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Wednesday, September 19, 2012

"Savings promised by the government and vendors of information technology are little more than hype." - WSJ


The Wall Street Journal has just tossed a large cup of cold coffee on HIT.
OPINION September 17, 2012, 7:25 p.m. ET
A Major Glitch for Digitized Health-Care Records
Savings promised by the government and vendors of information technology are little more than hype.


By STEPHEN SOUMERAI And ROSS KOPPEL
In two years, hundreds of thousands of American physicians and thousands of hospitals that fail to buy and install costly health-care information technologies—such as digital records for prescriptions and patient histories—will face penalties through reduced Medicare and Medicaid payments. At the same time, the government expects to pay out tens of billions of dollars in subsidies and incentives to providers who install these technology programs.

The mandate, part of the 2009 stimulus legislation, was a major goal of health-care information technology lobbyists and their allies in Congress and the White House. The lobbyists promised that these technologies would make medical administration more efficient and lower medical costs by up to $100 billion annually. Many doctors and health-care administrators are wary of such claims—a wariness based on their own experience. An extensive new study indicates that the caution is justified: The savings turn out to be chimerical.

Since 2009, almost a third of health providers, a group that ranges from small private practices to huge hospitals—have installed at least some "health IT" technology. It wasn't cheap. For a major hospital, a full suite of technology products can cost $150 million to $200 million. Implementation—linking and integrating systems, training, data entry and the like—can raise the total bill to $1 billion.

But the software—sold by hundreds of health IT firms—is generally clunky, frustrating, user-unfriendly and inefficient. For instance, a doctor looking for a patient's current medications might have to click and scroll through many different screens to find that essential information. Depending on where and when information on a patient's prescriptions were entered, the complete list of medications may only be found across five different screens.

Now, a comprehensive evaluation of the scientific literature has confirmed what many researchers suspected: The savings claimed by government agencies and vendors of health IT are little more than hype...
 OK, pretty damning. But,let's surf over to the abstract page of of one of the referent "scholarly" papers cited in the WSJ article's cited meta-analyic study, "The Economics of Health Information Technology in Medication Management: A Systematic Review of Economic Evaluations."
Conclusion. The quality of the economic literature in this area is poor. A few studies found that HIT may offer cost advantages despite their increased acquisition costs. However, given the uncertainty that surrounds the costs and outcomes data, and limited study designs, it is difficult to reach any definitive conclusion as to whether the additional costs and benefits represent value for money. Sophisticated concurrent prospective economic evaluations need to be conducted to address whether HIT interventions in the medication management process are cost-effective.
 Meta-analytic research, recall, is comprised of studies that study other studies. So, this effort is akin to "Dr. Joyce Brothers Does HIT."

To conduct the study, faculty at McMaster University in Hamilton, Ontario, and its programs for assessment of technology in health—and other research centers, including in the U.S.—sifted through almost 36,000 studies of health IT. The studies included information about highly valued computerized alerts—when drugs are prescribed, for instance—to prevent drug interactions and dosage errors. From among those studies the researchers identified 31 that specifically examined the outcomes in light of the technology's cost-savings claims.
I'm gonna hold my fire until I can get access to the McMaster thing. We'll see. Although, I will crack on this from the WSJ article:
It is already common knowledge in the health-care industry that a central component of the proposed health IT system—the ability to share patients' health records among doctors, hospitals and labs—has largely failed. The industry could not agree on data standards—for instance on how to record blood pressure or list patients' problems.
That is unfair. "Failed"? It's just getting underway. We've known of the knotty "interoperability" problem for quite some time, and a lot of smart people are working tirelessly to solve it within the paradigm of private market HIT.

Much more to come on this. In the imterim, I exhort you to read the numerous accruing companion WSJ article comments (107 at this writing).

The heads-up on the WSJ thing came by way of being copied on a response to our CFO Dan Memmott by Sharon Donnelly (pdf), our SVP of Corporate Strategy (and who used to be our REC Executive Director).
Dan,
Thanks for sharing. I appreciate the perspective of industry unduly driving the political agenda.

The article seems to confound two things: saving from HIT in cost of health care and saving from HIT in cost to the provider using it.

The evidence for the first is not there yet. Some think we have built the base needed to get the discrete actionable data to support electronically coordinating care and point of care clinical decision support that will eventually gain the savings. Others see us (primarily due to standards lag issue?) as far from there and legitimately question how current EHR and HIE architectures can support the needs of ACOs and other program designed to improve care and lower cost.   We may have a role in helping our community providers evolve together to a coordinated state that is required to see these benefits.

