Under the proposed Meaningful Use rules, there's still a disconnect between how CMS and ONC define a Summary of Care Record in the Rules, what the S&I Transitions of Care project did, and how they could be implemented in the CDA Consolidation guide. I've spent the last week making sense of it, and I think my last two posts succeed in that. We need to rationalize the description of the Summary Care Record, and we need to indicate how it can be implemented using the CDA Consolidation guide.
This could be better done in an implementation guide. The question that someone asked me this morning is if we need to write one in time for it to be named in the final rule. I think not, and here is why:
- It's time to ship what we have, and let people start implementing. We need to let the implementation issues guide the next steps, not what we theorize will be the issues.
- The current CDA Consolidation guide is based on a new framework for developing CDA templates. That framework also needs time for further development and improvement. Changing the guide (again) before we continue on framework development activities will further delay framework improvements.
We have substantial experience with CDA now in the Healthcare industry. The CDA Consolidation guide builds from that experience. We'll be better served by letting the industry move forward at a reasoned pace than we will by starting another crash project that will take away from comprehending what we already have.
At this stage, we need testing and validation tools, implementation tools and working source code. If you want something to work on for Meaningful Use, any of those are good targets.