Monday, September 26, 2022

Red Flag Notice: Is your serialization L4/L5 vendor ready for DSCSA 2023 compliance?

Understanding, planning and starting implementation for DSCSA 2023 is (and has been) the top priority for most pharma manufacturers.

We are just over 1 year out from the regulatory deadline (and nearly 10 years from the date DSCSA was passed) and some serialization L4/L5 vendors are indicating ‘new’ features/modules/portals will be required for DSCSA 2023 compliance. The vendors convey full ‘assurance’ to manufacturers that they will be compliant, but can’t provide any notable details, can’t provide timelines of when it will be ready and, most importantly, can’t commit to pricing for these ‘new’ components- that is a major red flag.

I worry many manufacturers are barreling down a path where they give their L4/L5 vendor full latitude to dictate their 2023 compliance approach, effort and, most importantly, costs but yet may not be given those details until 9/6/3 months before the deadline- likely after a point where the manufacturer can feasibly consider any other options.

What if your vendor comes back and says this ‘new’ component is going to cost a hefty implementation fee and an additional $30K+ per year?  Many manufacturers are currently in the midst of 2023 budget planning- how will you account for that?     In many ways this is the textbook definition of a mob shakedown- give your constituents (customers) assurance of safety (compliance), and then just before a known threat (compliance deadline) demand more money.

It is critical that manufacturers recognize there are other options for DSCSA 2023 compliance, and in most cases, these other options offer a lower TCO and lower risk profile then simply building point-to-point customer connections out of your L4/L5 system. (We summarize all options below)

But I’m also realistic that there are a large number of manufacturers who simply can’t comprehend considering options other than full reliance on their L4/L5 vendor (as unfortunate as this may be).  However even in that scenario- at an absolute bare minimum, and when I say ‘bare minimum’ I mean literally taking the time to send one email or have one phone call- manufacturers should be requiring their vendor lock in DSCSA compliance costs for 2023 and beyond TODAY.  Otherwise it’s your own fault if you get caught in the mob shakedown situation noted earlier.

For those that are willing to identify better approaches let’s summarize the key pros/cons:

Customer connectivity out of your serialization L4/L5 system

  • Regardless of who your L4/L5 vendor is and regardless of marketing that promotes a ‘network’ concept, every serialization L4/L5 vendor in the industry today relies on establishing point-to-point connections.  This is an extremely inefficient and archaic approach to enabling interoperability across a supply chain- yet admittedly this is the path that most manufacturers are following because they believe it to be the only option available

Again, this is beyond unfortunate. 

  • Pros:  L4/L5 vendors are experienced in establishing connections   Cons:  Costs will be higher than expected, promotes the point-to-point architecture which limits future scalability. For many manufacturers, this approach will add significant scope to their L4/L5 system which further limits flexibility and account control (account control essentially refers to the leverage a manufacturer has to dictate terms of engagement with a vendor)

Connectivity from your 3PL

  • An attractive option, especially for virtual manufacturers who have been relying on their 3PL for Lot Level T3 exchange.  While not every 3PL is offering DSCSA 2023 connectivity, this will be a popular approach for many small to medium manufacturers
  • Pros:  Often very attractive pricing, offloads responsibility of connectivity administration  Cons: Not the core competency of a 3PL, locks manufacturers in to that specific 3PL for DSCSA compliance, may limit visibility to data in manufacturer’s serialization system.

Leverage a DSCSA Connectivity Service

  • Finally after 10+ years, the industry has an option which reflects how supply chain interoperability should operate.  
  • A DSCSA connectivity service provides a true ‘connect once’ experience that also serves as the foundation for other value-add services which take advantage of a true network concept (e.g. recalls, verifications, tracing) (I can’t stress enough how different this option is compared to any current vendor marketing a ‘network’ concept. )
  • Doesn’t require manufacturers change their L4/L5 system, simply add one additional connection from the L4/L5 to the connectivity service and the connectivity service establishes connections with all downstream customers (EPCIS connects and portal)
  • Pros:  Based strictly on standards, commoditizes the exchange of data (as it should be), unrivaled long term TCO compared to L4/L5 vendor or 3PL options, provides greatest L4/L5 vendor account control to manufacturers   Cons:  A relatively new offering in the industry.

The options are there.  

The ability for manufacturers to solidify their DSCSA 2023 approach/effort/costs is in their control (for those willing to take the minimal effort). 

As always- it's on the industry to take the (smallest amount of) effort to become educated on all options and recognize the best approach is not always status quo.