The second, savings to the practice or hospital, is almost completely dependent on the way the provider plans and implements HIT. Those doing it well reap huge savings in their operating costs. Unfortunately this often includes allowing them to document care in a way that they are reimbursed more, which of course drives the overall cost savings of healthcare in the wrong direction. 

No magic bullet here – just a lot of work!

Some pushback in the HIT press:
A little patience for the health IT revolution

How long did it take American farmers to widely adopt hybrid corn?

Honestly, I don't know, but I do remember what I was told about that kind of adoption—30 years.

I was age 22 at the time and had just started my agriculture extension training with the Peace Corps in Sierra Leone, where we learned the basics of rice paddy construction and swamp rice cultivation. It wasn't until later, when we were posted to our villages to serve our two-year hitches, that we learned just how hard it was going to be to convince wary farmers to abandon their familiar but ecologically destructive slash-and-burn cultivation techniques.

While covering health information technology during the past 12 years, I've thought a lot about that warning against short-run overexpectations. I thought about that warning, again, reading a recent article in the Wall Street Journal, "A Major Glitch for Digitized Health-Care Records."...


...Interoperability is a failure only if your time line is too short and you begrudge the incomplete successes that are happening around us. E-prescribing, one form of interoperability, is soaring. In a couple of years, the federally sponsored Direct protocols will similarly become the method of choice for peer-to-peer communication, replacing the phone and fax machine. Even the far more complex query-and-response form of exchange is coming along. Earlier this month, the VA demonstrated a potential breakthrough in consent management technology for privacy protection using Direct and off-the-shelf standards from HL7.

"This is no time to go wobbly" on health IT, to borrow a line from Margaret Thatcher. The past and future public investments in health IT were—and will be—both proper and necessary.

Now is the time to execute and innovate—and, yes, to be watchful and even critical. But also, and maybe of the most importance, it's time to be patient...
Agree.
___

More pushback:
Asking the Wrong Questions About the Electronic Health Record
By ASHISH JHA, MD


...Now that we have made an important investment in EHRs, we need to figure out how to use this new technology to address the fact that the healthcare system is a mess.  We need to figure out how EHRs can promote coordination of care across sites, seamless flow of good clinical information, and smart analytics, to name a few things.  We simply can’t do that in a paper-based world.  I am sure that the healthcare industry single-handedly keeps the fax machine industry alive.  We need to stop. Period.  Every other part of our lives has become electronic and the benefits are clear.  Our lives are better because we bank online, communicate online, shop online.

The debate over whether we should have EHRs is over.  Can we fix our broken healthcare system without a robust electronic health information infrastructure?  We can’t.  Instead of re-litigating that, we need to spend the next five years figuring out how to use EHRs to help us solve the big problems in healthcare.
Emphatically agree. Once again, down in The Weeds' -
“A culture of denial subverts the health care system from its foundation. The foundation— the basis for deciding what care each patient individually needs— is connecting patient data to medical knowledge. That foundation, and the processes of care resting upon it, are built by the fallible minds of physicians. A new,secure foundation requires two elements external to the mind: electronic information tools and standards of care for managing clinical information.

Electronic information tools are now widely discussed, but the tools depend on standards of care that are still widely ignored. The necessary standards for managing clinical information are analogous to accounting standards for managing financial information. If businesses were permitted to operate without accounting standards, the entire economy would be crippled. That is the condition in which the $2½ trillion U.S. health care system finds itself—crippled by lack of standards of care for managing clinical information. The system persists in a state of denial about the disorder that our own minds create, and that the missing standards of care would expose.”…


…this subject matter may seem like just a variation on current policy concerns with using “health information technology” to bring “evidence-based medicine” to “patient-centered” care. Yet, current policy fails to comprehend the needed discipline in medical practice and thus fails to define precisely what is needed from health information technology. A dangerous paradox thus exists: the power of technology to access information without limits magnifies the very problem of information overload that the technology is expected to solve. Solving that problem demands a meticulous, highly organized, explicit process of initial information processing, followed by careful problem definition, planning, execution, feedback, and corrective action over time, all documented under strict medical accounting standards. When this rigor is enforced, a promising paradox occurs: clarity emerges from complexity.”


