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1
EHR-QTN
Final Review
Brussels, March 30th 2012
2Brussels, March 30, 2012
Introduction of consortium and experts
3
Agenda
The partners
EHR-QTN: why was it needed?
Overview of the Network Activities
Investments done during the lifetime of the project
Validation of the EuroRec Statements
EHR Market Overview: main conclusions
Roadmap towards a sustainable pan-European certification of EHR systems
Recommendations from the Roadmap
Quality Labelling and Certification Procedures: the quality of the process
Conclusions and what brings the future?
Questions
Brussels, April 8, 2011
4Brussels, March 30, 2012
5
EHR-QTN : Why certification? Why the project?
Brussels, March 30, 2012
6
Reasons for “Certification”
eHealth and more specifically Electronic Health Record systems have an enormous potential to improve quality, accessibility and efficiency of care, provided they are:
reliable, trustworthy and of sufficient quality;sharable and interoperable;used appropriately.
Quality labelling and certification through professional third party assessment offers best chances for a comparable and reliable quality documentation of those systems. Brussels, March 30, 2012
7
Some EHR quality issues
1. Patients are too important to just suppose that EHR systems are trustworthy.
2. Patient data should not be locked into one system or application.
3. Patients essential data should be made available anywhere anytime to health professionals authorised to access them.
4. Patient has the right to request confidentiality of some data to be handled while taking full responsibility for that option.
5. Patients’ data accesses should be audit-trailed.
Brussels, March 30, 2012
The quality challenge
Myers et al*. show that adverse events are mainly resulting from:
• missing or incorrect data;• data displayed for the wrong patient;• chaos during system downtime;• system unavailable for use.
Examples of reported incidents in healthcare where a medical information system was the cause or a significant factor: http://iig.umit.at/efmi/badinformatics.htm
*Myers DB, Jones SL, Sittig DF, Review of Reported Clinical Information System Adverse Events in US Food and Drug Administration Databases, Applied Clinical Informatics 2011; 2: 63–74.
9
Why was such project needed?
Too many authorities not aware of the quality needs and related problems.Even more authorities not effectively involved in quality labelling and certification.Lack of awareness about what exists.Existing initiatives not comparable with each other.Cross-border quality assessment almost unexisting.
Brussels, March 30, 2012
10
Overview of the Network Activities
Brussels, March 30, 2012
Dissemination & AwarenessWorkshopsAnnual EuroRec ConferencesProject DataConsortium MeetingsDeliverables
11
Workshops
In total 76 workshopsAt least one per countryAgenda of the workshops:
Year 1: Communications from the Commission, Seal Level 1, RepositoryYear 2: Validation of the EuroRec StatementsYear 3: Validation of procedures & roadmap for the countries with most chance of making progress
Brussels, March 30, 2012
12
Overview Workshops
• Listed in the three Annual Reports and the Final Report
• Reported in deliverables D1.4, D2.2, D3.2, D4-I, D4-II, D6.1a, D6.1b and D6.4
Brussels, March 30, 2012
Q14/09
Q27/09
Q310/9
Q41/10
Q54/10
Q67/10
Q710/10
Q81/11
Q94/11
Q107/11
Q1110/11
Q121/12
Tot.
National Workshops Planned - 6 6 7 7 7 6 7 7 6 7 6 72
National Workshops Reported / Announced
4 4 13 4 2 8 10 4 2 1 24 76
13
Workshops: questions and suggestions
Resulted in valuable comments and questions regarding:
Quality labelling and certification as such: need, quality & professionalism of the process;The content of quality assessment;The role of the (national) health authorities;The use and appropriateness of the EuroRec Descriptive Statements;The importance of functional testing.
Brussels, March 30, 2012
14
A Norwegian statement…
A recent Norwegian statement is an important one and based on a large experience in certifying “messages” (certifying all kind of standards based data exchange).
The Norwegian Ministry of Health and Care Services stated that “EHR Quality will be difficult to reach unless certification of the EHR systems is made mandatory”.