Jennason is excited to be working with manufacturers taking a holistic approach to DSCSA 2023 and helping to further educate them on these options.

Monday, July 18, 2022

DSCSA 2023 Testing: A blind resume comparison

A popular sports analysis mechanism is known as a 'blind resume'.  The idea is to provide a set of characteristics of two anonymous athletes/teams and allow the viewer to guess which 'resume' belongs to which athlete/team.  For basketball fans, this method is often used in the lead up to the annual NCAA basketball tournament as a way to evaluate two teams competing for a final spot in the field.   

On a deeper level, the intent of a 'blind resume' is to demonstrate the power of perception from brand recognition. Sports fans normally have preconceived ideas about who is 'good' and who is 'bad' and, thus, when presented with a two sets of characteristics- one generally 'better' than the other- the natural reaction is to assign the perceived 'good' athlete/team with the good set of characteristics and the perceived 'bad' (or not as good) athlete/team with the 'bad' (or not as good) set of characteristics.

And for those who haven't seen a 'blind resume' play out- the correct assignment is almost always the opposite.  It's a sneaky, yet intriguing method and one, I think, applies well to the serialization L4/L5 vendor space which has long been rife with misperception as a result of marketing imbalance and, quite frankly, misleading advertising.

In particular this method can be used to show a noticeable disparity when it comes to manufacturers' ability to perform testing as part of upcoming DSCSA 2023 efforts. 

As you've heard me say numerous times before- testing is the most important phase of any serialization effort.   Testing is not only a critical phase in determining overall success/failure of an effort, but is also the phase that most directly drives the level of internal/external resource effort needed and overall cost of a serialization project.   This is because a lack of testing performed, or the inability to perform adequate testing, increases overall risk- and when risk increases, the likelihood of exceptions/failures, including very costly exceptions/failures, increases as well.

So the key message is that all manufacturers need to plan for extensive testing as part of DSCSA 2023 efforts and must take steps to ensure this testing can be performed efficiently and cost-effectively.  

Interestingly, simply looking at who your serialization L4/L5 vendor is plays a major part in determining your ability to test. Enter the 'blind resume'... Good Luck!!


Remember the rule: Manufacturers who don't test or can't test increase their risk.  And those who simply 'trust' their vendor to perform all necessary testing will experience this- https://www.lifescienceserialization.com/2022/06/we-can-do-better-than-this.html -sooner rather than later.

I encourage everyone to leave their guesses in the comments!!  And feel free to reach out to Jennason for the blind resume answers and to hear more about our experiences testing against all serialization L4/L5 vendors.

Tuesday, July 12, 2022

A baseline for serialization L4/L5 pricing

Pricing of L4/L5 serialization systems has been a roller coaster over the past decade+.  The earliest adopters paid astronomically high fees (relatively speaking) only to see many vendors take on a 'race to the bottom' mentality during the height of system adoption ahead of DSCSA serialization and EU FMD milestones.

Unfortunately, a few factors persist which lead to wildly variable pricing- proving that L4/L5 serialization system pricing is still very much an art and not a science.

Pricing is once again a topic of discussion in the industry as many manufacturers are nearing the end of a contract term with their serialization vendor.  As such, the intent of this post is to offer a 'baseline' pricing scenario which manufacturers can use to assess whether they are paying market rates.

A key disclaimer:  Vendor fees is only one factor in the total cost of ownership of an L4/L5 serialization system.  Manufacturers who find themselves paying relatively low fees may still have a high total cost of ownership if they require significant internal resourcing to support the system, rely heavily on external resources to support the system and/or rely heavily on expensive vendor support resources.    

And to tease the topic of an upcoming post-  While system fees, of course, directly contribute to long term total cost of ownership (TCO), arguably, equally important to long term TCO is risk.  High risk with a serialization system increases the possibility of exceptions- and in the serialization world exceptions can mean product stops flowing and patients are at risk- in short- scenarios whose 'cost' can be business-altering.  Many manufacturers have justified paying higher vendor fees in return for having the perceived lowest risk (and lowest total cost of ownership) solution.  Unfortunately, in Jennason's experience, these manufacturers are in for a surprise when recognizing their higher cost vendor is, in fact, also the highest risk vendor.  (Much more to come on this topic)

The driver, and again intent of this post, is my belief that A LOT of manufacturers are drastically overpaying for their L4/L5 serialization system relative to current market rates.  The hope is more education will help manufacturers reevaluate and identify their best long term strategic partners or, at a minimum, give manufacturers leverage to renegotiate future contract terms.