- Lawrence Weed, MD and Lincoln Weed PhD, “Medicine in Denial”
None of which mandates being an unreflective, Pollyannish HIT cheerleader, to wit,

Epic FAIL!
County health doctors air complaints about county's new $45 million computer system
By Matthias Gafni, Contra Costa Times
MARTINEZ -- One of every 10 emergency room patients at the county's public hospitals in September left without ever being seen by a doctor or nurse because of long waits -- a number rising since implementation of Contra Costa's $45 million computer system July 1.
One patient waited 40 hours to get a bed.
Dr. Brenda Reilly delivered the troubling news Tuesday afternoon to county supervisors. She was one of three dozen doctors in the supervisors' chamber complaining about EPIC, new computer software aimed at integrating all of the county's health departments to create a federally mandated electronic medical record for patients.
To allow for the major computer program installation and conversion, administrators cut doctors' patient loads in half, in turn cutting the number of available appointments in half.
In a letter to the supervisors, Dr. Ori Tzvieli -- medical staff president whose union has been negotiating a new contract with the county -- along with 14 doctor co-signers pleaded for administrators to continue scaling back physician workloads because doctors are over-stressed. Six doctors have left this year, said Dr. Keith White, a 22-year pediatrician.
"We were not ready for EPIC and EPIC was not ready for us," White told supervisors. "As a result, the providers are struggling to provide safe and effective care for 100,000 citizens of the county, many of whom are very ill. We often feel that we are failing. We are very tired... many doctors have left and all are considering leaving."...
Ouch. The runaway market share leader in "certified" EHR, both ambulatory and inpatient. Talk about "Major Glitches."
 

IN OTHER NEWS

This hit my inbox last night:
Hi Bobby,

Thank you so much for applying for a press pass and congratulations on being chosen to attend the upcoming Health 2.0 Fall Conference in San Francisco on Oct 7-10 2012! We only choose the best and most qualified applicants to attend our exciting conference.

The press pass gives you access to the Health 2.0 conference and DC to VC. Below please find the instructions for registering and let me know if you have any problems...


...Please let me know if you have any additional questions or problems regarding registration and we look forward to seeing you in San Francisco soon!

Best regards,
Danielle
Health 2.0

www.health2con.com
I am really grateful. HIMSS12 was a blast, and I will cover this event with equal gusto.


___

BRIEF PERSONAL DIGRESSION

My beloved niece April was married this past weekend in Marquette, MI. I scored one big-time on this photo.


'eh?

Now-husband Jeff Nyquist is Dr. Jeff Nyquist, Vanderbilt PhD in neuropsychology, CEO of Upper Peninsula Home Health, Hospice and Private Duty. I want to get to talk shop with him at some point regarding long-term care HIT.

Power couple.


Any excuse to go to Marquette and see my sister and the kids. Jeff calls me "Uncle Bobby." I love that.

Downtown Marquette, shot from the reception restaurant balcony looking back up the hill.


What a cool little town.

My new grandnephew Anthony (8 wks old) agrees (Great Aunt Cheryl was holding him out on the balcony when I shot that).

___

BACK ON TASK

At the 6th Annual Fall Conference you will see the very latest technologies in Health 2.0, and we’ll maintain our tradition of hosting leading thinkers and fascinating conversation. This fall, new technologies will be presented in contextual environments woven around a developing narrative which illustrates the transformation occurring in the space. Change doesn’t come easily and a true, universal transformation requires the analysis, connection and redefinition of categories across all parts of the system. We’ll dive deeper into these issues with topics like big data analysis, personalized medicine, price transparency and keynotes from Health Futurist Joe Flower and Aetna CEO Mark Bertolini. Over two days we will progressively illuminate on stage, through mini-environments and discussion, that Health 2.0 is everywhere – it touches how we live, how we eat, how we interact with providers, patients and more. There’ll be lots of media coverage, hundreds of potential customers, and scores of potential partners to meet. If you want to get involved in health care innovation, you need to be at Health 2.0!
I booked my flights today. Awesome agenda. Starting with
Health Law 2.0
Health 2.0 has created a pre-conference session entitled Health Law 2.0 that addresses the pressing legal issues for both large and small Health 2.0 companies.   We have identified several key legal issues that face companies in the regulated world of health care and created two tracks of programming — one focused on Patient/Consumer Legal Issues and the other focused on Legal Issues with Providers, Plans and Life Sciences.