Brussels, March 30, 2012
15
EuroRec Conferences
Brussels, March 30, 2012
EHR-QTN EuroRec (Annual) Conferences
1EuroRec Conference 2009, Sarajevo, Bosnia & Herzegovina
August 30-31, 2009
2EuroRec Session at WoHIT 2010, Barcelona, Spain
March 17, 2010
3 EuroRec Conference 2010, Tallinn, Estonia June 18, 2010
4EuroRec Session at WoHIT 2011, Budapest, Hungary
May, 12, 2011
5Regional Conference on EHR Systems Quality Labelling and Certification, Belgrade, Serbia
November 21-22, 2011
16
Consortium Meetings
Brussels, March 30, 2012
EHR-QTN Consortium Meetings
1 Prague, Czech Republic, Kick-Off February 17-18, 2009
2 Sarajevo, Bosnia-Herzegovina August 31, 2009
3 Dublin, Ireland November 17-18, 2009
4 Tallinn, Estonia June 17, 2010
5 Sofia, Bulgaria December 9-10, 2010
6 Lisbon, Portugal June 17-18, 2011
7 Nicosia, Cyprus December 2, 2011
17
Deliverables
Brussels, March 30, 2012
TABLE 1. DELIVERABLESDel. no.
Deliverable name WP. Lead participant Nature (i) Dissemination level (ii)
Due delivery date
Deli-vered Actual / Forecast delivery date Comments
D1.1 Kick-Off Meeting 1 EuroRec E C 2 Yes 05.11.2009D1.2 Documentation for the workshops 1 EuroRec R C 2 Yes 05.11.2009
D1.3 EHR-QTN website 1 EuroRec R P 2 Yes 05.11.2009
http://ehrqtn.eurorec.org/http://www.eurorec.org
D1.4Report on Workshops 1 - 6 1 EuroRec E/R C 6 Yes 05.11.2009 Workshops 1 to 3
reported
D2.1Documentation for the second set of National Workshops
2 EuroRec R C 9 Yes 18.02.2010
D2.2Report on National Workshops 7 - 19
7 to 19
2 EuroRec E C 12 Yes 26.02.2010 Workshops 4 to 21 reported
D2.3Report on the Annual EuroRec Conference 2 EuroRec E C 12 Yes 15.02.2010
D2.4 First Annual Project Report 2 EuroRec R P 12 Yes 03.03.2010
D3.1
EHR Market Overview – Suppliers 3 EuroRec R P 15 Yes 30.12.2010
D3.1EHR Market Overview - Stakeholders 3 EuroRec R P 15 Yes 01.12.2010
D3.2Report on the National Workshops 3 EuroRec E C 18 Yes 04.11.2010 Workshops 22 to 27
reported
D4.1Report on the National Workshops (2 parts) 4 EuroRec E C 24 Yes 07.03.2011
09.03.2011
Workshops 28 to 44 reported
D4.2Report on the Second Annual EuroRec Conf. 4 EuroRec E C 21 Yes 16.03.2011
D4.3 Second Annual Project Report 4 EuroRec R P 24 Yes 16.03.2011
D4.4Validation of EuroRec Statements and EuroRec Use Tools
4 EuroRec R C 22 Yes 15.03.2011
D4.5Documentation for the third set of National Workshops
4 EuroRec R C 22 Yes 24.03.2011
D5.1 Report on the National Workshops 5 EuroRec E C 30 No Merged with Deliverable D6.1
D5.2Roadmap towards Sustainable Pan-European Certification of EHR systems
5 EuroRec R P 30 Yes 11.11.2011
D6.1Report on the National Workshops (2 parts) 6 EuroRec E C 36 Yes 08.02.2012 Workshops 45/76
reported
D6.2
Report on the validation of the quality labelling and certification procedures and scenarios
6 EuroRec R P 36 Yes 14.02.2012
D6.3Translated EuroRec Statements Report (2 parts)
6 EuroRec R C 33 Yes 05.03.2012
D6.4Report on the Third Annual EuroRec Conference
6 EuroRec E C 36 Yes 30.12.2011
D6.5 Third Annual Report 6 EuroRec R P 36 Yes 05.03.2012D6.6 Final report 6 EuroRec R P 36 Yes 10.03.2012
18
Investments during the lifetime of the project
Brussels, March 30, 2012
19
Investments
Improving functionality of the Repository.Definition of EuroRec Seal Level 1 and 2.Translations into 21 languages.Validation workshops.Setting-up effective quality labelling.
