conservative plot. Even if you earn a living being ideological.”

- Michael L. Millenson

"It is a generally a fairly convincing argument that people shouldn’t have to be subsidized to undertake a change which is in their best interest.

The reconciliation seems to be that EHR is not supposed to make a doctor’s practice more efficient and higher quality. It is supposed to make the system of care more efficient and higher quality, which is not the same thing. Those of you who took calc recall that maximizing the total of variables is not achieved by maximizing any one variable and this is a perfect example of that.

Those of you have served in combat certainly noticed that too — if everyone works as a team the unit takes fewer casualties. If you try to save your own hide, you might, but at the expense of more casualties overall."

- Al Lewis

"There are two ideas to keep in mind about Bayesian reasoning and how we tend to mess it up. The first is that base rates matter, even in the presence of evidence about the case at hand. This is often not intuitively obvious. The second is that intuitive impressions of the diagnosticity of evidence are often exaggerated."

- Daniel Kahneman, "Thinking, Fast and Slow"

"Physicians apply advanced scientific knowledge, but they must do so without the favorable conditions that experimental scientists create for themselves. Multitasking is forced on physicians, often in chaotic environments and under severe time and resource constraints."

- Lawrence and Lincoln Weed, "Medicine in Denial"

"It’s time to stop the whining about Obama care and acknowledge we already have universal health care. We just pay for it in the stupidest way possible that ensures problems are that much more disastrous and complicated when they’re finally treated."

- Mark Hoofnagle, MD, PhD

"Every act of conscious learning requires the willingness to suffer an injury to one's self-esteem. That is why young children, before they are aware of their own self-importance, learn so easily."

- Thomas Szasz, MD
___

"Of course, one reason that process metrics* are so popular is that processes are much easier to define and measure than outcomes."

- The Skeptical Scalpel
___

"There is an “illusion of validity” for any random data point, a seductive sense that is colored by what we hope will be true. Mountains of pharmaceutical claims are often made from mere molehills of data."

- Danielle Ofri, MD
___

"Joy empowers people. It is a source of energy that enables people to hope and plan and change their lives for the better. Spend some time around someone who is relentlessly negative and how do you feel–drained, right? More and more research shows that joy is not something that just happens to you, like a bolt of lightening out of the blue. Joy is, instead, a habit to cultivate. Negative thinking and despair are the crabgrass of our souls–weeds that take root and spread, sometimes to all areas of life. Joy, in contrast, is a soul’s rose–hardy when cared for, able to put down roots over time and withstand disease and extremes. Like a rose, however, your joy can become blighted from neglect or harsh conditions. We all need to tend to our joy–to prune away the badness, and to know that, even though it may look like a prickly bare root, if you invest time in a joyous outlook, gorgeous things will bloom, even in the harshest conditions."

- Dr. Jan Gurley
___

"'Solutions' exist only in mathematics."

- Karen Martin
___

"The issue of how to regulate clinical software is, in the long run, indistinguishable from the issue of how to regulate medicine. The only difference is that medicine is practiced in the open, without secrecy, subject to peer review, and under a merit-based state license."

- Adrian Gropper, MD
___

"Economist, rope, tree: some assembly required."

- Source unknown

DISCLAIMER:

I write this blog wholly on my own time and my own dime. The views proffered are expressly my own as a concerned and active citizen/taxpayer (in addition to being the result of my substantive experience in the various IT fields), and in no way reflect any policy views of my former employer, notwithstanding that some of the thinking has indeed obviously been spurred by the implications of the work with which I have been doing for them.

FAIR USE POLICY
I cite a ton of news and web sources spanning the breadth of relevant technical and policy domains, sometimes at substantial length. I believe I remain well within the bounds of "Fair Use," as [1] I am not doing any of this for profit, [2] I always provide attribution and links -- which, [3] far from negatively impacting any copyright holders' commercial interests, might actually increase traffic to and interest in their offerings.

Nonetheless, should I post anything of yours regarding which you have any objection, just let me know and I will remove it forthwith.

The KHIT Blog

Search the KHIT Blog

Monday, September 10, 2012

Draft 2014 CEHRT Certification Testing Stds Issued

No comments:

Post a Comment