r3gllc wrote on Tuesday, May 08, 2012:
I understand your frustration . I think this is probably from your experience in getting ONC certification - correct?
But, in my opinion these rules are much better compared to the ONC EMR certification… .As rightly mentioned by John - “The regulation strikes an interesting balance - how to encourage innovation while also requiring accountability for errors that result from software or hardware defects”
I have interacted with several people globally and have been in the data interface industry for a while - With that experience, in my humble opinion, the FDA rules are common place (similar rules are there in all developed countries, in-fact in europe they are worse, they have one set for each country and then one for EU), while compared to that the ONC certification rules were just “artificial rules, invented by the big vendors” to stop small vendors and any and all opensource penetration in EMR market (remember the first version of the CCHIT certification). …I really feel sorry that some of the greatest opensource healthinformatics ideas, which are conceived in our(US) universities cannot be implemented in US due to this “artificial, unnecessary certification criteria” … but that is a different topic and the boat on that had already sailed …
Coming back to the FDA rule - Yes, the FDA cert might be required for this interfaces but that is very similar to so many other industrial automation systems and most of them gets that from the federal agency as long as they stick with some type of standards such as the open OPC standard for industrial automation …
I really don’t want to stifle your innovation with this information, as what you are trying to do is a great effort and one of the very important one in the healthcare/ medical - infact, in the 2011 Scientific american among the 10 world changing ideas the first one was a "a list of forever health monitor " that interacts with medical devices - It is predicted that, these “always on” MDDS systems may reduce 75% of healthcare spending for chronic disease mgmt and extend life expectancy …
So, I think, as long as you stick with the open standards you should be okay, if FDA cert is required … worst case situation, FDA can stop your interface in US, but other parts of the world can still use it (or at-least get the idea to move forward)