Brussels, March 30, 2012
20
Functional Tools Investments
Extensionof the repository: secondary use of EHR data and lab reporting related issues.Adding content-related functionality:
definition sectioncomments and interpretationnational variants
Adding maintenance functions to manage e.g. modifications in a multi-lingual environment
Brussels, March 30, 2012
21
EuroRec SealsEuroRec Seal Level 2 defined during the lifetime of the projectBasic sets of quality criteria
Addressing reliability, trustworthiness, authentication, access management and basic functionalityComparable across borders and domains
Example of a “market driven” approachStandardisation of the procedure (see further)Products out of 7 different countries certified
Brussels, March 30, 2012
22
Industrial testimonies
“EuroRec Seal greatly helped to improve SW products.”
“Developers got clear guidelines about key features that are often neglected by end users.”
“Customers got additional assurance of software quality.”
“The Seal offers increased odds at foreign markets.”
“The EuroRec approach is very useful for new software (modules), new application design… giving ‘new ideas’.”
Brussels, March 30, 2012
23
Translations: 12.379 in total
Brussels, March 30, 2012
24
Validation of the EuroRec Repository and of the Descriptive Statements
Brussels, March 30, 2012
25
Validation of the statements
Validation doneWhen translating the original statementsDuring the workshopsBy the “clients”, software suppliers
Validation of the following aspects:FormulationContentTechnical correctnessImportance (for application quality)Feasibility
Reported in deliverable D4.4
Brussels, March 30, 2012
26
Setting-up effective quality labelling
Brussels, March 30, 2012
27
Effective Quality Labelling
Documentation free available.Seal request forms on the web.Procedure validated against the applicable standards.Partners involved (not only ProRec centres).
Brussels, March 30, 2012
28
EHR Market Overview : main conclusions
Brussels, March 30, 2012
29Brussels, March 30, 2012
30
EHR Market Overview - Summary
24 National market Overviews using a common templateTwo Deliverables
Del. D3.1 Part I: Suppliers and Supplier Organisations: 1.005 supplier / product IDDel. D3.2 Part II: Authorities and important stakeholders: 663 addresses
Detailed presentation: previous review
Brussels, March 30, 2012
31
EHR Market: some considerationsVery fragmented as expected
May endanger quality of applications, though never proven.Not the privilege of the suppliers: also large number of “important stakeholders”.
There is no one single nor homogeneous provision of healthcare in Europe, neither within one country
Each profession needs a “different” application.Using the same application in several countries does not work.
There is some market “concentration”Concentration of ownershipNo concentration of applications, even when the same name is used in different countriesBrussels, March 30, 2012
32
One of the project conclusions
The only approach that may work seems to be to increase harmonisation within diversity, offering more and more “similar” (not identical), functions based on the same basic functional and quality specifications.
Brussels, March 30, 2012
33Brussels, March 30, 2012
34Brussels, March 30, 2012
Roadmap towards a sustainable pan-European certification of
EHR systems
35
Deliv. D5.2 :Table of Content
1. Potential of the EHR: Why? Possible benefits? Barriers to adoption? Requirements?
2. Importance of Quality Labelling & Certification
3. Stakeholders and their role
4. State of Practice in Europe
5. Prerequisites for (sustainable) Quality Labelling & Certification
6. Main strategies regarding quality labelling and certification
7. Roadmap for certification at National Level
8. Cross-border Certification Roadmap
9. Cost of Certification & Business Definition
10. Risks and Remedies
11. EHR-QTN Recommendations
Brussels, March 30, 2012
36
Introductory statement
“Realising the potential health added and economic value linked to using an EHR system is not obvious. It requires huge investments and a professional development environment. It requires a permanent focus on “quality” at functional quality level and thus also regarding “interoperability”.Quality should be documented in an objective, comparable and trustworthy way.”
Brussels, March 30, 2012
37
Verification versus Validation
Verification = technical correctness of the software application or component of an application. Verification attempts to answer the question “is the software built right (rightly)?” => medical device directive ?Validation = compliance of the application to the consumer’s / user’s functional expectations: is the application offering what it is expected to do? Validation attempts to answer the question “is the right software built?” => procurement and functional validation !
