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.

What to do about ONC meetings next week if the US Government Shuts down

Just got this via e-mail today (because Monday the mail might not go thru).  In summary, if the Gov't shuts down, FACAs will not meet -- read the entire message below the line for details.


I have not been able to confirm what would happen to ONC S & I activities. Because those are led by contractors rather than ONC employees, it isn't at all clear what will  happen, and few of them are answering Skype/e-mail/twitter right now (just before 5:00 EST).


If a shutdown does happen, I will use any extra time (note, I said extra, because it was never free) to make progress on other fronts that have been postponed by government activities ;-)

If I learn more, I'll update this post.

Update: According to one source: All is still on: Contractors work at risk, and from another: Purely federal folks will not be on calls, but contractors are allowed to work at their own discretion.

Oh well, so much for work put on hold ;-(

   -- Keith

---

Dear FACA members,

As you may know, we face a possible government shut down as of midnight tonight, April 8. In case we do shut down, there will be no federal government activity including any FACA meetings or calls. I, and others at ONC, will be prohibited from conducting any of our duties while the government is closed. Once funding is available, we will return to work. IF THERE IS NO SHUT DOWN, THE MEETINGS WILL CONTINUE AS PLANNED.

Assuming we are shut down:  If there is a FACA Workgroup conference call and we are shut down, that call will not take place. However, if we find out the day before the call is scheduled, please assume that the call will take place. For example, the Information Exchange Workgroup has a call scheduled for Friday, April 15; if we are back at work on Thursday, April 14, that call will take place.

The situation is a little different if there is an in-person meeting, such as the HIT Policy Committee on April 13 in Washington, DC.  If we know by noon the day before (in this case, noon on April 12), you may assume the meeting will take place.

Travel: if you travel on the morning of April 12 for the HITPC but find after noon that the meeting is cancelled, we will be able to cover your costs since the funds are from FY10 money.  Also, if you find that the notification of the meeting occurring is short, you may wish to call into the meeting and we can arrange that.

Since we will know more at midnight tonight (but I cannot come into work this weekend if we are furloughed), I will email you all on Monday morning, April 11, with final instructions. I hope any shutdown is not lengthy, but if it does stretch more than next week, please watch the news. I will send you an email as soon as I am able. Please call or email me if you have questions. I will be available until about 11:30 am/ET on Monday, April  11 (Not over weekend if we are shut down).  Thank you for your patience and understanding. Judy

FACA Schedule – April 11 through April 22

In-person Meetings in Washington (will be held if Government open by noon the day before):

April 13, HIT Policy Committee meeting

April 20, HIT Standards Meeting

April 21, Certification/Adopting Workgroup meeting (I am also sending this information to panelists)

Workgroup calls (will be held if Government is opened the day before):

April  12, Quality Measures WG

April 14, Vocabulary Task Force

April 15, Information Exchange WG

April 18, Privacy & Security Tiger Team and Clinical Quality WG

April 19, Business Rules Tiger Team/Enrollment WG

April 22, Clinical Operations WG

Judith Sparrow

Office of the National Coordinator for HIT

Dept of Health and Human Services

Washington, DC