A key challenge, historically, is that pricing has not been purely market-driven, but instead driven simply by what the customer was willing to pay.  Additionally many manufacturers are not gathering insight into current market-rates. This, in turn, creates a 'perfect storm' scenario where manufacturers end up paying outrageously high fees.

Vendors love this 'perfect storm' because it means that on any given deal, if all the factors align, they can score a big sale. 

In the industry's best interest, we need to change that.... 

Thus, in an attempt to define a 'baseline' pricing scenario for a pharma manufacturer we'll use the simplest serialization use case.   Fortunately, many manufactures will fit into this exact use case (and are many of the manufacturers who we believe are drastically overpaying).

The baseline pharma manufacturer use case:

  • 1 CMO partner
  • 1 3PL Partner
  • 1-10 downstream customers
  • Compliance for 1 distribution market (US DSCSA for example)
  • Standard data requirements
  • Standard quality/validation requirements
For this scope if you are paying at or greater than $100,000 in annual recurring fees, you have an opportunity to reduce costs, conservatively, by 30% on annual basis and potentially as much as 60%. If you are paying significantly more than $100,000 in annual fees for the scope above, red-flashing alarms should be going off.  

In those scenarios, manufacturers may be able to absorb the fees which come with making a system change  (e.g. new system implementation fees, project fees from CMO/3PL partners, external support fees) and still realize a positive ROI within the first 2-3 years of their new contract.

For manufacturers, the window to solidify long term, strategic serialization vendors is now.  With the upcoming DSCSA 2023 implementation efforts, significant scope will be added to many manufacturer's serialization systems.  Thus, for manufacturers who have concerns about their current vendor, it's in their best interest to do a long term, strategic vendor evaluation first and then dive into 2023 efforts. 

Thursday, June 23, 2022

We can do better than this.....

This is the level of service from a ‘leading’ serialization L4/L5 vendor that the pharma industry deems acceptable.   

  • Manufacturer’s CMO and 3PL integrations are operating as expected.   No changes to data/ no changes to configuration are made
  • Manufacturer gets a call from their 3PL that data was not sent for a shipment that has just arrived
  • Manufacturer starts to investigate and finds that recent serialization data from their CMO is not being communicated to the 3PL.  Manufacturer opens support case with L4/L5 vendor
  • Manufacturer gets charged thousands of dollars by their 3PL due to not being able to provide serialization data on time
  • L4/L5 vendor takes over a week to determine that the root cause was due to a ‘fix’ for a defect they released as part of a previous version upgrade
  • Issue was never identified by the L4/L5 vendor because their internal testing doesn’t cover customer specific setup/configuration
  • While the issue is being investigated, the manufacturer has to hold batches from release so as to not incur additional late data fees from their 3PL 
  • L4/L5 vendor informs Manufacturer that the timing to make a ‘fix’ to resolve the issue caused by the earlier ‘fix’ is unknown.  Instead L4/L5 vendor directs manufacturer to make changes to their system in order to correct the issue.  
  • Manufacturer has to log a quality event internally to document the impact to product supply and justify the system changes.
  • Manufacturer makes changes and as part of quality procedure must test the changes.
  • L4/L5 vendor informs Manufacturer there is no technical way for the Manufacturer to test changes themselves- thus the manufacturer is forced to request testing support from the CMO
  • CMO charges manufacturer over a thousand dollars PER TEST      (Curiously the L4/L5 vendor of the CMO is the same L4/L5 vendor as the manufacturer)

End result- Manufacturer is out thousands of dollars, hours of internal resource time spent troubleshooting, supporting and authoring quality documentation and experienced a disruption to product flow.  All for an issue originally caused by the L4/L5 vendor which was completely avoidable.

With any other vendor 

  • the manufacturer would have had control over releases- allowing for standard quality activities to be performed that ensure proper qualification within the manufacturer’s specific setup/configuration/deployment.    
  • the manufacturer would be able to test any-and-all changes themselves, rather than be forced to engage in extremely costly support activities with their partners

Manufacturers desperately need to recognize how unsustainable this ‘status quo’ is going forward as everything ramps up to new levels (e.g. more connections, more complexity, more use cases, more exceptions). 

Pharma industry- It doesn’t have to be like this. Demand better.   And if things don’t improve- then make changes- as we’ve seen recently the biggest pharma’s recognize the need to make changes- you can do the same. 