Brussels, March 30, 2012
38
Five areas for quality labelling and certification
Data exchange facilities (incl. IOP)Functional (incl. some aspects of IOP)Administrative and billing facilitiesUse related measurements and validationSoftware development quality (out of scope, not specific for EHR systems)
=> Different expertise , different organisationsDublin, November 17-18
39
Scope of EHR QL & Certification
Different expertise => Different organisations.Our focus for Deliverable D6.2 is on
Functional testing, including some aspects of interoperabilityData exchange (message production and integration)
We will address how to “cooperate” later on.
Dublin, November 17-18
40
The use of EHR systems
Consortium listed the top 5 good reasons to generalise the use of EHR systems.A small literature survey proofs quantifiable profits.There are nevertheless still barriers to EHR adoption:
by Healthcare Professionalsby IT providersrelated to political and organisational factors
Brussels, March 30, 2012
41
Not all EHR systems are good enoughSelecting the most appropriate application from the correct vendor is a real challenge => importance of assessing the systems’ quality.Comprehensive and correct use is another important factor =>
Importance of training the usersImportance of assessing the usersMotivation for incentives for the users.
Brussels, March 30, 2012
42
Impact of certificationConsortium listed the top 5 good reasons to adopt country wide EHR certification:• Assure compliance to national rules and
standards.• Increase quality of the products through
coherent and pre-tested functionality.• Leverage exchange of health (care)
related data and interoperability of systems.
• Improve patient safety in care.• Have a reliable data source for
secondary use.Brussels, March 30, 2012
43
Prerequisite
“ If quality labelling and certification of EHR systems is to become generalised, then it needs endorsement at the highest competent levels e.g. by the EU Commission, the responsible Member States Ministries, the Healthcare Providers Organisations and the specialised industry.”
Brussels, March 30, 2012
44
Stakeholders & Functional Diagram
Brussels, March 30, 2012
Certification body
CAB
InitiatorIAF
Product
Supplier Authority
Accreditation body
Certificate
Label
ISO/IEC 17020 =>
<= ISO/IEC 17011
ISO/IEC 17025 =>
45
Kind of Quality Assessments
“Authority driven” versus “Market Driven”
Independent organisation / Industrial organisationPublic initiative / Supplier initiative
Third party assessment versus self-assessmentComprehensive versus ModularNational / Regional versus Cross-BorderSystem functionality versus “Interoperability”Generic versus Domain/Target Specific (LIS,…)
Brussels, March 30, 2012
Procedure and kind of attestation
Certification procedure Attestation
granted
Third party assessment by a CAB being a public authority or an organisation granted power by a public authority either by law or by regulation.
Certificate
Third party assessment by a CAB on requirements issued by an organisation not empowered by law or by regulation.
Quality label
Self-assessment with an external audit. Conformity assessment is done by the supplier and documented to a third party, being a public entity, a professional organisation or an industry federation.
No “attestation” but a Quality Mark on
the product is allowed
Self-assessment by vendor who performed testing on his own products and affirms that they conform to a given set of requirements.
Declaration of quality
most
su
itab
le
pro
ced
ure
47
Actual “National” Certification
Brussels, March 30, 2012
• Existing “national” certification
• Foreseen within 1-2 years
• Considered
48
Actual “cross border” quality labelling
Not “authority driven”There is no such an authorityNo formal recognition of certificates across borders
Three “private” initiativesEuroRec: independent, focus on EHR systems (functional and exchange as function)
I.H.E.: industry driven, focus on testing the exchange and the technical interoperabilityContinua Health Alliance: industry driven, focus on devices content portability
Brussels, March 30, 2012
49
One Destination, Two Itineraries
Different and complementary approaches but always phased in a similar way:
Setting the framework & the decision to go for itPre-assessment: organisational contextAssessment: test related activitiesGranting label or certificate
Brussels, March 30, 2012
Roadmap for Certification: national level
Setting the Framework
•Convince the authorities to take the decision to go for quality labelling and certification
•Create the legal framework
•Accredit a certification body
•Create advisory platforms with users and suppliers
•Select the standards to be used
Pre-assessment Phas
e
•Select and prioritise functions / processes to be assessed
•Negotiate feasibility with suppliers and users
•Formulate verifiable quality criteria
•Create appropriate documentation regarding each of the criteria and the procedure
•Manage Q & A and "interpretations"
•Select CAB (Conformity Assessment Body)
Assessment Phas
e
•Define "test population"
•Define "test scenario's"
•Development of assessment tools
•Evaluate test scenario's on feasibility and appropriateness
•Install logistics (inscription, financial aspects,..)
