ONC HIT Certification Program Test Results
Transcription
ONC HIT Certification Program Test Results
Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 ONC HIT Certification Program Test Results Summary for 2014 Edition EHR Certification Part 1: Product and Developer Information 1.1 Certified Product Information Product Name: Falcon Product Version: 2.35.0 Domain: Ambulatory Test Type: Modular EHR 1.2 Developer/Vendor Information Developer/Vendor Name: Falcon, LLC. Address: 1551 Wewatta St. Denver CO 80202 Website: www.falconehr.com Email: [email protected] Phone: 303.681.7226 Developer/Vendor Contact: Laura Whalen Page 1 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 Part 2: ONC-Authorized Certification Body Information 2.1 ONC-Authorized Certification Body Information ONC-ACB Name: Drummond Group Address: 13359 North Hwy 183, Ste B-406-238, Austin, TX 78750 Website: www.drummondgroup.com Email: [email protected] Phone: 817-294-7339 ONC-ACB Contact: Bill Smith This test results summary is approved for public release by the following ONC-Authorized Certification Body Representative: Bill Smith ONC-ACB Authorized Representative Function/Title 6/4/14 Signature and Date 2.2 Certification Committee Chair Gap Certification The following identifies criterion or criteria certified via gap certification §170.314 x (a)(1) (a)(17) x (d)(5) x (a)(6) (b)(5)* x (d)(6) x (a)(7) (d)(1) x (d)(8) x (d)(9) x (f)(1) *Gap certification allowed for Inpatient setting only No gap certification Page 2 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 2.3 Inherited Certification The following identifies criterion or criteria certified via inherited certification §170.314 (a)(1) (a)(14) (c)(3) (f)(1) (a)(2) (a)(15) (d)(1) (f)(2) (a)(3) (a)(16) Inpt. only (d)(2) (f)(3) (a)(4) (a)(17) Inpt. only (d)(3) (f)(4) Inpt. only (a)(5) (b)(1) (d)(4) (a)(6) (b)(2) (d)(5) (f)(5) Optional & Amb. only (a)(7) (b)(3) (d)(6) (a)(8) (b)(4) (d)(7) (f)(6) Optional & Amb. only (a)(9) (b)(5) (d)(8) (g)(1) (a)(10) (b)(6) Inpt. only (d)(9) Optional (g)(2) (a)(11) (b)(7) (e)(1) (g)(3) (a)(12) (c)(1) (e)(2) Amb. only (g)(4) (a)(13) (c)(2) (e)(3) Amb. only x No inherited certification Page 3 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 Part 3: NVLAP-Accredited Testing Laboratory Information Report Number: KAM-060314-1867 Test Date(s): 06/06/13, 03/06/14, 06/03/14 3.1 NVLAP-Accredited Testing Laboratory Information ATL Name: Drummond Group EHR Test Lab Accreditation Number: NVLAP Lab Code 200979-0 Address: 13359 North Hwy 183, Ste B-406-238, Austin, TX 78750 Website: www.drummondgroup.com Email: [email protected] Phone: 512-335-5606 ATL Contact: Beth Morrow For more information on scope of accreditation, please reference NVLAP Lab Code 200979-0. Part 3 of this test results summary is approved for public release by the following Accredited Testing Laboratory Representative: Kyle Meadors ATL Authorized Representative Signature and Date 6/4/14 Test Proctor Function/Title Nashville, TN Location Where Test Conducted 3.2 Test Information 3.2.1 Additional Software Relied Upon for Certification Additional Software Surescripts Network for Clinical Interoperability Health Companion Applicable Criteria b.1, b.2, e.1 e.1 Functionality provided by Additional Software Direct HISP Portal Page 4 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 Additional Software Applicable Criteria Functionality provided by Additional Software No additional software required 3.2.2 Test Tools Version Test Tool Cypress x x 2.4.1 ePrescribing Validation Tool 1.0.3 HL7 CDA Cancer Registry Reporting Validation Tool 1.0.3 HL7 v2 Electronic Laboratory Reporting (ELR) Validation Tool 1.7 x HL7 v2 Immunization Information System (IIS) Reporting Validation Tool x HL7 v2 Laboratory Results Interface (LRI) Validation Tool 1.7 HL7 v2 Syndromic Surveillance Reporting Validation Tool 1.7 x Transport Testing Tool 178 x Direct Certificate Discovery Tool 2.1 1.7.1 No test tools required 3.2.3 Test Data Alteration (customization) to the test data was necessary and is described in Appendix [insert appendix letter] No alteration (customization) to the test data was necessary 3.2.4 Standards 3.2.4.1 Multiple Standards Permitted The following identifies the standard(s) that has been successfully tested where more than one standard is permitted Criterion # Standard Successfully Tested §170.204(b)(1) (a)(8)(ii)(A)(2) HL7 Version 3 Implementation Guide: URL-Based Implementations of the Context-Aware Information Retrieval (Infobutton) Domain §170.204(b)(2) HL7 Version 3 Implementation Guide: Context-Aware Knowledge Retrieval (Infobutton) Service-Oriented Architecture Implementation Guide Page 5 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 Criterion # Standard Successfully Tested x (a)(13) §170.207(a)(3) IHTSDO SNOMED CT® International Release July 2012 and US Extension to SNOMED CT® March 2012 Release §170.204(b)(1) (a)(15)(i) (a)(16)(ii) HL7 Version 3 Implementation Guide: URL-Based Implementations of the Context-Aware Information Retrieval (Infobutton) Domain x §170.204(b)(2) HL7 Version 3 Implementation Guide: Context-Aware Knowledge Retrieval (Infobutton) Service-Oriented Architecture Implementation Guide §170. 210(g) Network Time Protocol Version 3 (RFC 1305) Network Time Protocol Version 4 (RFC 5905) The code set specified at 45 CFR 162.1002(c)(2) (ICD-10CM) for the indicated conditions §170.207(i) (b)(7)(i) HL7 Version 3 Standard: Clinical Genomics; Pedigree §170.210(g) §170.207(i) (b)(2)(i)(A) §170.207(j) The code set specified at 45 CFR 162.1002(c)(2) (ICD-10CM) for the indicated conditions x §170.207(a)(3) IHTSDO SNOMED CT® International Release July 2012 and US Extension to SNOMED CT® March 2012 Release x §170.207(a)(3) IHTSDO SNOMED CT® International Release July 2012 and US Extension to SNOMED CT® March 2012 Release Annex A of the FIPS Publication 140-2 (e)(1)(i) [list encryption and hashing algorithms] AES SHA-1 (e)(1)(ii)(A)(2) §170.210(g) Network Time Protocol Version 3 (RFC 1305) x §170. 