Jo Ann Klein • almost 8 years ago
Prototype of Production System?
We were initially excited to see this opportunity as we are very interested in and have experience in patient portal development. However, after reviewing the rules, as a developer, I have multiple concerns about this contest which I will bullet below:
Who owns the completed product? Is it the VA, developer, and/or the physician who has put the product in his/her EHR? How are licenses to be managed?
Why is the federal government forsaking their own Federal Acquisition Rules (FAR) rules permitting this contest? This contest is requiring personal health data from private entities to transmit into a system that the government (VA) will access to import this personal data into the patient's VA EHR. By supporting the placement of non-vetted products into a government production system, this contest bypasses all government regulations for installing a COTS product. In addition, there is no representation from the VA to guide product development.
Who will make sure the product meets all government security requirements for data (HIPAA, PI, PHI, HL7), as well as technology/network security (MPLS lines)? How will user security managed? Will the VA fund the addition of this security?
Who supports and maintains the product? Who is responsible for upgrades? Who is financing this?
Who supports the Patient Call Center for the myriad of questions that will come in pertaining to IDs/Passwords/clinical data interpretation?
How can this be a one-size fits all product when there is no standardization of data dictionaries across EHRS, many of which are home-grown? How can we know how to map data correctly?
Why is this a contest and not a RFP/RFI? It should be based on the complexity of security issues surrounding the tranmission of patient data.
Finally, why would any company give away their source code for the "possibility" of winning $50,000 when it costs much more than for development?
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