Let's pray that CCHIT takes a crash course in open source.

The new proposed CCHIT certification standards [ PDF, slide 8 ] are a small step in the right direction. Unfortunately, they also betray CCHIT's profound lack of understanding of the economics and technology behind open source.

In order to work to its potential, an open source community would be comprised of thousands of independent developers. Developers work with existing open source such as VistA, or download an SDK. They then are free to improve it by building modules on top of the original. In order to make the time investment feasible to a single developer, these modules are typically very small in scope. Outside healthcare, an open source deployment normally consists of scores or hundreds of "bite-sized" modules running on top of a kernel or core.

The EHR-M standard provides a double disincentive. First, it puts the cost of certification on the innovator / developer. Secondly, it makes it uneconomical to divide modules into the very small components that independent developers can afford to build without financial backing.

There is no guarantee that a customized open source deployment would retain all of the features and functionality of the CCHIT-certified modules that it contains. For the purposes of maintaining quality standards EHR-M certification is meaningless.

Unfortunately, EHR-S certification won't fare much better. By using screen captures as a basis for EHR-S certification, CCHIT is committing to a process that's as worthless as using paper printouts for usability testing. An EHR that looks good on paper could be utterly unusable -- an expensive lesson that was learned bitterly in the 1990s by most dot-coms.

The choice of the word "site" in EHR-S is also quite unfortunate -- at times during the first Town Call, it was unclear as to whether CCHIT was using "site" to refer to a single location/organization or at a single web domain.

[written as a response to John Halamka's post A New Approach to Certification ]


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