210(g) Network Time Protocol Version 4 (RFC 5905) Annex A of the FIPS Publication 140-2 (e)(3)(ii) [list encryption and hashing algorithms] AES SHA-1 §170.207(a)(3) Common MU Data Set (15) IHTSDO SNOMED CT® International Release July 2012 and US Extension to SNOMED CT® March 2012 Release x §170.207(b)(2) The code set specified at 45 CFR 162.1002(a)(5) (HCPCS and CPT-4) Page 6 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 Criterion # Standard Successfully Tested None of the criteria and corresponding standards listed above are applicable 3.2.4.2 Newer Versions of Standards The following identifies the newer version of a minimum standard(s) that has been successfully tested Newer Version Applicable Criteria No newer version of a minimum standard was tested 3.2.5 Optional Functionality Criterion # x (a)(4)(iii) Optional Functionality Successfully Tested Plot and display growth charts (b)(1)(i)(B) Receive summary care record using the standards specified at §170.202(a) and (b) (Direct and XDM Validation) (b)(1)(i)(C) Receive summary care record using the standards specified at §170.202(b) and (c) (SOAP Protocols) (b)(2)(ii)(B) Transmit health information to a Third Party using the standards specified at §170.202(a) and (b) (Direct and XDM Validation) (b)(2)(ii)(C) Transmit health information to a Third Party using the standards specified at §170.202(b) and (c) (SOAP Protocols) (f)(3) Ambulatory setting only – Create syndrome-based public health surveillance information for transmission using the standard specified at §170.205(d)(3) (urgent care visit scenario) Common MU Data Set (15) Express Procedures according to the standard specified at §170.207(b)(3) (45 CFR162.1002(a)(4): Code on Dental Procedures and Nomenclature) Common MU Data Set (15) Express Procedures according to the standard specified at §170.207(b)(4) (45 CFR162.1002(c)(3): ICD-10-PCS) No optional functionality tested Page 7 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 3.2.6 2014 Edition Certification Criteria* Successfully Tested Criteria # Version TP** TD*** Criteria # Version TP TD (c)(3) 1.6 (d)(1) 1.2 (a)(1) 1.2 x (a)(2) 1.2 x (a)(3) 1.2 1.4 x (d)(2) 1.4 x (a)(4) 1.4 1.3 x (d)(3) 1.3 x (a)(5) 1.4 1.3 x (d)(4) 1.2 (a)(6) 1.3 1.4 (d)(5) 1.2 (a)(7) 1.3 1.3 (d)(6) 1.2 x (a)(8) 1.2 (d)(7) 1.2 x (a)(9) 1.3 1.3 (d)(8) 1.2 x (a)(10) 1.2 1.4 (d)(9) Optional 1.2 x (a)(11) 1.3 x (e)(1) 1.7 1.4 x (a)(12) 1.3 x (e)(2) Amb. only 1.2 1.5 x (a)(13) 1.2 x (e)(3) Amb. only 1.3 x (a)(14) 1.2 (f)(1) 1.2 1.2 x (a)(15) 1.5 (f)(2) 1.3 1.7.1 (a)(16) Inpt. only 1.3 (f)(3) 1.3 1.7 (a)(17) Inpt. only 1.2 (f)(4) Inpt. only 1.3 1.7 x (b)(1) 1.6 1.3 x (b)(2) 1.4 1.5 (f)(5) Optional & Amb. only 1.2 1.2 x (b)(3) 1.4 1.2 x (b)(4) 1.3 1.4 (f)(6) Optional & Amb. only 1.3 1.0.3 x (b)(5) 1.4 1.7 (g)(1) 1.6 1.8 (b)(6) Inpt. only 1.3 1.7 x (g)(2) 1.6 1.8 x (b)(7) 1.4 1.5 x (g)(3) 1.3 x (c)(1) 1.6 1.6 x (g)(4) 1.2 x (c)(2) 1.6 1.6 1.5 x x x 1.2 1.6 No criteria tested *For a list of the 2014 Edition Certification Criteria, please reference http://www.healthit.gov/certification (navigation: 2014 Edition Test Method) **Indicates the version number for the Test Procedure (TP) ***Indicates the version number for the Test Data (TD) Page 8 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 3.2.7 2014 Clinical Quality Measures* Type of Clinical Quality Measures Successfully Tested: Ambulatory x Inpatient No CQMs tested *For a list of the 2014 Clinical Quality Measures, please reference http://www.cms.gov (navigation: 2014 Clinical Quality Measures) CMS ID Version CMS ID 2 x 22 v2 50 x x Ambulatory CQMs Version CMS ID 90 136 117 137 122 v2 x 138 Version CMS ID Version 155 x v2 156 v2 157 52 123 139 158 56 124 140 159 61 125 141 160 62 126 142 161 64 127 143 128 144 129 145 x 165 v2 x 166 v3 65 v3 66 x 163 164 x 68 v3 130 146 x 69 v2 131 147 167 74 132 148 169 75 133 149 177 153 179 154 182 77 x 82 CMS ID 134 135 Version CMS ID v2 Inpatient CQMs Version CMS ID v2 Version CMS ID 9 71 107 172 26 72 108 178 30 73 109 185 31 91 110 188 32 100 111 190 53 102 113 55 104 114 60 105 171 Version Page 9 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 3.2.8 Automated Numerator Recording and Measure Calculation 3.2.8.1 Automated Numerator Recording Automated Numerator Recording Successfully Tested (a)(1) (a)(9) (a)(16) (b)(6) (a)(3) (a)(11) (a)(17) (e)(1) (a)(4) (a)(12) (b)(2) (e)(2) (a)(5) (a)(13) (b)(3) (e)(3) (a)(6) (a)(14) (b)(4) (a)(7) (a)(15) (b)(5) x Automated Numerator Recording was not tested 3.2.8.2 Automated Measure Calculation Automated Measure Calculation Successfully Tested x (a)(1) x (a)(9) (a)(16) (b)(6) x (a)(3) x (a)(11) (a)(17) x (e)(1) x (a)(4) x (a)(12) x (b)(2) x (e)(2) x (a)(5) x (a)(13) x (b)(3) x (e)(3) x (a)(6) x (a)(14) x (b)(4) x (a)(7) x (a)(15) x (b)(5) Automated Measure Calculation was not tested 3.2.9 Attestation Attestation Forms (as applicable) Appendix x Safety-Enhanced Design* A x Quality Management System** B x Privacy and Security C *Required if any of the following were tested: (a)(1), (a)(2), (a)(6), (a)(7), (a)(8), (a)(16), (b)(3), (b)(4) **Required for every EHR product 3.3 Appendices Attached below. Page 10 of 11 Test Results Summary for 2014 Edition EHR Certification Version EHR-Test-144 Rev 17-Feb-2014 Test Results Summary Document History Version 17-Feb-2014 Description of Change Edited: section header page 3; contact info page 4 Date 17-Feb-2014 10-Feb-2014 Modified layout 10-Feb-2014 20-Nov-2013 Updated test tool sections 20-Nov-2013 25-Oct-2013 Corrected numbering of 3.2.8 section 25-Oct-2013 15-Oct-2013 Modified layout slightly 15-Oct-2013 01-Oct-2013 Initial Version 01-Oct-2013 2014 Edition Test Report Summary Page 11 of 11 UX Design & Falcon EHR 7.1.2013 User experience design (UXD) is an approach to the design of products and services that looks beyond the design of the artifacts itself to the experience that it creates for the people who use it. UXD incorporates an understanding of human psychology and human behavior into the products we create. Hypothesis We start with an idea about what we are trying to accomplish in the context of a project. This is a high-level, supposition, “We think that these users want to do something so that…” This could be a problem to be solved, supporting a job to be done, etc. The ideas come from many different sources including, customer feedback, sales, marketing, product, development, client