The panels we have assembled include the leading experts in each topic who will provide an overview and important updates.  The panel also will work through some interactive examples of problematic arrangements and provide insight on how to avoid legal risk.  In every session, there will be ample time for questions.

The tracks will run concurrently and you may attend sessions in either track.  This is a wonderful opportunity for all Health 2.0 companies to delve deeper into the legal issues so they can make better choices as well as identify potential opportunities and capitalize on them.  It’s also very useful to hear what different experts think about a particular issue so you can make informed decisions.

We look forward to seeing you at the Health Law 2.0 pre-conference!
You can bet I will be there. Then, Monday Morning:
Keynotes
Leading Health Futurist, Joe Flower, will discuss the practical solutions that health care organizations need to implement to deliver health care at half the cost. Joe is a regular columnist who contributes to Hospitals and Health Networks, has spoken at thousands of health care meetings and is the author of a new book Healthcare Beyond Reform: Doing it RIght for Half the Cost.

Aetna CEO, Mark Bertolini will discuss the how his company is leading the pack in a transformation from insurance company to health tech services company, while bringing along its partners -- both providers and technology companies -- and its customers -- employees & consumers. Last year they introduced the iNexx platform and in 2012 they are debuting the CarePass consumer platform, and on our stage will announce the results of the Aetna CarePass Platform and Medication Reminder Developer Challenge.

I've written of Joe's impressive work before:


SEPT 20th UPDATE:
THIS SHOULD BE AN INTERESTING READ


Got it on Kindle last night. Looks like a safe bet for $9.99. I already know my "basics" and then some, but it never hurts to get another perspective. This is spot-on:
I believe that the range of approaches that many organizations are using creates a strong need for process improvement professionals to be “tool agnostic” and fluent in several improvement dialects. This would position these improvement practitioners to serve as trusted advisors or coaches to business leaders rather than true believers that specialize in the one best way they know to improve work.
-  Page 34, Kindle Edition.
UPDATE: While nominally "method agnostic," a quick first scan reveals this book to be fairly "Lean" favorable. A good thing, in my view. I like in particular the specific attention paid at the end to "knowledge work" (i.e., like, uh, HIT software development and management, ja?).

A handful of my conceptual visual mapping "workflow" overviews:


Click to enlarge.


UPDATE

National Association Created to Represent Regional Extension Centers for Health Information Technology
New national group formed to provide a strong voice for the 62 Regional Extension Centers that provide assistance and guidance for the adoption and use of health information technology.


Silver Spring, MD (PRWEB) June 21, 2012

A new national association has been formed to provide a strong voice for the 62 Regional Extension Centers that provide assistance and guidance for the adoption and use of health information technology. The Association of Regional Centers for Health Information Technology, or ARCH-IT, represents Regional Extension Programs and the unique needs of the independent health care providers served by RECs in every state across in the United States...

I know these people must be tired of me calling them out (and, note that I have not personally outed them). But, I'm still on the lookout for that "strong voice."


I have no Beltway Gucci Gulch experience, but, the lobbying strategy -- uh, "trade association strategy" -- escapes me. Nonetheless, I suppose should there be no federal dollars tied up in this "effort" (via the RECs), it's none of "my business."
___


WASHINGTON (HealthcareIT News) – There are no set appropriations for how much the federal government can spend on rewarding providers who adopt and use electronic health records under the Medicare and Medicaid meaningful use EHR incentive program, according to National Coordinator for Health IT Farzad Mostashari, MD.

"Whoever qualifies, gets paid; there's no hard cap," said Mostashari, who gave a keynote at the Annual Policy Summit for the Health Information Management and Systems Society (HIMSS) on Wednesday.

Mostashari said the federal government estimates it will pay out around $20 billion in incentives before the program shifts to a penalty in 2015, but there is no fixed budget set in the HITECH Act that mandated the program. The government recently announced it has paid out nearly $7 billion since the program began in 2011...
There is, however, a hard cap on REC funding, which will be gone this time next year. And time is rather quickly running out to do anything substantive about that.
___

More shortly. NIST 2014 CEHRT Testing Stds, 2nd wave release, more HIPAA breach follies and fines, more on "usability," AAFP on PCMHs and APNs, DURSA, #VDTnow...

M...O...U...S...EEEEE...