•Assess the applications
•Document conformity or non conformity to the criteria
Granting & Maintaining the
Label /
Certificate
•Decide on granting or not granting the label or certificate
•Document motivation and archive assessment documentation
•Enable "appeal" and "retesting" sessions
•Distribute the "incentives"
•Update / upgrade of the criteria for future use
51
Conditions enabling “national certification”
Consortium listed the top 5 enablers for a country wide certification:• Stimulate the use of certified EHR systems by creating
incentives (€).• Create a legal framework enabling to define quality
criteria for the EHR.• Initiate a cooperative platform involving all stakeholders
to define domain / profession specific quality criteria for the different EHR settings (GP, secondary care, …).
• Stimulate the use of certified EHR systems by offering services (e.g. simplification of administrative procedures).
• Initiate a cooperative platform involving all stakeholders to define overall quality criteria for the EHR.
Brussels, March 30, 2012
Cross-border Certification Roadmap
Setting the Framework
•Create or recognise an institute or organisation to grant labels to EHR applications
•Create contractual context governing the quality labelling platform and processes
•Create advisory platforms with users and suppliers to gather domain expertise
•Elaborate and validate internal quality procedures, compliant with standards (ISO 17020)
Pre-assessmen
t Phas
e
•Select and prioritise functions / processes to be assessed (set of criteria / IHE profiles) applicable across Europe
•Consider feasibility with suppliers and users
•Create appropriate documentation regarding each of the criteria and the testing procedure
•Manage Q & A and "interpretations"
•Select CAB (Conformity Assessment Body)
Assessme
nt Phas
e
•Install logistics (inscription, financial aspects,..)
•Define "test scenario's"
•Develop assessment tools
•Evaluate test scenario's on feasability and appropriatness
•Assess the applications
•Document comformity or non confirmity to the individual criteria or to the profile
Granting & Maintaining the
Label /
Certificate
•Decide on granting or not granting the label or certificate
•Document motivation and archive assessment documentation
•Enable "appeal" and "restesting" sessions
53
Roll-out of Quality Labelling & Certification
Mandatory
Voluntary
Incentivised
Brussels, March 30, 2012
54
Mandatory CertificationAdvantages
Less important to consider feasibility. Less efforts required for consensus building with users and suppliers.Easier to implement a long term strategy for authority and for suppliers.
ProblemsOnly possible when use of EHR is made mandatory.Authority needs to have the means of its ambition.Defensive suppliers contesting ‘interpretations’ of the criteria.May reduce competition and innovation.
Brussels, March 30, 2012
55
Voluntary quality labelling & certificationAdvantages
Based on a consensus between different stakeholders.Less “contestation”.Shared cost has more chance to be accepted.
ProblemsSlower take-up and still non-certified products on the market. Risk that the actual results will falter.Long and fastidious negotiations regarding requests from users and/or authorities.Long and stepwise approach.Weakest partners may hamper progress.
Brussels, March 30, 2012
56
Incentivised model
Best of two worlds… empowerment of the user.Advantages
Involvement of all stakeholdersWin-win for all stakeholders
ProblemsImportant involvement of authorities granting incentivesImportant pre-assessment efforts.
Brussels, March 30, 2012
57
Functionality & Interoperability
Brussels, March 30, 2012
58
Cooperation: eHealth Quality Institute
To improve quality and efficiency of the processesTo align / link requirements formulation and documentationTo have full documentation availableTo centralise information on “certified” applications and componentsTo invest in toolsTo favour trans-European certification through recognitionTo increase independence from providers and users
Brussels, March 30, 2012
59
European Dimension ?