services, regulatory, etc. Concept We conduct user research (interviews, surveys, focus groups) to better understand the problem to be solved or the job to be done. We define and describe the people who we are solving the problem for. We define why it’s a problem in the first place. We define the context of use, which is an important consideration when designing a solution. We define how they are currently getting things done without the solution (if they are). We shadow users to understand how they are using the system and what unarticulated issues they may be running into. We include ideas about solutions we think may solve the problem. We frame the usability metrics, if applicable. For example, in one project, the goal was to be able to create a patient note in a single click. We may include information on what competitors are doing or how unrelated, external software is solving a similar problem in another field. We may benchmark usability metrics of the current software, (such as how long it takes users to accomplish certain tasks) in order to demonstrate that our eventually solution improved the efficiency, effectiveness, and satisfaction of these tasks. Design The designer assigned to the project will wireframe potential solutions based on the concept. We ideate multiple, different solutions and test them with users as well validate their feasibility internally. Based on their feedback, we merge these solutions into a single design, which is created in a high fidelity, functional prototype. The prototype is then validated internally. Internal reviews happen with the development team to ensure that the proposed solution is possible. Development will also provide design inputs if they have ideas about how certain things can/should work. We then set up a series of usability studies to test the prototype with customers. In the studies, we ask the users to perform a series of tasks that we know they are trying to accomplish with the software. We observe how they use the prototype, where they succeed, and more importantly, where they struggle. We alter the design based on our observations during the studies. This cycle of iteration can happen once or many times depending on the problem we are trying to solve and the complexity associated with it. Example Design 1 Example Design 2 Example Design 3 Merged Design, based on usability studies The output of these activities is lean documentation of the solution in a User Story. Build We work with our developers on a daily basis to build out the solution in the real application. We provide daily design direction and work through any issues or complications that arise as the design becomes reality. We create an implementation plan and communicate the product changes internally and externally. We collect user feedback one final time once the design has been implemented in the real application, before it has been released to the entire user base. We may make small adjustments based on this feedback, if applicable. We then release the finished solution to our customers. We may conduct additional usability studies with the implemented design a few months after it has been released. The purpose of these studies is to collect usability metrics such as task time and compare them to our previous benchmark, so that we understand if we are making the software more efficient to use. EHR Usability Test Report of Falcon version 2.35.0 Falcon version 2.35.0 Date of usability test: Specific dates for each section provided within. Date of report: May 18, 2014 Report prepared by: Falcon Product Team Table of Contents Executive Summary.........................................................................................................................2 Introduction ....................................................................................................................................2 Method ..................................................................................................................................................2 Tasks ......................................................................................................................................................3 Procedure ..............................................................................................................................................3 Test Location & Environment.................................................................................................................4 Test Forms and Tools .............................................................................................................................4 Participant Instructions ..........................................................................................................................4 Usability Metrics ....................................................................................................................................5 DATA SCORING...................................................................................................................................5 Specific Test Process/Results by Section .........................................................................................5 170.314.a.1 Computerized provider order entry ...................................................................................6 170.314.a.2 Drug-drug, drug-allergy interaction checks ........................................................................7 170.314.a.6 Medication list ...................................................................................................................8 170.314.a.7 Medication allergy list ........................................................................................................9 170.314.a.8 Clinical decision support ..................................................................................................10 170.314.b.3 Electronic prescribing.......................................................................................................11 170.314.b.4 Clinical information reconciliation ...................................................................................12 Executive Summary