Friday, January 7, 2022

What manufacturers face in complying with DSCSA 2023 data exchange requirements

It’s shaping up to be an interesting year for pharma manufacturers in their preparation for 2023 DSCSA compliance.  There are several components of the 2023 milestone that will require manufacturers to carry out serialization projects ahead of the deadline- and many of those projects will need to occur this year (2022) to meet industry expectations.

Central to the 2023 requirements is the need for the data exchanges sent upon the sale of drugs to include serialization data.    To date, these data exchanges (often referred to as T3s) have contained lot-level information only and have been accomplished via a combination of EDI messages (ASNs) and portals.

As highlighted in previous posts, the 2023 milestone represents the time when the pharma industry will need to enable data integration across the entire supply chain.   The approach identified in the US is to establish point-to-point connections between all responsible entities. (e.g.  a manufacturer needs to ensure there is a mechanism to exchange serialization data with each of its downstream customers)          

Many manufacturers, especially virtual manufacturers, may be in for a shock when realizing the level of effort they’ll need to expend to establish these point-to-point connections.   Why is this?

To date, many manufacturers have had the luxury of relying on their 3PL partners to establish and manage data exchanges with downstream customers (e.g. T3 exchange). These services have been provided by many 3PL’s as part of standard serialization support packages.

But, as noted, come 2023 these data exchanges need to transition to serialized exchanges and we are now starting to see some clues as to how 3PLs plan to offer support.  Unfortunately many manufacturers have learned, or will soon learn, that their 3PL will not support exchanging serialized data directly with downstream customers.  In those scenarios, that means the responsibility to establish and maintain connections with all downstream customers falls back on the manufacturers. And because the industry has aligned around the use of EPCIS to facilitate the serialized data exchanges, all of the connections established using EDI for Lot level T3 exchange won’t offset any of the effort that will be needed.  This will result in a significant undertaking considering many manufacturers may have dozens of (or more) customers.

So what are the next steps for manufacturers?

  • Set up time to discuss DSCSA 2023 with your 3PL(s) ASAP.   

A survey of the leading 3PLs in the US reveals the following range of approaches:

    • Some 3PLs are planning to support sending serialized T3s directly to downstream customers AND will make the data available to the manufacturers as well- essentially extending the service they currently provide for Lot Level T3s
    • Some 3PLs will give the manufacturer a choice- they can either send serialization data directly to the downstream customer -OR- they can send the serialization data back to the manufacturer- but they won’t do both.
    • Some 3PLs are not offering the option to send serialization data to downstream customers and will only send the serialization data back to the manufacturers- putting the responsibility fully on the manufacturers to establish the downstream connections. 

Interestingly enough, I can’t blame those 3PLs for distancing themselves from supporting the direct exchanges with customers.   The amount of connectivity that needs to be established over the next 2 yrs is such an exponential increase over what’s been done across the industry to date, the 3PLs recognize that it will result in an exponential increase in issues and problems- and they simply don’t want to have full responsibility for that.   Can’t blame them.

  •  Understand the impacts to your existing serialization vendor contract

Many manufacturers were fortunate that during the initial implementation of their serialization system the vendor did most of the heavy lifting to establish connections to partners and provide quality/validation documentation. What was often overlooked is that many vendor contracts set limits on the number of partners they will connect and/or the contracts define fees for establishing additional connections.   Look for yourself-you may find ‘small print’ that notes the vendor included the first 1 or 2 or 3 connections, but after that the ‘heavy lifting’ becomes the manufacturers responsibility. 

Again, many manufacturers may be in for a shock when they are presented with increases to their annual recurring fees (to cover the additional connections) as well as new SOWs to provide resource support to establish the new connections. (since many won’t have planned to have the internal resources to do the ‘heavy lifting’ themselves) 

  • Identify the level of effort needed to ensure 2023 compliance and look for ways to minimize the impact to your resources 

Regardless of how your 3PL plans to support serialized data exchanges, manufacturers should recognize some level of resource impact will always fall back on them.  The scope of impact, of course, depends on the 3PL’s plans as well as the level of support provided (or you choose to have provided) by your serialization vendor.    If your 3PL and serialization vendor take on most of the work, then your internal resource impact may be limited to typical document reviews and ensuring validation alignment.  However, the manufacturer will always be on the hook to perform a level of testing to ensure each of the individual connections is working as expected. 