Healthcare remains national competence.Dual approach only realistic:
Extended National CertificationIncremental upgrade of cross-border initiatives
Recognition of national certificatesEuropean “incentives” for using certified systems
Brussels, March 30, 2012
60
Recommendations from the Roadmap
Brussels, March 30, 2012
1. Business aspects2. Main Risks3. Recommendations4. Conclusions
61
Business DefinitionDefining and rolling-out a / ONE common business opportunity is very hypothetic:
Different approaches (authority driven versus market driven).Different options and content (criteria) in the different countries.Market driven initiatives each on a different track.Impossible to receive information from the commercial initiatives.
Market potential for EuroRec and IHE described in Del. D5.2
Brussels, March 30, 2012
62
Budget for maintaining infrastructure
Brussels, March 30, 2012
Budget for completion of the translation of the actual repository
Number of languages
Cost per language
Total
Completing actual sets of translations 20 15.000 300.000
New Languages 5 20.000 100.000
Coordination and Consistency Management 25 5.000 125.000
525.000
Supporting integration of national specific variants
Defining the national variants and translating them 30 5.000 150.000
Coordination and Consistency Management 30 2.500 75.000
225.000
Annual Maintenance Costs
Number of languages
Cost per language
Total
Maintenance of the translated statements 25 5.000 125.000
Coordination and Consistency Management 25 2.500 62.500
187.500
Expanding the repository to be more comprehensive (3.000 statements)
Central Repository Maintenance and Expansion 225.000
Translating to the different languages 25 15.000 375.000
600.000
63
Sustainability of national certification
Create a relation of trust and partnership between authorities, users and industry. Increase economic viability of the suppliers by supporting the use of certified EHR systems and stimulating defragmentation of the market. Costs need to be shared between health authorities and the industry, industry e.g. paying only the effective testing / assessment.
Brussels, March 30, 2012
64
Sustainability of national certification
Develop and support a common “language” to describe functional requirements in a comparable way: national repository of reusable statements publicly available. Functional assessment and “interoperability” assessment should be offered by a recognised Health IT Quality Institute.
Brussels, March 30, 2012
65
Main Risks identified
1. Lack of any decision to go for quality labelling and certification.
2. Insufficient resources to invest in certification bodies, CABs and in favouring the use of certified EHR systems.
3. Market fragmentation due to national / regional healthcare delivery systems, regulations and the multi-professional and multi-lingual European reality => limited resources.
Brussels, March 30, 2012
66
Main risks
4. Nationally defined functional and data exchange related criteria to be avoided, when possible.
5. Actual cross-border health-IT is dominated by solution provider for “technical” departments and services. Insufficient to guarantee quality expressed in reliability, trustworthiness and appropriateness of the content.
6. Balkanisation and commercialisation.
Brussels, March 30, 2012
67
Recommendations• Legal and regulatory framework
• Create and harmonise the legal and regulatory framework stimulating national or regional authorities to enforce the use of quality labelled and certified applications.
• Clarify the role of Directive 2007/47/EC regarding software development aspects, EHR functional aspects and Data-Exchange related issues
• Involvement of stakeholders• Certification bodies should be accredited and compliant to
international standards, more precisely ISO 17020.• Favour cooperation between all service providers active in
different areas of quality labelling and certification of EHR systems: administrative data exchange, clinical data exchange and system functionality.
• Create an advisory platform involving all stakeholders to agree on content and feasibility of requirements.
Brussels, March 30, 2012
68
Recommendations (2)• Technical Framework
• It is highly recommended to strengthen the European scale pioneering initiatives (EuroRec / I.H.E) in order to keep certification on the agenda.
• Invest in maintenance and expansion of the actual descriptive statements and profiles towards more completeness and towards including more “domain- or profession-specific sets”.
• Address the issue of personnel shortage in health informatics in general and more specifically in health informatics quality assessment.
Brussels, March 30, 2012
69
Recommendations (3)
• Quality labelling and certification process
Third party assessment is the most suitable procedure for the still immature market of EHR systemsIt is strongly recommended to start “small”, to evaluate effectiveness and to increase focus step by stepThe incentivised model seems the most promising, surely for self-employed healthcare professionals
Brussels, March 30, 2012
70
Recommendations: cross-borderQuality labels and certificates are primarily national. Strengthen national certification in order to improve average quality and to enable in a second step the Trans-European harmonisation, improving comparability and portability of content. The EuroRec statements facilitate cross-border and cross-domain functional certification of EHR systems. It would be a pity not to use these opportunities. The IHE profiles are in principle country-independent and are used as European Profiles for data-exchange.