Usability tests of Falcon version 2.35.0 were conducted on a variety of dates by the Falcon product team. The purpose of these tests was to test and validate the usability of the current user interface, and provide evidence of usability in the EHR Under Test (EHRUT). During the usability test, healthcare providers matching the target demographic criteria served as participants and used the EHRUT in simulated, but representative tasks. The specific participation numbers are provided in the sub sections below. This study collected performance data on a number of relevant tasks typically conducted on an EHR. The process, content, and results for each functional area are outlined within each sub section. Participants all had prior experience with the EHR. In all cases, the administrator introduced the test, and instructed participants to complete a series of tasks (given one at a time) using the EHRUT. During the testing, the administrator timed the test and, recorded user performance data. The administrator did not initially give the participant assistance in how to complete the task. Introduction The EHRUT tested for this study was Falcon version 2.35.0. Designed to present medical information to healthcare providers in their offices and in dialysis centers, the EHRUT consists of a web based platform and a mobile platform. The usability testing attempted to represent realistic exercises and conditions. The purpose of these studies was to test and validate the usability of the current user interface, and provide evidence of usability in the EHR Under Test (EHRUT). To this end, measures of effectiveness, efficiency and user satisfaction, such as time to complete task, errors in completing task, were captured during the usability testing. Method Current customers were contacted to participate in the studies. In some cases, the customers had volunteered in advance for potential participation. Participants were chosen to represent a variety of key characteristics (practice size, EHR experience) that would be important in extending findings to the user base. Study Design Overall, the objective of this test was to uncover areas where the application performed well – that is, effectively, efficiently, and with satisfaction – and areas where the application failed to meet the needs of the participants. The data from this test may serve as a baseline for future tests with an updated version of the same EHR and/or comparison with other EHRs provided the same tasks are used. In short, this testing serves as both a means to record or benchmark current usability, but also to identify areas where improvements must be made. Each participant used the system in the same location, and was provided with the same instructions. The system was evaluated for effectiveness, efficiency and satisfaction as defined by measures collected and analyzed for each participant: • • • • • Number of tasks successfully completed within the allotted time without assistance Time to complete the tasks Number and types of errors Participant’s verbalizations (comments) Single Ease Question (SEQ) which we use to measure satisfaction Tasks A number of tasks were constructed that would be realistic and representative of the kinds of activities a user might do with this EHR; tasks specific to each section are outlined within the content below. The selection and definitely of tasks was done in collaboration with the users. We prioritized tasks based on prominence in workflow and risk associated with possible user errors. Further, we prioritized the steps in the tasks (the user’s path) based on the most error prone path. If errors exist within any of the critical modules, we will assess risk against the prioritized list below. Priority 1 2 3 4 5 6 7 Falcon Prioritization of Modules Module Name CPOE Medication List Electronic Prescribing Medication Allergy List Drug-to-Drug/Drug Allergy Test Clinical Information Reconciliation Clinical Decision Support Procedure At the scheduled time, the facilitator dialed into the conference line and webex meeting. The participant did the same. The facilitator thanked the participant for their participation and described the tasks that they would like the participant to complete for each section. The facilitator explained the purpose of the usability test, asked the participant to think out loud, as this will give the facilitator and his/her team better insight into how the participant understands the user interface. The facilitator explained that he/she may not answer the participant’s questions during the test, because one of the goals of the session is to ensure that the participant can use the software when someone is not there to help. The facilitator moderated the session including administering instructions and tasks. The facilitator also monitored task times and took notes on participant comments and performance/behavior. Task timing began once the administrator finished reading the question and gave the participant control of the system via WebEx. The task time was stopped once the participant had successfully completed the task, as determined by predefined success criteria. Scoring is discussed below. Following the session, the facilitator thanked each individual for their participation. Participants', task success rate, time on task, errors, SEQ, and comments were recorded into a spreadsheet. Test Location & Environment All testing was conducted virtually, via phone and WebEx meeting. The participants used mouse and keyboard when interacting with the EHRUT. Technically, the system performance (i.e., response time) was representative to what actual users would experience in a field implementation. Test Forms and Tools During the usability test, various documents and instruments were used, including: Predefined taskscenarios which are created to be representative tasks in the system. A timing application on iPhone/iPad was used to record time on task. The participant’s interaction with the EHRUT was captured and recorded digitally with WebEx tools. Participant Instructions The administrator reads the following instructions aloud to the each participant: • Brief explanation of the purpose of the test – find usability problems – access satisfaction with the design • We are going to ask you to run through a couple of scenarios, I’ll read each scenario to you and then ask to you being. After the scenario is completed, we will ask you to rate the scenario based on how easy or difficult you felt the scenario was, 1-7. • It’s important to note that we are testing the software, not you! Any problems or difficulties you encounter are due to poor design and not anything that you are doing wrong. In fact, this is probably the only time today where you don’t have to worry about making any mistakes. • You are welcome to ask questions since we want to know what you find unclear in the interface, but we will not answer most questions during the test itself, since the goal of the test is to see whether the system can be used without outside help • Feel free think out loud – this helps us understand how you view the system and makes it easier to identify usability errors • Please feel free to be honest, you won’t hurt our feelings and the purpose of this session to ensure the design works when actually used • Any questions before we begin? Usability Metrics The goals of the test were to assess: 1. Effectiveness of Falcon by measuring task-scenario completion percentage and recording number of errors 2. Efficiency of Falcon by measuring the average task time 3. Satisfaction with Falcon by measuring ease of use ratings, using the Single Ease Question (SEQ) DATA SCORING Effectiveness: Tasks were counted as being completed if the user could meet the task success criteria Task Success A task was counted as a “Success” if the participant was able to achieve the correct outcome, without assistance, within the time allotted on a per task basis. The total number of successes were calculated for each task and then divided by the total number of times that task was attempted. The results are provided as a percentage. Task Failures If the participant abandoned the task, did not reach the correct answer or performed it incorrectly, or reached the end of the allotted time before successful completion, the task was counted as a “Failure.” No task times were counted for failures. The total number of errors was calculated for each task. Task Time Each task was timed from when the facilitator passed control of the screen through WebEx until the participant had achieved the predefined completion criteria. Only task times for tasks that were successfully completed were included in the average task time analysis. Average time per task was calculated for each task. Variance measures (standard deviation and standard error) were also calculated. Satisfaction: After each task-scenario, the participant was asked, on a scale of 1-7, how difficult or easy was this task? 1 being very difficult, and 7 being very easy. Specific Test Process/Results by Section 170.314.a.1 Computerized provider order entry Participants • • • • • Physician 1 Physician 2 Physician 3 Physician 4 Physician 5 Date and location • June 24 – 28, remote conference call and WebEx Tasks • You need to order lab results for a patient. Order a lipid panel, hemoglobin and hematocrit test. Save & Print the order. Metrics • • • • Avg. Task Time: 159.24 Avg. Task Completion: 50% AVg. # of Errors: 1.83 SEQ: 3.7 Results • This task tested poorly, with only half of the users completing the task. The average task time was excessive considering the simple nature of the task. We found many areas of improvement. Findings • Please see areas of improvement Areas of improvement • • • When creating the order, the system defaults to a Diagnostic Order, and the user has to change the order type to a lab order. Several users became confused at this stage, and tried searching for lab tests to order in the diagnostic order screen, which accounts for the 50% task completion rate. Several lab tests that physicians routinely order are missing from the lab test list, leading to inefficient work-arounds The lack of an eSig function leads to inefficient practice workflow, because the physician must print and sign the order as opposed to just printing it • Some of the lab tests have esoteric names, which lead to difficulty in finding them. 170.314.a.2 Drug-drug, drug-allergy interaction checks Participants • • • • • Physician 1 Physician 2 Physician 3 Physician 4 Physician 5 Date and location • 3.11.2013-3.15.2013, Remote conference call and WebEx Tasks • • We observed providers as they prescribed medications that had various drug-drug and drugallergy interactions and solicited their feedback on the interactions they were presented. We asked users to adjust the severity of the drug-drug interactions that appeared Metrics • • • • Avg. Task time: 72.4 seconds Avg. Completion Rate: 40% Avg. # of Errors: 0.6 SEQ: 2.4 Results • • The most common compliant was the interactions were too frequent and/or too slow to appear when there was an interaction. The timing of displaying the interactions however was very natural for the providers, as soon as they select the drug to be prescribed, we show the interaction, and then allow them to override or select a different drug. Many users could not find the settings screen to adjust the severity of the drug-drug interactions. If they did find the screen, they were easily able to adjust the interaction levels accordingly. Findings • Please see areas of improvement Areas of improvement • The readability of the text for each interaction could be greatly improved • Many providers noted that the alerts are too frequent, even when turned down to the lowest setting 170.314.a.6 Medication list Participants • • • • • Physician 1 Physician 2 Physician 3 Physician 4 Physician 5 Date and location • 3.11.2013-3.15.2013, Remote conference call and WebEx Tasks • We focused this test on reviewing the medication list while charting a note on a patient. The goal was to see if the providers all the information they needed and if they had common tasks accessible to them. Metrics • • • • Avg. Task time: 37.8 Avg. Completion Rate: 100% Avg. # of Errors: 0 SEQ: 5.6 Results • Providers like having the ability to review medications while they chart their note on the patient. It makes it easy to make changes while they are in