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523 N Sam Houston Pkwy Suite 125
Houston, TX 77060
USA

(866) 675-6277

Professional Imaging is the largest provider of consultations for swallowing disorders in the United States.  

Our objective to provide the most timely and in-depth medical evaluation based on the patient's needs.   

We take pride in offering the most comprehensive, patient-centered, on-site evaluations available in the medical community.  

Each Professional Imaging clinic is staffed with a licensed physician, a certified speech language pathologist, and a driver technician whom aids in transportation of patients to and from facilities.  The physician compiles a complete medical history of each patient by performing extensive chart review, interview of family, staff, or patient as appropriate. Once a patient’s case history is completed the doctor then performs a focus-expanded physical exam of the patient along with the radiographic MBSS in conjunction with the speech language pathologist. Upon completion of the consultation, recommendations are made to the primary care physician, facility SLP, and facility nursing staff.  

Not only will we provide efficient delivery of high quality services, but we will also be dedicated to treating each and every patient with dignity and respect.   We continually strive to be the leader in service providers of specialized dysphagia evaluations.

 

EHR Real World Testing Plan 2025

Professional Imaging, LLC

PI EMR v2 - CHPL ID 15.07.05.2835.PROI.01.01.1.230127

Developer Real World Test Plan URL:  https://www.proimagetx.com/ehr-real-world-testing-plan

2025 RWT Plan

This Real World Test Plan is ACB approved and the Plan ID # is 20241106pro.

 

 

Justification for Real World Testing Approach

 

The overall approach for our Real World Testing includes extraction and analysis of data regarding ongoing activity and simulated testing where there is no ongoing use of relevant certified functionality.

 

The PI EMR v2.0 Certified Health IT Module is self-developed. It is not available for sale. It is only used by Professional Imaging LLC and its affiliates.  As a self-developer with a very narrow practice scope, resources for implementing RWT must, by necessity, be limited to mitigate negative financial impact.

 

The care setting in which this module is used is an ambulatory interaction with Nursing Facilities. For some of the criteria covered in the Real World Testing plan, testing will be conducted using simulated environments utilizing a pass/fail metric due to the absence of real world use. The affected criteria in this regard are those related to Care Coordination, Public Health, Application Program Interfaces and Electronic Exchange. As there is no ongoing activity in these cases, it is not possible to measure ongoing compliance.

 

The circumstances for this are as follows:

  • As yet, no Nursing Facilities have requested use of the interoperability functionality being tested. This is due to the fact that Nursing Facilities are not required to use an EHR as doing so is not seen as a benefit.

  • No Nursing Facility, patient, patient representative or providing clinician has ever requested access to our API.

  • We are either unqualified for or unable to (due to unavailability of agencies prepared to receive the data) perform the activities covered by criteria related to Transmission to public health Agencies.

 

In the cases mentioned above, our Real World Testing approach measures success through demonstrating conformance and interoperability through simulated testing. Testing will be conducted to confirm and document that each data point transmitted and received is accurate and complete as required by the relevant certification criteria.

 

For certified functionality that we do have ongoing activity, the records of that activity will be analyzed regarding the successful transmission and receipt of relevant information. Documentation of that analysis will be provided.

 

The RWT plan may also utilize data transfer with an affiliate practice. The affiliate practice, which provides the same type of specialized service as Professional Imaging, has been selected due to their ongoing relationship with our practice and their availability for this testing.

 

Where applicable, several certification criteria may be tested simultaneously.

 

Criteria to be Tested

  • § 170.315(b)(1) Transitions of care

  • § 170.315(b)(2) Clinical information reconciliation and incorporation

  • § 170.315(b)(10) Electronic Health Information Export

  • § 170.315(e)(1) View, download, and transmit to 3rd party.

  • § 170.315(f)(2) Syndromic surveillance

  • § 170.315(f)(7) Health care surveys

  • § 170.315(g)(9) Application access— all data request

  • § 170.315(h)(1) Direct Project

 

Standards Updates

There have been no standards updates.

 

Schedule of Key Milestones

 

  • 1Q-2025: Begin communication with affiliate practice to schedule participation in real-world testing.

  • 2Q-3Q 2025: During the 2nd and 3rd quarter, real world testing will be scheduled and performed. It is expected that a preparatory call will be made with the affiliate practice to prepare them for testing activities. Capture and analysis of data relevant to functionality will be conducted. Test results will be documented and ultimately used to build the test report. If any non-compliances are observed, we will notify the ONC-ACB of the findings and make the necessary changes required. Testing for (b)(10) may also occur in 4Q as the relied upon software vendor sees fit.