Brussels, March 30, 2012
71
Cross-border recommendationsPromote equivalence of certificates across Europe by validating at European level both the functional descriptive statements of EuroRec and the IHE profiles. Enforce portability of quality assessment labels and certificates across the Union. Consider the possibility to create a cross-border “Register of Quality Labelled or Certified Clinical Software”, offering information about the products (complete EHR systems as well a software modules) and documentation about the certification process.
Brussels, March 30, 2012
72
Quality Labelling and Certification Procedures: the quality of the process
Brussels, March 30, 2012
73
Deliverable D6.2
Documents quality requirements / applicable standards to quality labelling and certification.Describes the distinct roles of the initiator / authority, the certification body, the accreditation body and the conformity assessment body.Describes in detail the assessment and the granting phase as described in the roadmap deliverable.
Brussels, March 30, 2012
74
Applicable standards
Brussels, March 30, 2012
Stakeholder Applicable ISO/IEC StandardAccreditation Body ISO/IEC 17011:2004
ISO 9000:2000ISO/IEC 17000:2004VIM:1993
Certification Body ISO/IEC Guide 65Conformity Assessment Body ISO/IEC 17025:2005
[1] General requirements for accreditation bodies accrediting conformity assessment bodies (ISO/IEC 17011:2004)- Quality management systems – Fundamentals and vocabulary (9000:2000)[2] Conformity assessment – Vocabulary and general principles (ISO/IEC 17000:200)[3] International vocabulary of basic and general terms in metrology (VIM:1993)[4] General requirements for bodies operating product certification systems (ISO/IEC Guide 65)[5] General requirements for the competence of testing and calibration laboratories (ISO/IEC 17025:2005)
75
A reminder…
Brussels, March 30, 2012
Certification body
CAB
InitiatorIAF
Product
Supplier Authority
Accreditation body
Certificate
Label
ISO/IEC 17020 =>
<= ISO/IEC 17011
ISO/IEC 17025 =>
76
Accreditation Bodies
Standard (17011:2004) addressesLegal responsibilityStructureImpartialityConfidentialityLiability and FinancingAccreditation activitiesGeneral procedures (application, …)Management of non-conformitiesInternal audits…Human resources
Describes the responsibilities of accreditation bodies, certification bodies and conformity assessment bodies
Brussels, March 30, 2012
77
Certification Bodies
ISO/IEC Guide 65 outlines the following aspectsGeneral provisionsOrganisational and operational aspectsSubcontractingQuality system in placeProcedural aspects about granting, maintaining, extending, suspending and withdrawing a certificateInternal auditsDocumentationRecord keepingConfidentialitySpecific quality criteria regarding the personnel
Brussels, March 30, 2012
78
Certification Bodies (2)
Other topics addressed in the ISO GuideWay to deal with changes in certification requirementsAppealsProcedures for complaints, appeals and disputesProcedure for the certification applicationHow to prepare the evaluationThe evaluation itselfDecision making on the certificationSurveillance aspectsUse of licenses, certificates and other marks
Brussels, March 30, 2012
79
CAB – Conformity Assessment Bodies
ISO/IEC 17025:2005 General requirements for the competence of testing and calibration laboratoriesAddresses 5 major topics
Scope of the standardNormative referencesTerms and definitionsManagement requirementsTechnical requirements
Brussels, March 30, 2012
80
Actual Status
Accreditation is “national” => cross-border activities are formally excludedmain issues still to be addressed:• Independence• Split between CB and CAB
National initiativesAccreditation body seems to be active in FranceBelgium, Serbia, Ireland… clear split CB/CABOther countries: authority defining scope, testing and granting the certificate
Brussels, March 30, 2012
81
Assessment & Granting Phase
Brussels, March 30, 2012
82
Assessment Phase
Test Bed (environment, test population, test patient)Test Scenarios and Test ScriptsAssessment toolsEvaluation feasibility & appropriatenessLogistics, mainly the service agreementAssess the applicationDocumenting conformity & non- conformity to the criteria
Brussels, March 30, 2012
83
Granting Phase
Decision (by the certification body)MotivationArchive assessment documentationAppeal and RetestingValidity of Label or Certificate (version…)Withdrawal of Label or CertificatePreparing the future
Brussels, March 30, 2012
84
Documenting actual certification
The deliverable documents the authority driven national certification procedure(s) in
AustriaBelgiumDenmarkFranceIreland PortugalSerbia
Brussels, March 30, 2012
85
For each country we documentedWho initiates / initiated the process of certification?Legal or Regulatory context, if anyDomain addressed by the national certificationIs the certification compulsory, optional and/or incentivisedInvolvement of different stakeholdersNational scenario(s)Effectively granting the CertificateAppeal proceduresPossible contractual commitments related to the Quality Labelling and Certification
Brussels, March 30, 2012
