Openemr Vs ONC NIST Testing

bradymiller wrote on Wednesday, December 01, 2010:

hey,
Put Visolve’s above patch into a github branch here (for those of you now dependent on git):
https://github.com/bradymiller/openemr/commits/visolve-eth-rac_1
-brady

bradymiller wrote on Thursday, December 02, 2010:

hey,
Put a review on the github commit here:
http://github.com/bradymiller/openemr/commit/702aaaa2673dae5f5ccd516d48ae375e142a3b3d
-brady

bradymiller wrote on Friday, December 03, 2010:

Visolve,

I reworked your Problem List and Allergy patch (also cleaned up the problem list screen a bit). Posted the patch in your tracker:
http://sourceforge.net/tracker/index.php?func=detail&aid=3082117&group_id=60081&atid=1245239#
And the github branch is here:
https://github.com/bradymiller/openemr/tree/prob-all-brady_1

I think this should pass NIST; let me know your thoughts.

-brady

visolveemr wrote on Saturday, December 04, 2010:

Hi Brady,

We have posted replies for your comments on race and ethnicity patch in the github branch
http://github.com/bradymiller/openemr/commit/702aaaa2673dae5f5ccd516d48ae375e142a3b3d

We also tested the modified problem list and medication allergy patch. We did not find any issues against NIST procedures.

Thanks,
Vicareplus Team,
services@vicareplus.com

bradymiller wrote on Saturday, December 04, 2010:

hey,

Thanks. We’re on a roll. I just committed the modified problem list and medication allergy patch to sourceforge:
http://openemr.git.sourceforge.net/git/gitweb.cgi?p=openemr/openemr;a=commitdiff;h=fc729f4b5b8e174ae369d66a1814f88a06241957

I’ll await the revised (just some minor issues) race/ethnicity patch.
-brady

stephen-smith wrote on Sunday, December 05, 2010:

I just updated the wiki that “Maintain up-to-date problem list” and “Maintain active medication allergy list” need retesting, but should be fixed in master.

stephen-smith wrote on Sunday, December 05, 2010:

Looks like we may have already fixed the Audit Log issue as well; The 4.0 demo currently allows me to sort by patient id.  I’ll mark it as needed retesting on the wiki.

stephen-smith wrote on Sunday, December 05, 2010:

I was reviewing existing certified products and I found that some of the Modular EHR products that are certified actually satisfy very few of the criteria.  My two main examples are McKesson - Horizon Meds Manager and Midwest Software, LLC - Chiro QuickCharts.  There only intersection in features are either things OpenEMR already handles or things that were recently fixed.  Because of this, I think current 4.0 development could be certified as a Modular EHR.

Being able to say your product or service is certified by ONC is becoming a very important issue.  As such, I think it might be time to really push for a 4.0 release so that it can be submitted for testing by an ATCB.  Also, a funding drive for the testing costs should probably be started.

Brady and Rod (in particular), what are the main issues that must be resolved before we can do a 4.0 release?  All (or at least most) of the remaining NIST / HHS / ONC / MU criteria can be pushed to a later release.  In theory, it might be possible to submit a snapshot (identified by a Git commit SHA contained in master) for testing, but I think it would be better for it to be an official release.

Is there some good way to pool any monetary resources and accept public donations for the monetary costs associated with testing?  I think I read on the wiki that 19.5k USD needs to be available.

There is some documentation that still need to be written and provided to whatever ATCB performs the testing.  Would it be best to organize this on the wiki or in Git as part of the 4.0 manual?  ViCare+'s test results do provide some of this.

bradymiller wrote on Sunday, December 05, 2010:

hey,

Anybody gonna shell out the cash for Modular EHR? And then out again for Complete EHR? Tony, can you make sure Stephen is plugged into the MU effort via email and the conference calls.

There are lots of bugs to fix in the tracker. The ones within The Group: Release 4.0 are especially high priority before a release. Also, need a manual. Many resources (including mine) are focusing in on MU requirements, so the bugs and manual not getting much attention.

Development is moving pretty fast, so if we freeze code it will quickly become outdated feature-wise (not a bad thing, just don’t want to prematurely pull the trigger if there’s no funding commitment and paperwork commitment towards Modular EHR anyways).

-brady

jcahn2 wrote on Monday, December 06, 2010:

Ahoy Brady,

It is possible that there are a large number of United States physicians who are potential users (=vendor’s clients) for OpenEMR who are only waiting for a certification status.  There is no way to count this number, but in my bones, I feel there are many.  These docs also need to make a software choice now in order to get up and running in time to qualify for HITECH money  for the 2011 year.  “Now” means in the very near future, probably will decide on which software before the end of this year or very early 2011. 

