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Tuesday, August 13, 2013

What's the Rush?

I got into a debate... no, not really, call it a fight with one of the SD co-chairs today over our rush to get CCDA Release 2.0 out the door.  I've been asking why we are trying so hard to get it out, and I finally hear today that ONC would like it finished by December.  Now, when the project was first discussed (around the Working Group Meeting in January), that was a perfectly understandable deadline.  After all, if we wanted something that could be referenced in the Meaningful Use Stage 3 NPRM, having a DSTU Ballot in September is ideal.  We could even have the final document perhaps ready in time to be referenced by the NPRM (subtract a few months from the NPRM date if you want to align with regulatory requirements), or at least very close.

Things are slightly (to say the least) different since CMS announced that Stage 3 wouldn't arrive until 2014.  Several people I've spoken to (although none in any Federal agency) seem to believe that Q3 or Q4 is likely, and I agree.  Although trying to get anyone to admit that in government would be next to impossible.  Even so, it's pretty reasonable to assume that deadlines are just a bit looser than they were when we were first discussing this project.

Why do I want to wait?  My main reason is that I would really like the next edition of Consolidated CDA to do two things:

  1. I want it to version templates the way that the forthcoming Templates DSTU proposes.
  2. I'd like one of the adjuncts to the C-CDA DSTU  to be in the new machine readable Templates DSTU format.
There are a couple of reasons for this:  My biggest complaint about the CCDA was not the changes we made to it, but the fact that SO MANY of the template identifiers changed, and the amount of work that created for implementers. We HAD to change the identifiers, but there were several better ways to handle that.  That's ONE of the things that the Templates DSTU (and the IHE CDA Harmonization profile) are trying to work out.  The cost to deal with template identifier change is not something I want to consider.  I know how much time I already spent on it here.

Meaningful Use Stage 4 isn't out of the question.  I think that before we go into Stage 3, we need to have a solid basis for how we manage change in templates before we issue a new edition of CCDA.  And our current mechanism isn't it.  It doesn't matter how much documentation you provide, until it is provided in a standard, machine readable format, it isn't going to be easy to update EHR software to support new editions of the standard.  I've been through this several times already, and I know many of my colleagues feel the same way.

My other big issue is trying to align international projects with the CCDA.  Having template identifiers change underneath me just as I start to get things aligned makes it nearly impossible for me to get anything done.  IHE and HL7 agreed to synchronize on CCDA.  I'm almost done with the IHE synchronization. Given the extra half year needed to polish CCDA into Release 1.1 for Meaningful Use IHE is a full cycle behind.  I don't want to have to redo all that effort and analysis because of the new template identifiers, or figure out how to piece these things back together using the new machine readable change log I've been promised.

So, if I'm right, and Stage 3 isn't "just around the corner", why are we killing ourselves trying to get it done, instead of trying to do it right?  I'd rather spend my time getting the Templates DSTU out in a timely fashion, rather than fighting yet one more battle about speed vs. quality.  Then I'd have machine readable CCDA specifications, based on a standard, and that should make the whole industry happy.  I could download the templates into MDHT, and just generate code.  That would make me joyous.

It might also be nice to have a little bit of CCDA experience in production behind us too, before we finish  release 2.  Implementation experience is valuable, but what are you going to do with the real challenges?  They won't start showing up for a few more months when healthcare providers start using the software that EHR implementers have been implementing and certifying.

I'm guessing that one of the challenges that I'm dealing with is the fact that money is running out of ONC's war-chest.  The chest was already almost empty, but they appear to have managed to move some research dollars and put them into CCDA improvement efforts.  That could be ONE reason why the push is still on.  If so, it's the wrong reason.

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