their workflow as opposed to making them travel to a different module in order to make changes. However there were several aspects of the list that they found lacking, as we discuss in the Areas of Improvement below. Findings • Please see Areas of Improvement Areas of Improvement • The “SIG” was placed to the right of the medication name, which reduced the overall readability of the medication • • • • While providers could “edit” medications, we lacked specific actions for common tasks such as refilling medications or dose changes Many providers requested that we show the allergies along with the medications on the medication list We lacked the ability to print the medication list from the medication list module, which was a sore spot among many providers Under the “Inactive” medications tab, we showed the medication start date as opposed to the medication stop date 170.314.a.7 Medication allergy list Participants • • • • • Physician 1 Physician 2 Physician 3 Physician 4 Physician 5 Date and location • 3.18.2013 – 3.22.2013, remote conference call and webex Tasks • We focused this test on reviewing the medication allergy list while charting a note on a patient. The goal was to see if the providers all the information they needed and if they had common tasks related to medication allergies accessible to them. Metrics • • • • Avg. Task time: 15.8 Avg. Completion Rate: 100% Avg. # of Errors: 0 SEQ: 6 Results • The allergy list module tested fairly well and is fairly straight forward. Providers liked the fact that we displayed the allergy, the type (e.g., medication, order, etc.), the severity, and the reaction. There were some deficiencies as noted in the areas of improvement section. Findings • Please see areas of improvement. Areas of improvement • • The check-box to signify “No Known Drug Allergies” was not present in the allergy list module When adding a medication allergy, we defaulted the selection to “Routed Drug”, however providers usually found it easier to search by “Drug Name”, e.g., Lipitor as opposed to Lipitor 40 MG 170.314.a.8 Clinical decision support Participants • • • • • Physician 1 Physician 2 Physician 3 Physician 4 Physician 5 Date and location • 3.18.2013 – 3.22.2013, remote conference call and webex Tasks • We asked providers to create CDS interventions using our customized alert module. We asked them to review interventions and discussed what they consider valuable. Metrics • • • • Avg. Task time: 214.2 seconds Avg. Completion Rate: 100% Avg. # of Errors: 0 SEQ: 4.2 Results • Providers found this feature very helpful. They enjoyed the customizable nature of the alerts, and specifically liked that the alerts could be turned on only for one provider at the practice instead of the entire practice. Findings • We did extensive testing on this feature prior to release. Our most pertinent finding was that in addition to user defined alerts, what really helps the providers is being able to relate certain medications and lab results to problems. So that when they are charting on that problem, they can review any medications or the latest lab results associated to that problem. Areas of improvement • N/A 170.314.b.3 Electronic prescribing Participants • • • • • Physician 1 Physician 2 Physician 3 Physician 4 Physician 5 Date and location • June 17 – June 21 2013, Remote conference call and WebEx Tasks • • • Your patient needs a new prescription for Lisinopril. ePrescribe your patient one, feel free to use your local pharmacy. Start: eCharting > Encounters End: User has ePrescribed the lisinopril Rx Metrics • • • • Avg. Task time: 59.15 seconds Avg. Completion Rate: 100% Avg. # of Errors: 0 SEQ: 5.0 Results While providers did not make any errors and were able to complete the task, we noticed many areas of improvement as noted below. Findings • Please see areas of improvements Areas of improvement • • Pharmacy Search – when searching by zip code, the search returns pharmacies in that zip code, but also returns pharmacies that had the search string in their phone number, which polluted the list and made finding a local pharmacy much more difficult Saving a default pharmacy – The function to save a default pharmacy to a patient’s chart is in another screen, so providers found it very difficult to update a default pharmacy when the patient changed pharmacies • • • Auto focus – When initiating the eRx, the cursor did not auto-focus into the search box, this adds an unnecessary click Quantity – The quantity of pills did not auto-calculate based on the instructions and the number of refills Allergies – While ePrescribing, the allergies were not viewable which sometimes forced the provider to stop the eRx workflow, and go back to the chart to review the patient’s allergies. 170.314.b.4 Clinical information reconciliation Participants • • • • • • Nurse 1 Nurse 2 Physician 1 Physician 2 Physician 3 Physician 4 Date and location • 9.18.2013 – 10.10.2013, Remote conference call and WebEx Tasks The goal of this workflow is to facilitate the clinical information reconciliation of structured medications, allergies and problems into a patient’s electronic medical record. This helps providers achieve an accurate list of these data elements. • • • • • Task 1 – Review and add a medication from a transition of care summary to the patient’s chart (exact match) Task 2 – Review and add a medication from a transition of care summary to the patient’s chart (one-to-many) Task 3 – Review and add an allergy from a transition of care summary to the patient’s chart Task 4 – Remove an allergy from the patient’s chart Task 5 – Review and add a problem from a transition of care summary to the patient’s chart Metrics • • • • Results Avg. Task time: 158.4 Avg. Completion Rate: 100% Avg. # of Errors: 0.4 SEQ: 6.2 Users were able to complete each task without error. It took users less than 5 seconds to complete tasks 1, 3 and 4. Tasks 2 and 5 took significantly longer to complete – up to 3 minutes. At times, the workflow was abandoned after starting tasks 2 and 5 because the provider did not know what to select from the list of many offerings or did not have adequate knowledge to select the correct value. • • • • • Overall, the workflows