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Friday, October 4, 2013

Is ONC Essential?

This most excellent question was posed on Twitter by Tom Sullivan, editor of Government Health IT.

Let's look at what isn't happening, and ask some critical questions:

1.  TTT is still down.  Actually, it's just NIST's version of it that is down.  The real challenge here is not for testing bodies, but for organizations trying to certify product who need access to this tool prior to their certification runs.

What does this mean?  It means that organizations that didn't have time, skills or resources to duplicate the TTT infrastructure are stuck on testing.  Some certifiers have a copy of the testing tool handy  (e.g., CCHIT reported that they do).  Contact your certifier and see if they'll make that available to you for precertification testing.  And next time, get a copy of the tools before they go away.

It would be nice if someone else who had them made them publicly available to anyone, customer or otherwise, to use while folks are off on furlough, and it would be a huge publicity bump.  We as an industry should take some responsibility for having the necessary infrastructure. but I digress.

Essential?  Only if having vendors be able to provide product so that providers can start Meaningful Use Stage 2 on time is essential.  If necessary, both CMS and ONC have the regulatory tools to fix the problem. The folks most hurt by this are likely smaller vendors, who either haven't already tested, or didn't replicate the testing tools.

Essential?  Maybe.  Missed?  Absolutely. But the reality is, probably not as much when I compare it to other things that aren't happening.

2. CHPL isn't being updated.  That's a potential challenge in the long term, but not just yet.  If it starts impacting the ability of vendors to provide product or providers to use certified product, then yes, it could be worth looking over.  But I don't see a delay lasting as long as by when someone has to attest for Stage 2.  f that were to happen, there's a lot more important things to worry about.

Essential? Nah. Missed? A bit.

3. Federal employee engagement in standard development. They have the requirements, but they mostly contract out the work.  Contractors are somewhat impacted, but many are still working.
Essential?  Nah. Missed? Not yet, but could be soon.

4.  S&I Framework:  You wouldn't believe the number of hours that I'm spending this week and next on project proposals coming out of S&I.  And while key Federal people aren't available to discuss them, the rest of the world moves on why the Government remains at a stand-still.

The only essential things here are what ONC considers to be essential to meet it's mandates.  And what I'd like to see is a bit more rational pace.

HL7 is moving forward with Project Scope Statements on the Theory of Everything related to Clinical Quality even though they aren't here to guide us. Volunteers got it done.

There are some ways we could make S&I Framework more volunteer driven, less a burden on ONC, and more relevant to healthcare provider needs, but I think one of its values to ONC is that it is very driven by ONC requirements.  There's a middle path in here somewhere, and it could be worth exploring again in the future.

Essential? No.  Missed? Yes.

5. FACA Meetings not being held.  Development of regulation is being slowed down.

Essential? No.  Missed? Not really. Those deadlines were insane to start with.  It's important work, but that also means its important to do right.  And right and fast don't always go together.

I think the most hurtful component of ONC cutting back to the healthcare economic sector is what these delays mean for healthcare providers and healthcare IT vendors with respect to Meaningful Use stage 2. There seems to be some economic impact here, but I have no clue how to measure it.  But I bet there's some essential person at OMB who could compute the economic cost of the shutdown working right now.

The next most challenging impact is on the final quality of results should ONC try a hurry up to hit some of its internally set deadlines with regard to new regulations.  If congress shuts you down, and you wind up being late, I don't think they should count that against you.  As I recall, the Secretary of HHS has some leeway here.

The really painful part will be kick-starting everything again.  I feel bad for Jacob. What better way could there be to start a new job but to send all your people home.

Overall, Essential? No.  Missed? Yes.

1 comment:

  1. Keith, There seem to be two highly related issues: 1.) the pace of HITECH; 2.) the role for ONC. High tech accelerated a lot of trends and ONC plays a vital role here. But it's hard to accelerate cultural change. May I ask the question differently? We face a crisis in health care delivery. How, in your mind, have these many initiatives accelerated positive and meaningful change? Conversely, how has the pace and scope potentially led to sub-optimal results?
    Your question on the economic impact is an equally important one.