It is admirable for the project to strive for certification as a Complete EMR.  Will it matter if that milestone is attained 6 months from now or a year from now, if a large number of users could be signed up now with a Modular EMR?  Feature development would continue and vendors will update the code in use so that their docs could use the new features as a part of their MU requirements.  (Docs must do more than just use a certified EMR to get their HITECH money.)  I am not clear if each physician requirement must be accomplished with a certified part of an EMR to qualify.  Does anyone have clarification as to the interpretation of MU here?

Would docs be willing to pay $100/year or $200/year to use a certified EMR?  All I can say is the commercial guys are running about 5-10x that amount without batting an eye.  200 new docs would pay the certification bill.

# Uncomment as appropriate.  Default is “The train is leaving the station”
# $warning=The clock is ticking;
# $warning=The train is leaving the station;
# $warning=The sharks are circling;
# $warning=A stitch in time saves nine;

Thanks again,                Jack Cahn MD

aperezcrespo wrote on Monday, December 06, 2010:

Hi folks,
   Well we setup a booth at the local medical convention.  3000 doctors attended the convention.  Nearly all those that approached the booth asked the same question first,  Is it certified?   Second only to “Really for free?”.  The only way we obtained new clients was by raffling installation services.
And yes you are correct about the commercial software vendors,  doctors are signing up as long as it is certified (modular or complete) something we experienced first hand at the convention.  They were signing up with software inferior to OpenEMR, but it was certified.

For 2010 (90 day use) and 2011 (365 day use) providers only need to submit via attestation the use of a certified EHR.  Providers will be audited once the infrastructure is in place.  And if they (knowingly or not) summited for incentives with uncertified technology it will be considered fraud. 

There are other aspects of MU which have nothing to do with EHR.  For example Security Risk Assessment, (a service which we now provide)  of which only a portion is Information Technology related.

So keep in mind that a Certified EHR is only part of it but it is the primary part.

Alfonso

bradymiller wrote on Monday, December 06, 2010:

hey,
If somebody(or a group) committed money/time to apply for Modular EMR, I’d support rushing out a release (besides some minor bugs, codebase is stable), which could be done in a matter of days (the release would unlikely contain all the thrills such as full internationalization or package deployment (ubuntu package and appliance), but these deficiencies would be worth acquiring “certification”. Just let us know when somebody (or some group) steps up. So, to clarify, the issue of releasing 4.0 is not the bottleneck in acquiring certification.
-brady

jjcanales wrote on Monday, December 06, 2010:

Brady, Thanks for the clarification.  Does anyone know the actual cost of applying for Modular EMR certification?

-Joe

jjcanales wrote on Monday, December 06, 2010:

Ok, answered my own questions. It looks like the “Full Certification” cost is $34,300, but the “Module Certification”  cost depends on how many modules are certified. I included the pdf for the pricing structure and the certification details from CCHIT website below:
Full pricing documentation can be found here: http://www.cchit.org/sites/all/files/Pricing-ONC-ATCB-2011-2012.pdf
ONC-ATCB Certification details can be found here: http://www.cchit.org/get_certified/ONC-ATCB-Certified-2011-2012

Standard Certification Fees (due with application)
Eligible Provider Complete EHR $34,300
EHR Module  Criteria Fees
Fees are based on the number and complexity of ONC/HHS criteria tested.  See chart.
  Base fee, includes mandatory security criteria  $7,000
Criteria fee for complexity 1 $650
  Criteria fee for complexity 2 $950
Criteria fee for complexity 3 $1,250
Criteria fee for complexity 4 $1,500
Criteria fee for complexity 5 $2,000

tmccormi wrote on Monday, December 06, 2010:

I can be had less expensively from other certification bodies.    Remember, it’s not just the cost to the certification body, someone needs to be the point of contact and do the tests as the official representative of OpenEMR.  And OEMR.ORG will have manage the certification tracking, and other minor expenses. 

Good to see the interest level finally picking up.  We’ve been pounding on this for a year now.

-Tony

stephen-smith wrote on Monday, December 06, 2010:

bradymiller
Anybody gonna shell out the cash for Modular EHR? And then out again for Complete EHR? Tony, can you make sure Stephen is plugged into the MU effort via email and the conference calls.

