Wednesday, December 17, 2014

What does a HIE policy cost?

A colleague of mine were talking about policies the other day. She's been involved in policy development in a number of places, and I've also had an inside view of the process a few times myself, as well as a lot of anecdotal evidence.

So, to start with, a typical policy document might be 50 pages or so. From a professional policy writer, that might take about a page a day, and cost about $1000 to $1500 / day.  You could go lower or higher of course, but this is a decent ballpark range.  So to start off with, $50,000 to $75,000 right from the get go.  Now of course, if you already employ such a person, you might argue the rates with me, but once you account for your real costs spent on their salary, their office, their equipment, and their benefits, you are right back in that range.  Of course, that budget is already allocated, and so might be an easier pill to swallow.

Now, lets look at the work involved.  You probably need a few face to face meetings, hopefully you already have the resources to host that, otherwise you have to pay for that, but for now, lets just assume you have those resources.  An you need a few people, call it 10, to help you work out your policies.  Some of these will be lawyers ($$$$) and policy experts ($$$$) and security experts ($$$), and a bunch of C-level folk (or one level down).  Again, pricy.  You probably need them for 2 to three face to face meetings for a couple of days.  Hopefully they are volunteers and you don't have to pay for their time or travel.  Because if you do, their time could cost you oh, call it $250/hr.  And then you need a few teleconferences.  We won't worry about the T-con facilities, because you probably are already paying for that, and for this project, its small change.  So, call it 10 two hour meetings where not everyone shows up every time, and you have 20 hours * 5 people = 100 hours.  So there goes another $25,000 into the policy.  And if you had 3 days worth of face to face meetings with the whole team, then you have another 24 hours * 10 people = 240 hours.  So a grand total of 340 hours x $250 / hr.  So there went another $85,000.  And if you are signing the checks and managing this, you are likely involved for at least some part of the effort just to oversee the whole project.  So there goes another 4 hours a week times 10 weeks = 40.  So throw yourself into the pool, and 40 * 250 = $10,000.

Add it all up and there went somewhere between $170,000 and $195,000, and three to six months of time.  Hopefully you had volunteers, and that cuts it down quite a bit. But I'm betting you are paying for at least one lawyer and one policy expert, and those people don't come cheap. Even so, you might get by at around $150,000.  And depending on your overhead, and the number of people, and the length of the project you might pay even more than these figures.

Back to our 50 page document.  There are about 250 words on a page.  So a grand total of 12,500 words.  Now, that gives us a range of $12-16 per word.  Dang, I'd love to get that.  I wrote 92138 words for The CDA(tm) Book, I seem to be a few orders of magnitude off.

Not all words are of equal value.  Some stuff is pretty straightforward.  Other words are much more important.  I've seen a room of ten people argue for an hour over two words.  That's around $1250 per word.  Remember that figure the next time you get into a debate over words.

-- Keith

Wednesday, December 10, 2014

Project Argonaut for the HL7 community

This showed up in my Inbox this morning via Grahame Grieve and was sent to the HL7 FHIR Mailing list.  Given that there's a lot of interest in what Project Argonaut is, and few details, I thought others might benefit from this as well. I reproduce it here with Grahame's permission (and since that list is available for anyone to join, there's no issues there either).

-- Keith

Project Argonaut was announced last week. You can see the announcement here. That press release was intended for an external community, and didn't address lots of important questions for the HL7 community itself. So here's an outline of what project Argonaut means in practice for HL7

FHIR Ballot on May timeline

Project Argonaut arose in response to our concern that we may not be able to deliver the FHIR DSTU2 for the May ballot next year. Lots of implementers - a much wider community than the identified Argonauts - have a strong interest in that outcome. The Argonauts decided to step up and ask us what they could do to help us meet the May deadline. 

We really appreciate that, and we're glad of the help. But like everything, it comes at a price. We haven't committed that we will absolutely hit the May deadline - we can't - but we've committed to giving it a really good shot. That does mean that there's going to more pressure than there already was, and the FHIR/HL7 leadership (including EC,TSC, FGB, FMG) will need to manage the impact of this on our community. Another price is that the Argonauts have specific goals related to the JASON task force report; Project Argonaut covers more than merely "publish the FHIR DSTU 2 in May"

Specifically, Project Argonaut will have 3 main sub-projects:

1/ Security

The first project is to review the way Smart-On-FHIR uses OAuth and OpenID Connect. Specifically, Dixie Baker will drive this, and consult with the Project Argonaut community and beyond to ensure that the arrangements meet their requirements and also are consistent with wider industry best practices in these regards. 

This work is actually outside HL7. Once it's complete, and the specifications have been tested in real systems and proven satisfactory, it is our plan to work with the Security WG to bring the resulting spec into the HL7 community as a full standard, probably part of the FHIR specification (though not dependent on FHIR - this would have use in a wider context)

2/ CCDA --> FHIR mapping 

Our biggest issue with the May ballot is mapping between CCDA and FHIR. It's our intent to publish a full detailed CCDA profile for FHIR, that will describe how to represent the same content in FHIR that is in CCDA, and provided detailed conversion support. Publishing this as a full profile is not part of the May ballot (and hasn't been for a while); instead, we plan to provide this as an implementation guide subsequently. But this will only work if we're confident that there's basic alignment between CCDA and FHIR, and we can only be sure of this once we've done detailed mapping between the two. So this detailed mapping is a pre-condition of DSTU 2; accelerating this is the principal outcome from Project Argonaut for the FHIR specification itself. 