86
Documenting actual quality labelling
The deliverable documents the market driven cross-border quality labelling procedure(s) as implemented by:
EuroRecI.H.E.Continua Health Alliance
Brussels, March 30, 2012
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For each initiative we documented
Who initiates / initiated the process of certification?Legal of Regulatory context, if anyDomains addressed by the quality labelIs there any incentive favouring the quality labelling?Involvement of different stakeholdersImplemented scenario(s)Effectively granting the Quality LabelAppeal proceduresPossible contractual commitments related to Quality Label or Certificate
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Global Comparison
Global comparison made by the University of Victoria between:
The Certification Commission for Healthcare Information Technology (CCHIT) – United StatesDepartment of Health and Human Services (HHS) – United StatesISO/IEC 15408 – The Common Criteria for Information Technology Security EvaluationThe European Institute for Health Records (EuroRec)Health on the Net foundation (HON)Canada Health Infoway (Infoway)The Australian National E-Health Transition Authority (NEHTA)
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What has been compared?
• Service category• Quality objectives(accountability, identifying
purpose, consent, limiting collection, limiting use, disclosure, retention, accuracy, safeguards, openness,
individual access, challenging compliance) • Focus of conformance assessment• Certification body (administration, independencde,
impratiality, integrity, quality system, accreditation, complaints & appeal)
• Methods and procedures
• Certificate (assessment details, expiration, re-certification, warranty..)
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EuroRec : Certification Body
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HHS: Certificate related
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Recommendations (about the process)
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•Discretion and Confidentiality
•Impartiality
•Openness
•Distinct roles involved organisations
Independence
•Initial Documentation
•Rules of Evaluation
•Testing Documentation
Documentation of the process
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Recommendations (about the process)
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•Involvement of all stakeholders
•Distinguish generic and domain specific
•Consider national / regional variants
Content to be validated /
tested
•Precise unambiguously the version of the SW
•Limit the validity to intended user group(s)
•Limit validity to region or country (if applic.)
Limitations of Certificate or
Label
•Pay attention to effective use to realise full added value
Effective Use
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What could the future bring?
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Certification
Authority driven certification will progress progressively:
because quality only now becomes an issuebecause the authorities want to influence the products
There is a risk that these efforts aren’t
coordinated and comparablere-usable outside country of certification
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Quality Labelling & Quality Mark
Border-independent and on initiative of the supplierQuality Mark for products:
established practice and related businessnot independent but it works
Quality Labelprogress slowly (free to candidate for it)(never) comprehensiveSMEs are a problem
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Main risk
Americanisation:One single countryRules issued endorsed by the authoritiesResources available to “influence” the market
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Conclusions
The project clearly contributed to increased awareness about QL&C amongst specialised industry, health professionals and health authorities.Certification is in the lift (> 10 countries)
In principle national and authority drivenStill fragmented and not (very) comparableCovers functionality and data exchange
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Conclusions
Market driven QL is the current approach for cross-border quality assessment. This should be supported, independent and freely accessible.Market driven QL services are offered mainly by three organisations addressing different aspects :
• Functional quality of the (professional) applications
• Ability to exchange (emit and receive) content• Portability (and safety) of device outcome
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Conclusions
Functional certification should be comparable and documented in the same way across borders by using an EHR functional descriptive language. Comparable national certification leads towards an increased harmonisation of the applications and facilitates interoperability.One-stop shopping regarding both data exchange and functionality quality labelling could boost the quality labelling and certification activities.
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Thank You...