were well received and intuitive. Displaying medications, allergies and problems alphabetically helped users easily locate the data. Providers liked the fact that one or many providers could participate in this workflow at different times. Providers had a difficult time understanding what was added from the transition of care summary to the patient’s chart. Displaying the “source” was simply not enough. Providers were not aware that hovering over the patient’s name would progressively disclose patient demographics. Findings Providers receive anywhere from 1 to 5 referrals per week 60% of referrals come from a doctor’s office; 40% are from the hospital Today, transition of care documents are scanned into the patient’s chart. Medications, allergies, and problems may also be manually entered as structured data into the chart prior to a patient’s appointment by the medical assistant or nurse. Different members of the care team will review and reconcile the different lists. Medical Assistants and Nurses will most likely review and reconcile the medication and allergy lists, whereas physicians will review and reconcile the problem list. Several providers were disappointed that the discharge summary (inpatient) and the assessment/plan narrative was not required information in the transition of care CCDA. This “tells the story” of why the patient was hospitalized or why he or she was visiting a doctor. There is some value in knowing the source of the data after adding the information to the chart. Areas of improvement • • • • To reduce the cognitive load required to differentiate data added from the transition of care summary to the patient’s chart, we added a visual indicator next to the row. An “I” information icon was added after the patient name to provide affordance that patient demographic information could be found by hovering over the icon or name. Drug to drug/allergy/problem checks would be helpful in this workflow. We intend on adding this post certification. Not all information is parsed from the CCDA; therefore, we intend on providing a link to open/view the transition of care summary within this workflow post certification. Falcon EHR - Quality Management System Overview: We use the same homegrown QMS consistently across all modules of Falcon EHR. Below are the processes we use in the development, testing, implementation, and maintenance of each certification criteria. Development Systems Requirements and Design • Template and process for defining system requirements and design • Review and hand-off process to development and quality assurance team • Prototyping and physician advisory board review • Outlines sign-off requirements by key stakeholders Development • Development coding standards and best practices – “Falcon EHR Development Commandments” • Unit Testing and Code Review templates • Tool standards for IDE and debugging Configuration Management • Source control • Separation of duties for release management • Environment management • Pre-production testing requirements Testing (Quality Assurance) • • • • • Test case templates Defect management tool and process Prioritization definitions Defined Entry and Exit criteria User Acceptance Testing with end users Implementation • • • • User security and access management procedures Practice training and implementation guidelines Electronic help guides available in application Assigned Customer Account Managers Maintenance • • • • • Dedicated 24/7 Helpdesk with trained support specialists BMC Remedy tool SLA’s definitions for support tickets ITIL based processes and monitoring tools Emergency Bug Fix/Maintenance Release processes Attestation to QMS Report I, Kelly Port, attest that the above Quality Management System report is accurate in describing the approaches utilized by Falcon to ensure consistent quality and performance across all functions within our system. Signed: _______________________________________ Title: _Director_________________________________ Date: _5/29/2013_______________________________ Audit Attestations Test Requirement: DTR 170.314.d.2-4: Protect Audit Log Test Requirement: DTR 170.314.d.2-5: Detection of Audit Log Alteration This is a letter of attestation that identifies the method(s) by which Falcon EHR protects 1) recording of actions related to electronic health information, 2) recording of audit log status, and 3) recording of encryptions status) from being changed, overwritten, or deleted by the EHR technology. Copying Electronic Health Information Falcon EHR does not allow the user to copy a patient’s health information. We do allow the user to deactivate (delete), view, modify, and create the following elements, but we do not provide the functionality to copy them. We cannot think of a clinical scenario in which copying the following elements would be relevant to our users: • Problems • Medications • Allergies • Labs • Demographics In support of the clinical summary measure, Falcon does allow download and transmission of a patient’s encounter. In the clinical summary screen, the Recipient, Sender, Date, and indication of whether it was Printed or Emailed (with email address) is recorded. See screen shot below. Audit Attestations Audit Log Protection. Actions and statuses recorded in accordance with paragraph (d)(2)(i) must not be capable of being changed, overwritten, or deleted by the EHR technology. The audit screen within Falcon records actions related to create, view and modify transactions. The screen itself that displays the records of these actions is not editable. It is a view-only screen where audit transactions can be reviewed or monitored. See screen shot below. Audit Attestations Audit Log Status and Encryption Status The audit log for a physician practice is enabled by default within Falcon. As shown above, the screen does not allow a user to disable audit log status or disable encryption status. Detection. EHR technology must be able to detect whether the audit log has been altered. To meet the prevention requirement Falcon has implemented a trigger on the audit table that stores the audit transactions which prevents users from accessing or altering the table. If a user tries to access the table an exception is thrown. Falcon has opted for removing all potential access to the table versus implementing functionality to detect whether the audit log has been altered. In order to detect whether the audit log has been compromised, functionality has been implemented to record transactions (username, last setup and last change date-time) if any insert or updates were made to the audit log itself. Due to the trigger placed, the expectation is this log should have 0 transactions at any time. If any events get logged, the development team will be alerted and the username and transaction date-times will be reviewed to determine any breach that requires follow-up. Technical Spec Project Name: Falcon Device Data Encryption Table of Contents 1.0 Introduction .................................................................................................................................... 