Alternatively, if your 3PL does not plan to support direct exchanges with downstream customers and/or your serialization vendor won’t do most of the ‘heavy lifting’ (or wants to charge you too much) then there is a considerably greater impact on your internal resources.  In this scenario manufacturers will need to oversee the projects to establish connections with each of your downstream customers (even with your vendor involvement).  And while these projects will have synergies in terms of their structure and approach, at a technical level, configuration and testing steps will have to be done individually for each customer. 

Thus a common theme is the need for manufacturers to execute testing in support of establishing these downstream connections.  And the level of testing required (regardless of the scenarios noted above) should not be underestimated.  

  • Consider a minimal need to generate multiple test batches to verify each individual customer connection- and that assumes testing for each connection is successful first time ( 😊 )  
  • Additional test batches will be needed to re-test any failures as well as test any required exception scenarios. (exception handling will be the single greatest cause of headaches over the next 2 years-  the ability to cover a broad range of business scenarios and production-like volumes is the only way to uncover these exceptions)   
  • So a manufacturer who has just 10 customers is looking at 20-30+ simulated test batches, each (likely) incorporating varying products, packaging configurations and all requiring unique test serial numbers. (The more realistic # of test batches needed by most manufacturers is certainly much higher)
  • The options for manufacturers to facilitate all of this testing is limited. 
    • You can ask your CMOs to simulate test batches and some may agree- but the timeliness, flexibility and scalability is out of our control
    • You potentially can leverage your serialization vendor’s UI to simulate batches on a small scale- but this quickly becomes laborious when numerous aggregations and any level of realistic product volumes are required.  Even on a small scale, depending on all set ups required, it may take an hour+ to execute a single test.
The better option is to leverage a simple automated testing tool purpose-built for pharmaceutical serialization projects.   Watch the following brief demonstration on how the Jennason Serialization Test Tool (https://www.jennason.com/solutions) can reduce your testing time to a matter of seconds and give you full control to cover any testing scenario and volume levels required.   In addition to saving you time and money, the tool also generates barcode reports (1D and 2D barcodes corresponding to your simulated serialized shipments) that can be shared directly with your 3PL and downstream customers to better support their testing efforts.  In short, everyone wins.

Commercial details (https://www.jennason.com/shop) are shared during the demonstration as well as options for leveraging the solution as a service combined with Jennason’s advisory consulting. 



 

 

Tuesday, December 29, 2020

EPCIS woes continue.....

Another day…another woefully non-compliant EPCIS message supported by some of the ‘biggest’ players in the space.  Most will say  “Hey Scott, lighten up, it gets the job done so who cares if a few things here-and-there are not compliant”     

So as a year-end message I’ll get back on my soapbox again-   The reality is most of these ‘infractions’ (except the last one discussed below) likely don’t have a material impact on how the EPCIS communicates the necessary information from point A to point B….  the real risk/concern is this is yet again just one small example in an absolute ocean of examples where the industry is not just lax in its attempts to strictly adhere to EPCIS but is fully welcoming of it.

I’m not some private investigator with special tools that can detect these issues- I’ve praised/linked to the FREE tool that will reveal most of the issues below in a matter of seconds (https://epcisworkbench.gs1.org/ui/home)….so this can’t be about it being too hard to root out non-compliance…its simply that:

1) To this point, there hasn’t been an overwhelming reason to be air-tight on EPCIS compliance-   No EPCIS police to come around and stop product from flowing and not nearly enough interconnectivity across the industry for these issues to start causing bigger issues.

2) It’s hard to push back when some of the ‘biggest’ players in the space are the ones openly generating non-compliant EPCIS and/or willing to accept non-compliant EPCIS

Previously I’ve raised the notion of one simple way that non-compliance with EPCIS directly impacts the industry:

Take the last issue highlighted below.  Its black-and-white- both entries are simply not compliant.   But it’s happening out there in the wild (which by the way I would be interested to know if either the sending or receiving vendors are ‘certified’ by an EPCIS conformance testing service) which means the system generating this EPCIS was built in such a way that allows that to happen and, even worse, the system receiving these messages either A) didn’t catch these as issues and/or B) was built (and even possibly ‘enhanced’) to support receiving these messages.   The development it takes to support not only compliant EPCIS but now also the ocean of non-compliant EPCIS costs money.  And do you think the vendors just eat those costs?  Of course not, it goes back on the industry through increased annual fees or baked into some new ‘module’ that will be marketed.  

Now extrapolate that out over the massive number of ‘connections’ that have to be put in place by 2023 for the US market to achieve compliance.    If every vendor can go off and define what they feel is acceptable use of EPCIS then it’s the pharma industry who ultimately feels the pain.