  • 4Q-2025: During the last quarter of the year, the CY 2026 real-world test plan will be completed according to ONC and ONC-ACB requirements and expectations. The test plan will be prepared and submitted per the deadline requirements.

  • February 1 2026: Document our CY 2025 test results into our RWT Test Report and submit to our ONC-ACB.

 

Care Coordination

The following outlines the measure that has been identified to best demonstrate conformance to criteria concerning Care Coordination (170.315(b)(1) and 170.315(b)(2)).

 

Measure Description

The metric used for testing functionality covered by these criteria is the successful secure transmission, receipt, re-incorporation and data verification of the required transition of care documentation. Direct messaging will be conducted using MaxMD Direct mdEmail v.3.0 third party software.

 

Measure Justification

The stated metric was selected as it provides full testing of the functionality.

 

Expected Outcome

The expected outcome is that the data transmitted will be identical with that of the data received. This will be confirmed by the reconciliation process covered under (b)(2) and the received data is successfully imported and applied to the target patient record. That record will also be validated using the USCDI v1 R2.1 Validator Tool.

 

Test Methodology

· As self-developers, our practice does not use CCDA R2.1 documents in a real world setting to send or receive patient health records with outside providers. As such, we will conduct testing using synthetic patient data.

 

· For the b1 criteria, we will generate both a Continuity of Care and a Referral Note CCDA R2.1 document using a representative synthetic patient. Both CCDA xml files will be validated using the USCDI v1 R2.1 Validator Tool (at https://ett.healthit.gov/ett/#/validators/ccdar3).

 

· The b2 criteria will be tested using a representative synthetic patient. First, we will import an initial patient record (CCDA R2.1 xml) file. Next, we will import an updated patient record for the same patient containing new medications, problems and alerts and reconcile (merge) it with the medications, problems and alerts in the initial patient record. To simulate a referral from another practice, we will generate the initial and updated patient records (CCDA R2.1 files) at a practice at one location and then transmit the CCDA files to a 2nd practice at a different location using a secure messaging system. Importing, reconciliation and incorporation of the initial and updated CCDA files will then be performed at the 2nd practice. The resulting patient record will be exported in CCDA R2.1 format and validated using the USCDI v1 R2.1 Validator Tool (at https://ett.healthit.gov/ett/#/validators/ccdar3).

 

As we are using relied upon software Darena Solutions MeldRx for compliance with the requirements for 170.315(b)(10) Electronic Health Information Export, the following details the Real World Testing approach for this criteria.

 

Measure Description

Export USCDIv1 clinical data for a population of patients for use in a different health information technology product or a third-party system. The metric used for testing functionality is the successful export batches of patient data in a straightforward fashion and providing the exported data in the form of valid C-CDA files that conform to the HL7 standards as described in the HL7 Implementation Guide for CDA® Release 2: Consolidated CDA Templates for Clinical Notes.

 

Measure Justification

We will test the §170.315 (b)(10) criteria independently. The RWT will be witnessed via a Zoom session with the participants using a production environment and real patient data. Upon completion, we will observe the successful conformance of the certified technology to be able to Authenticate a patient/authorized representative and for them to request portions of the PHI using an application of their choice outside of the EHR’s domain.

 

Expected Outcome

• Date and time ranges can be configurable via the UI

• Targeted Practices can be configurable via the UI

• Patients exported can be configurable via the UI

• Logging in as a Vendor Admin will allow access to the export functionality

• Logging in as a non-Vendor Admin will not allow access to the export functionality

• Use the Edge Test Tool to check validity of output file

• Data was available for the entered date and time range

• The export summary contained data only within that date and time range

• Export summary was created and completed successfully

• Saving to a preferred location is allowed

• Visually confirming the export after save is performed and successful

• Prepare RWT results report with 95% plus success rate

 

Patient Engagement

The following outlines the measure that has been identified to best demonstrate conformance to the certification criteria concerning Patient Engagement (170.315(e)(1)).

 

Measure Description

This use case is tracking and counting how patients are given access to their portal account over the course of the reporting period. Third party software employed for testing includes MaxMD Direct mdEmail v.3.0 for direct messaging, Meinberg NTP (Version 4.2.8p12) for NTP compliance and time server synchronization and WebSupergoo ABCpdf (Version 10117) for zipping files requested for download or transmission. 

 

Measure Justification 

This use case measure will provide a numeric value to indicate both how often this interoperability feature is being used as well as its compliance to the requirement. An increment to this measure indicates that the EHR can create a new patient portal account and give the patient access to it. A survey can often provide more information on the impact and value of an interoperability element than a standard software test evaluation. The patient portal is intended to support patient engagement with their health records and the ability to transmit their patient data as a C-CDA or human readable copy. 