2 2.0 Falcon Core ..................................................................................................................................... 2 2.1 3.0 Architectural Principles & Technologies Employed ..................................................................... 2 Falcon Mobile.................................................................................................................................. 2 3.1 Architectural Principles ............................................................................................................... 3 3.2 Technologies Employed .............................................................................................................. 3 3.3 User Ability to Disable Encryption ............................................................................................... 4 4.0 Walkthrough of Encryption ............................................................... Error! Bookmark not defined. 4.1 Initiate a Session ........................................................................... Error! Bookmark not defined. 4.2 Examine stored data ..................................................................... Error! Bookmark not defined. Table of Figures Figure 1 - Excerpt from FIPS140-2 showing FIPS acceptance of Falcon Mobile's encryption algorithm...... 3 Figure 2 - App settings ................................................................................................................................ 4 Figure 3 - Falcon Mobile icon on iOS home screen ....................................... Error! Bookmark not defined. Figure 4 - Falcon Mobile home screen .......................................................... Error! Bookmark not defined. Figure 5 – Column structure of the PatientRoundingSchedules table .......... Error! Bookmark not defined. Figure 6 - Patient data is non-readable in the database ............................... Error! Bookmark not defined. DaVita Confidential February 5, 2011 Technical Spec Falcon Device Encryption Summary 1.0 Introduction Falcon supports two types of devices utilized by the end customer: personal computers and tablets. Our product offering and technology stack is described as Falcon Core which is employed by personal computers and Falcon Mobile employed by tablets. Falcon employs encryption processes and protocols to manage and protect patient data. The purpose of this document is to give the reader a detailed overview of the technologies employed and how those technologies work together to ensure that patient data is secure while housed on these end user devices. 2.0 Falcon Core As a standard practice, Falcon Core does not persist any PHI data on end user devices. Regardless, any data stored on the client is stored in a secure manner. 2.1 Architectural Principles & Technologies Employed Data stored is inherently de-identified, de-normalized and then encrypted using AES256 encryption. Data is never decrypted at rest and before data can be accessed it must be decrypted. Accessing decrypted data requires both an access username and access password. The encryption password as well as the access username and access password can be changed at will. Changing any one of these keys will cause all clients to delete their local data stores. By practice, the encryption password is changed with every code release – typically every two weeks. The encryption password, access username and access password is stored in the central database in a secure co-location facility which has limited access and follows DaVita access policies. The end user is not able to modify any of these settings. All data, including PHI data is encrypted during transmission ustin standard HTTPS protocols. 3.0 Falcon Mobile Falcon has invested capability in protecting patient data for our mobile product offering as PHI data is stored on the local device. Falcon Mobile is designed from the ground up to ensure that patient data is always encrypted and therefore secure to the degree possible using industry standard design patterns and technologies. 6/4/2014 DaVita Confidential Page | 2 Technical Spec Falcon Device Encryption Summary 3.1 Architectural Principles Falcon Mobile uses SQLite to store data onto a mobile device. In order to make this medium secure for storage of sensitive information include patient data, we have made the decision to keep all sensitive data (including patient identifying data) encrypted at all times. This includes times when the data would be considered to be “at rest”, but it also includes all times when the application is actually running. 3.2 Technologies Employed Falcon Mobile uses AES128 for encryption of all patient identifying data. Per Drummond Test Scenario 170.314.d.7, we have confirmed that the algorithm used is listed as “FIPS APPROVED” in FPIS140-2 ( see figure 1) Figure 1 - Excerpt from FIPS140-2 showing FIPS acceptance of Falcon Mobile's encryption algorithm 6/4/2014 DaVita Confidential Page | 3 Technical Spec Falcon Device Encryption Summary 3.3 User Ability to Disable Encryption Falcon Mobile does not give the end user any ability to disable encryption. It is always active for all users. Please see figure 2, which shows that there is no setting for adjusting the encryption. Figure 2 - App settings 6/4/2014 DaVita Confidential Page | 4