The AMA and 33 other organizations sent a letter to National Coordinator Karen DeSalvo last week.  The letter has seven requests of ONC:

1. Decouple EHR certification from the Meaningful Use program;
2. Re-consider alternative software testing methods;
3. Establish greater transparency and uniformity on UCD testing and process results;
4. Incorporate exception handling into EHR certification;
5. Develop C-CDA guidance and tests to support exchange;
6. Seek further stakeholder feedback; and
7. Increase education on EHR implementation.

Let?s take them one-by-one ? 

Decoupling EHR certification from the EHR incentive programs.  One could argue that this is already happening, and we can expect it to continue to happen.  Check.

Re-consider alternative software testing methods.  I?m not sure that ?re-consider? is what?s in order here.  The letter asks ONC to re-consider the stance on scenario based testing.  But ONC?s stance is (and always has been) that scenario based testing is a great idea.  Is the goal of the letter to express enthusiasm for this model?  ONC will share the enthusiasm.  The harder part will be to create a framework that builds and maintains scenario-based test procedures.  This is a shared responsibility.  Shared by government (ONC and NIST) and industry (health IT developers) and – yes – the AMA and the 33 other organizations who sent the letter.  ONC has invited everyone to participate (here?s the open test development site).  So far – I don?t see much (any?)  engagement from the AMA or the others who signed the letter.  It?s relatively easy to write a letter saying someone else is responsible for solving problems.  Time to step up to the plate and participate in the solutions, folks!

Establish greater transparency on UCD testing.  Yep.  I agree.  ACBs need to enforce this, and ONC needs to get serious with those who don?t comply. UCD testing results not posted on the CHPL?  Give them 60 days warning (more than enough!) and de-list the product.  

Incorporate exception handling & C-CDA guidance and tests.  These requests expresses AMA?s ambition for ONC (and NIST?) to do full interoperability testing.  But as defined by congress in ONC?s authority – the certification program does conformance testing.  That means the products conform to the standards.  It doesn?t mean they have been tested with full end-to-end interoperability tests.  If we want ONC and NIST to do that – there will need to be an expansion of ONC?s authority and budget.  Asking ONC to do this is barking up the wrong tree.  AMA should lobby Congress on this one, not ONC. Yes – there is some low-hanging fruit here with the C-CDA. ONC could offer more explicit guidance to limit some of the optionality that exists in the HL7 standards.  I agree on this point.

Seek stakeholder feedback.  I think they do a pretty good job with this.  ONC?s FACAs are open to the public, transcribed, and always invite public comments.  

Increase EHR implementation eductaion. Well, ARRA funds are depleted.  While I agree that there is work to continue here – but ONC and the RECs and the developer community – I?m not sure that this can be increased in context of the current fiscal situation.  

I?ll enable comments on this post - as I?m interested in how others view this letter.