Firstly, going for Complete EHR certification will take quite a while for the project to achieve at the current pace.  Secondly, for many users, “What features?” is only a useful question after the answer to “Is it ONC Certified?” is “Yes.”.  Finally, given the current HHS roadmap, there will be a new final rule around July 2012 and everyone will have to get certified again, so it’s not like certification cots were ever a one-time deal.

bradymiller
If somebody(or a group) committed money/time to apply for Modular EMR, I’d support rushing out a release (besides some minor bugs, codebase is stable), which could be done in a matter of days (the release would unlikely contain all the thrills such as full internationalization or package deployment (ubuntu package and appliance), but these deficiencies would be worth acquiring “certification”. Just let us know when somebody (or some group) steps up. So, to clarify, the issue of releasing 4.0 is not the bottleneck in acquiring certification.

That’s completely fair.  It’s good to know we are flexible on that.  Tony, is the current funding situation correct on the wiki?  Something like 1.6k USD raised and we don’t really know exactly how much it will cost?

bradymiller
It looks like the “Full Certification” cost is $34,300, but the “Module Certification”  cost depends on how many modules are certified. I included the pdf for the pricing structure and the certification details from CCHIT website below:

That’s from CCHIT.  There are at least two other ATCBs that can provide ONC certification.  I think the Drummond Group was the least expensive alternative so far.  It’s also possible to become a ATCB by going through a separate ONC process, so it might be that some organization reading this might become an ATCB both to certify OpenEMR and as an alternative revenue stream.

tmccormi
And OEMR.ORG will have manage the certification tracking, and other minor expenses.

Oemr.org seems to be owned by Rod:

$ whois oemr.org
...
Domain Name:OEMR.ORG
Created On:09-Apr-2005 00:43:36 UTC
Last Updated On:09-Apr-2010 01:22:36 UTC
Expiration Date:09-Apr-2011 00:43:36 UTC
Sponsoring Registrar:TierraNet Inc. dba DomainDiscover (R86-LROR)
Status:CLIENT TRANSFER PROHIBITED
Registrant ID:TNTN-0000371515
Registrant Name:Roark, Rod

I thought openmedsoftware.org would be handling this:

$ whois oemr.org
...
Domain Name:OPENMEDSOFTWARE.ORG
Created On:17-Mar-2005 20:31:13 UTC
Last Updated On:30-Dec-2009 16:38:32 UTC
Expiration Date:17-Mar-2013 20:31:13 UTC
Sponsoring Registrar:Network Solutions LLC (R63-LROR)
Status:CLIENT TRANSFER PROHIBITED
Registrant ID:39241373-NSI
Registrant Name:Open Source Medical Software

I don’t really care who takes point in getting OpenEMR certified as long as they publish the certification results.  At that point everyone can benefit from the certification.  According to the wiki the 501(C)3 most closely associated with the OpenEMR codebase is the owner of openmedsoftware.org

BTW, does anyone have any comments / critiques of my changes to the NIST testing status page?  I think I preserved all the information and the reformat makes it easier for me to see what criteria we currently meet or are working on.

stephen-smith wrote on Monday, December 06, 2010:

/me really wishes this forum had a preview and/or edit ability.

bradymiller wrote on Monday, December 06, 2010:

Stephen,
oemr.org domain is in process of getting transferred. Your NIST page is very nice; much, much clearer than what we had before; now just need to keep it updated and avoid it turning into a random notes page.
-brady

visolveemr wrote on Monday, December 06, 2010:

Brady,

We incorporated the changes for race and ethnicity and provided the patch in the tracker
https://sourceforge.net/tracker/?func=detail&atid=1245239&aid=3122211&group_id=60081

we have also updated the same in our git hub branch:
https://github.com/visolve-selvi/openemr/commits/demographics_changes

Do share your views.

Thanks,
Vicareplus Team,
services@vicareplus.com

jjcanales wrote on Monday, December 06, 2010:

Here is the pricing structure for the Drummondgroup, they appear to be less expensive.  It looks like of the 110 or so EMRs that have been certified, about 40+ were module certified, the rest had complete certification.  I think any certification will get the attention of docs.
Here is the full pricing and testing details: http://www.drummondgroup.com/pdfs/EHR_Testing_and_Certification_Guide_Rev_D.pdf
Drummondgroup testing general testing details can also be found here: http://www.drummondgroup.com/html-v2/EHR/

Pricing
Remote Testing Prices
Complete EHR – Inpatient $19,500
Retest fee $6,000
Complete EHR – Ambulatory $19,500
Retest fee  $6,000
Modules 10-19    $11,500
Retest fee for 10-19 modules - $4,000
Modules 20 or more $16,000
Retest fee for 20 modules or more - $4,000
Individual Module Pricing:
Privacy and Security Modules - $5,000.00
Each additional ambulatory or general module - $900.00
Each additional inpatient module - $1,000.0

-Joe