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http://online.wsj.com/article/SB124027664223937475.html

Some interesting points raised (once again) in this article (which takes the
time to point out a couple of "oopsies" on early adoption) , but they STILL
seem to miss the point about persistent access and fail to consider the
retention period being either the patient's life or longer in cases of some
oncology and exposure records.

This was pretty interesting though:

The stimulus bill says doctors and hospitals must use "certified" electronic
systems to qualify for incentive payments, but the job of establishing
certification criteria will fall largely to Dr. Blumenthal, named to the
post from Harvard Medical School last month.

Major systems on the market now are certified by the Certification
Commission for Healthcare Information Technology, a group that has operated
with a combination of federal funding and fees from companies that apply for
certification for their systems.

CCHIT certification is based largely on whether a system can exchange
information with systems sold by other companies, and on whether a system
includes certain functions.

Okay, so:

- The stimmy bill says the systems must be certified- Check
- The 'certification' is based on ability to exchange info with other systems   
   and inclusion of certain functions- Check
- The CCHIT is a group operated  with a combination of Fed funding and 
  "fees from companies that apply for certification"- WHAT?!?!?

This is as bad or worse than DOD 5015.2, because in this case, it affects
ALL CITIZENS whose physicians are impacted by this... DOD 5015 only impacts
(by mandate from NARA) the use of ERMS by Federal Agencies to manage Federal
Records.   

And again, this is a case of "pay to play"... so I'm sure the requirement
for exchange between systems in the design documents for certification will
be limited to the architecture and requirements of other systems whose
companies are paying a fee to be part of this closed partnership funded on
the backs of taxpayers.  And what are the 'certain functions' that are
included... or more importantly that are not included? 
  
I understand ARMA may be deciding where to get involved in this process?  I
would have to think this is a shining example of where they'd want to
interject an opinion and/or encourage some involvement.

If a small number of well funded companies establish the requirements for
certification that ALL systems are required to meet for medical
practitioners to obtain funding under the ‘‘American Recovery and
Reinvestment Act of 2009’’, the result will be all of our citizens impacted
by the guidance developed with Federal funding and the desires of a limited
few companies who were able/willing to pay to establish the ground rules all
others must comply with.

Larry
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