How this will work is that a small group of people - mainly the ones already doing the work on a volunteer basis - will be paid to focus a significant amount of their time on performing detailed mapping between CCDA and FHIR. This will be done openly, using normal HL7 channels (a mix of email, skype, wiki, and google documents). The mapping documents that this group prepares will probably be similar to the CDA -> FHIR mapping document ( and everyone is welcome to observe/review/comment on the outcomes. Any issues in FHIR resources that this group identifies will be forwarded to the relevant owning committee for resolution using the normal committee processes (the small project Argonaut team has no authority in an HL7 sense).

3/ FHIR implementation testing 

Although the Argonauts are supporting us to produce the FHIR DSTU 2, they have a specific interest in it - the parts that relate to the JASON task force recommendation around API based access to healthcare data. Based on this, the current draft for comment includes a brief Argonaut implementation guide ( that briefly describes Meaningful Use based access to EHR data and documents.

As part of the Argonaut project, we'll be performing several implementation based activities that have the aim of verifying that the DSTU and this profile actually are suitable for their purpose. Those of you who have already been involved in the FHIR project will know that this is basically business as usual for us, it's just expanding our existing approach to a new community. So one of the streams at the San Antonio Connectathon in January will be focused on the Argonaut interest of MU based access to data, which is using the "Fetch Patient Record" to fetch the patient record in MU compliant resources (note that the Argonaut interest is in granular access APIs, but we're just testing this most coarse access for this connectathon). There'll be other engagement activities as well, which will be announced as we get on top of them.

Plenty of people have asked "How do I get involved with project Argonaut?".  There are two answers to this.  

  • In terms of supporting the HL7 project work directly (suitable for the existing HL7 community), reviewing the CCDA mappings and participating in connectathons as well as reviewing the draft DAF work and participating in the ballot cycles and related committee work are all excellent ways of being involved
  • At a corporate level, lots of external organizations have expressed interest in becoming involved. We're working on scaling up the FHIR community to support this, in association with the Argonauts. There will be more news on this soon.

One final note: Lots of people have asked about the relationship between project Argonaut and the ONC DAF project. Well, it's simple: The Project Argonaut work is accelerating the first phase of the DAF project


Friday, December 5, 2014

What's the question?

What ever it is, if it involves Health IT, interoperability, or anything else, the answer seams to be FHIR.  And I agree, FHIR has plenty to offer the industry with regard to interoperability.  Today, the #HITsm tweetchat was all about FHIR, and the recent (yesterday) announcement of the Argonauts project by HL7 and a variety of other participants.  There's no real cabal here, or perhaps I should say that differently: Just about every cabal out there is involved.  It's the cabal of cabals.  You've got HIT Standards committee leadership and CommonWell leadership and HSPC leadership, and leaders of many other factions I'm sure.

I get to laugh a little bit about all this buzz, because I recognized FHIR was going to be pretty significant quite some time ago (in fact 2+ years ago).  And John Moehrke has been involved with the FHIR Management Group since it was initiated.  The doers have been at it for a few years already, it's good to see some of these other folk join in ;-)

And now of course, everyone wants to know what FHIR is and has advice on how to move it forward and make it better.  If you want to understand FHIR, start first with this primer.  Whoops, that's not a primer, that's actually the standard.  But it is already a pretty good place to start.  If you want to see FHIR in action, what I'd suggest you do is sign up for the HL7 FHIR Connectathon happening in January in San Antonio.  If you cannot make it to that event, you still have an opportunity to see what is happening with FHIR in IHE at the IHE Connectathon in Clevland [frankly, I'll prefer the weather in San Antonio, but will be at both events].  If you want to get involved in FHIR, join HL7, and get on the list serves, the Skype chat, the Wiki or just about any other media available.  While FHIR presently is being developed by just about all of HL7, soon there will be an HL7 Workgroup devoted solely to FHIR.

The Argonauts project is about hitting the closing stretch on the next release of FHIR, which is expected to be DSTU Release 2 in May.  There are a couple of major components related to that project (mostly about a few parts of of what FHIR DSTU 2 expects to deliver):

  1. Documents
  2. Granular Data
  3. Integration with OAuth 2.0
  4. Project Management
The OAuth 2.0 piece is a bit extra, but is part of what needs to happen to support things like a RESTful Blue Button API here in the US.  Already there's some work that Josh Mandel did for Blue Button + Pull, and for which IHE started the Internet User Authentication (IUA) profile a couple of years ago.

The big news about FHIR is not so much about Jason or the Argonauts (most all of whom die in the end, except perhaps Heracles), and more about the fact that like the Argo, FHIR has the biggest collection of Interoperability heroes on board.  With a crew like this, it should be an amazing ride. Are you in?


Thursday, December 4, 2014


My 1000 words for the day (and actually, they are Regina's):

Wednesday, December 3, 2014

Bones or Monty Python?

A couple of weeks ago, Bob Watcher wrote: Meaningful Use. Born, 2009, Died, 2014? John Halamka suggested we need to Declare Victory for Meaningful Use (see item #5) by 2016 even earlier this year.

I'm not so sure Meaningful Use is dead.  It's pretty clear its a program in transition, but that writing was already on the wall when there was a transition from payments (2014) to penalties (2015).  I fully expect to have another 500 pages to read this holiday season.

How about you? Who's right? Bones or the old coot from Monty Python?


Tuesday, December 2, 2014

FHIR is all the Buzz

This morning I got another unsolicited sales request, but this one amused me.  The company reports "extensive experience in FHIR and HL7 integration, EMR, HIS, Cloud Engineering, Big Data Integration, HAdoop, Java, J2EE based HA Architectures, Web-services, Android, iPhone and a host of other cutting-edge technologies" buzz-words!

I love it that FHIR has reached Buzz-word status, but even more so, for the right reasons.