 

Expected Outcome 

We will get reporting values on patient portal access as well as patients use of the portal’s interoperability features. Measure #1: Report the number of new patient accounts created over a three (3) month period. The measurement will produce numeric results over a given interval. We will utilize various reports and audit logsto determine our measure count. A successful measure increment indicates compliance to the underlying ONC criteria. 

 

Testing Methodology:

We will use analysis of the usage logs from our patient portals to provide total counts of documents added to our portals and total counts of documents viewed and downloaded. At our practice's request the option to transmit patient records has not been enabled. To test the transmission of patient records we will transmit a representative sample of synthetic patient records in CCDA R2.1 format from our EHR to our HISP provider. A representative sample of downloaded and transmitted CCDA R2.1 files will be validated using the USCDI v1 R2.1 Validator Tool (at https://ett.healthit.gov/ett/#/validators/ccdar3).

 

Public Health –

The following outlines the measure that has been identified to best demonstrate conformance to the certification criteria concerning Transmission to Public Health Agencies (170.315(f)(2) and 170.315(f)(7).

 

Measure Description

The metric used for testing functionality covered by these criteria is the successful secure transmission, receipt, verification and processing of the required public health data.

 

Measure Justification

The stated metric was selected as it provides full testing of the functionality.

 

Expected Outcome

The expected outcome is that the data transmitted will be identical with that of the data received and the data will be successfully processed by the receiving entity. This will be confirmed by the validation websites.

 

Test Methodology -

  • f2: Generate NIST HL7v2 Syndromic Surveillance xml files for a representative sample of synthetic patient data based on our actual patient cases. This process may produce as many as 5synthetic patient files, confirm the accuracy and completion of these test files then use the NIST HL7v2 Syndromic Surveillance validation website at https://hl7v2-ss-r2-testing.nist.gov/ss-r2/#/home for validation .

  • f7: generate a NHCS xml survey file for a representative sample of synthetic patient data based on our actual patient cases. This process may produce as many as 5 synthetic patientfiles,confirm the accuracy and completion of these test files, then use the NHCS validation website at https://cda-validation.nist.gov/cda-validation/muNHCS12.html to validate the generated xml test files.

 

Application Programming Interfaces

The following outlines the measure that has been identified to best demonstrate conformance to the certification criteria concerning APIs, 170.315(g)(9).

 

Measure Description

The metric used for testing functionality covered by these criteria is the successful secure retrieval and verification of the applicable data by a simulated patient. Third party software employed for testing includes MaxMD Direct mdEmail v.3.0 for direct messaging.

 

Measure Justification

The stated metric was selected as it provides full testing of the functionality.

 

Expected Outcome

The expected outcome is that the data received by the simulated patient will be identical with that of the data transmitted. This will be confirmed by the comparison between the data sets.

 

Testing Methodology

We will use an in-house developed application named PI_EHR_API_Test that demonstrates use of our certified EHR API.

  

Testing of g9 will be performed by downloading a CCDA R2.1 document for a synthetic patient. This file will be validated using the USCDI v1 R2.1 Validator Tool (at https://ett.healthit.gov/ett/#/validators/ccdar3).

 

Electronic Exchange

The following outlines the measure that has been identified to best demonstrate conformance to the certification criteria concerning Electronic Exchange (170.315(h)(1)).

 

Measure Description

The metric used for testing functionality covered by these criteria is the successful secure retrieval and verification of the applicable data for a simulated patient. Third party software employed for testing includes MaxMD Direct mdEmail v.3.0 for direct messaging.

 

Measure Justification

The stated metric was selected as it provides full testing of the functionality.

 

Expected Outcome

The expected outcome is that the data received by the simulated patient will be identical with that of the data transmitted. This will be confirmed by the comparison between the data sets.

 

Testing Methodology

Send 2 Direct messages to a test Direct address, one message with an attachment and one with no attachment. Then we will recover the Direct message replies to these messages, again one with an attachment and one with no attachment. This will be done by sending the message to a HISP provider test address then verifying the contents of the received messages on the HISP provider user website match our EHR.

 

This Real World Testing plan is complete with all required elements, including measures that address all certification criteria and care settings. All information in this plan is up to date and fully addresses the health IT developer Real World Testing requirements.

Authorized Representative Name: Michael Goforth

 

Authorized Representative Email: mike@proimagetx.com

 

Authorized Representative Phone: 360-359-3690

 

Authorized Representative Signature: 


 

Date: November 6, 2024