In this space, 2021 will be the year of collaboration (or non-collaboration depending on how it plays out).   The technical issues below are likely viewed by many (not me) as minor, but what needs to be in focus is whether the industry maintains the mindset that’s been attached to EPCIS compliance…. There should be no ‘minor’ or ‘major’ non-compliance- it needs to be black-and-white… you’re either compliant or you’re not….and unfortunately, we are long past the point where non-compliant practices have become the norm.

I wrote a blog post nearly a year and a half ago that pondered whether EPCIS had lost its value as a standard within pharma serialization….  Instances such as below would seem to indicate nothing has really changed….and I still think we are just at the tip of the iceberg when it comes to understanding the impact that these seemingly insignificant and incredibly detailed ‘misses’ will have when trying to accomplish end to end traceability in pharma.

My last few posts have focused on the need for the industry to do a reality-check on whether we are moving forward with serialization/traceability in pharma in the best way possible.  Non-compliance with EPCIS is yet another reason why this reality check is needed.

----------------------------------------------------------------------------------------

Note: X’s are mine- used to preserve confidentiality



Thursday, November 12, 2020

Quick Thoughts on HDA's EPCIS Implementation Guidance....

Quick thoughts on the EPCIS implementation strategy released by the HDA in September... (https://www.hda.org/~/media/pdfs/government-affairs/position-statements/2020-09-29-getting-ready-for-epcis.ashx)

Few important highlights for me, with one being especially timely given my last post regarding the necessity for options centered around open governance industry networks.

Currently, EPCIS is the only internationally recognized standard that will meet these DSCSA requirements. 

Always good to to see the commitment to standards and specifically EPCIS.   Yet still amazing how many current connections across the industry (and even new connections continue to be established) which either do not use EPCIS or use a non-compliant EPCIS structure.

An additional complicating factor is that given the many supply chain entities that must meet the DSCSA’s 2023 requirements, competition for the services of the limited number of experts and consultants to advise on EPCIS execution will be keen. We anticipate a very high demand for this expertise -- potentially limiting trading partners’ ability to obtain the timely help they need just as they face the DSCSA’s critical deadline.  

Of course as a consultant myself I have to biasedly agree with this.     But, in my opinion, the real importance of this statement is not that I'm going to be busy the next 3 years, but rather what am I going to be busy doing?    My guess is most people read that paragraph and think "Yea think of all the connections that have to be set up between every manufacturer and their wholesalers and the wholesalers and pharmacy/hospitals.   Yikes that's a lot of work!!!"

And in fact that's exactly where the HDA guidance continues to....

At the outset, the bulk of this implementation will center on each manufacturer achieving successful EPCIS data exchange with each of its wholesale distributor trading partners. 

We encourage each pair of manufacturer and wholesale distributor trading partners to work together to establish a joint implementation plan for EPCIS execution that builds in adequate time for putting the necessary infrastructure in place, evaluating data quality, onboarding, testing, and stabilization.

And here is where my opinion starts to diverge...

The statement above sends a very clear message to the industry that we will follow the same path as we've been on for the past 10+ years...spending the dollars and resources to set up connections between each partner.   As I said in my last post- if that is the direction the industry chooses to go then c'est la vie.   I wish the guidance here wouldn't explicitly assume that's the best path forward....

My central point is-  We will have missed the boat again if we spend the next 3 years setting up integrations between each trading partner.   Those dollars and resource time should instead be allocated to deploying an open, industry governed collaborative network  (and no, despite whatever claims might be made, none of the traditional solutions/vendors fit this mold today).    Take the learnings from the last 10 years- recognize the good parts but also own up to the bad parts- and simply just look to improve over the next 3 years...staying on the same path isn't improvement....   As stated in my last post- that's the industry's call to action.....   

But there also is a call to action for solution providers.....   In HDA's defense, it would have been hard to even make reference to an open industry network in this guidance because, frankly, we havent heard nearly enough about them yet..... The messaging is starting, as we saw from the Linux Foundation announcement last month, but we need more info, more education and more tangible understanding of exactly how such a network operates and can meet the needs of 2023.... and we need all of that ASAP.

My view is, at a bare minimum, we at least owe ourselves the time/effort to more deeply consider the open network concept before assuming its not an option at all....So while I fully agree that it will take a lot of work to achieve 2023 compliance I hope that work is focused on the right efforts...



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