Maybe I'll just start a new post. Some of the topics will just continue, as always.
___

CODA
Kansas HIE to hand over authority to the state
September 20, 2012, Anthony Brino, Contributing Editor, Healthcare IT News


TOPKEKA, KS – The Kansas Health Information Exchange will dissolve itself and hand over operations to the state’s health department after a long stakeholder debate about the costs of the public-private HIE, and its regulatory role, in a state with a growing provider-based HIE network.

The Kansas Health Information Exchange (KHIE) board voted last week to transfer its operations to the Kansas Department of Health and Environment by October 2013, when federal grant funding is set to expire. The plan still needs to be approved by the state legislature.

Cost was apparently the largest factor behind the decision. Staffing KHIE as an independent body was estimated to cost $400,000 a year, and the board was considering charging fees from providers or HIEs. Shifting KHIE’s regulatory operations to the state would cost about $54,000, state officials have estimated...


Created in 2010, KHIE evolved from an HIE commission created by then-governor and current U.S. Health and Human Services secretary Kathleen Sebelius. Initially intended to be an HIE, it eventually sought to be more of a regulator, as health systems started building their own infrastructure and connecting to the Kansas Health Information Network, a statewide HIE built with private funding by the Kansas Hospital Association and the Kansas Medical Society.

KHIE’s public-private nature has at times been controversial, and the effort to scale back what some might consider a bureaucracy comes as Republican Governor Sam Brownback’s administration is trying to scale back the role of government in other areas, like transitioning almost all of the state’s Medicaid recpients into managed care organizations.

It’s not entirely clear what will happen to the remainder of the roughly $9 million KHIE received from the Office of the National Coordinator.

“We would like to have some of the stimulus funds," Laura McCrary, executive director of the Kansas Health Information Network, told Government Health IT in August.

"There’s about $5 million left, and we’re hopeful we’ll get a portion of that," McCrary said. "It’d be great to have a bridge fund" for exchange infrastructure in the works.
Hmmm... a BobbyG Photoshop Moment inexorably ensues...


I have to wonder whether the HIT politics in Kansas are as fraught as they are in my state, Nevada. Our situation differs materially, in a way (perhaps it's sort of the inverse). HealtHIE Nevada is not the ONC HIE Grantee. Nevada DHHS is (though we are the ones with "boots on the ground" at this writing).
The Office of Health Information Technology is responsible for administering Nevada’s ARRA HITECH State Health Information Exchange (HIE) Cooperative Agreement, facilitating the core infrastructure and capacity that will enable statewide HIE and coordinating related Health IT initiatives...
As the initial phase of implementation to the State  Health IT Plan, NV DIRECT will soon be deployed.  NV DIRECT will allow participants to send authenticated, encrypted patient health information directly to known, trusted recipients.  This electronic capability will enable providers to share relevant and authorized patient medical information directly and securely with each other.
This latter thing (NV DIRECT) goes to stuff like the DURSA (Data Use and Reciprocal Support Agreement), which I am now tasked with assessing, with respect to resources likely to be necessary for compliance.

You don't just sign a DURSA pro forma.


One last thought before firing up a new one. OK, my Coda can be longer than most peoples' blog posts, I know. Dr. Rob Lambert wrote an interesting post the other day, "Care on the Continuum," wherein he discussed more on his decision to go "Direct Care" (i.e., Direct Patient Pay).
My change from a traditional practice to direct-care has caused me to challenge some of the basic assumptions of the care I’ve given up to this point.  Certainly, the nature of my documentation will radically change with my freedom from the tyranny of E/M coding requirements.

Perhaps the biggest change in my care comes courtesy of the way I get paid.  The traditional way to be paid is for service rendered (either at an office visit or procedures done).  This means that I am financially motivated to give the bulk of my attention to people when they are in the office.  They are paying for my attention, so I try to give them their money’s worth.  The corollary of this is that I tend to not think about people who are not in the office to be seen.  The end-result is an episodic approach to care that is entirely dependent on the patient paying for an encounter.


There is a huge problem with this approach to care: people live their lives between encounters.  Life does not go on hold between office visits for my patients, and the impact of my care is not dependent on what happens in the encounter, but what happens between visits.  My ability to help my patients depends on my ability to affect the continuum.  If I do a good enough sales pitch for a person taking their medications, and if I consider the life-circumstance which may affect their ability to take the medicine, then I am successful.  I don’t learn about the success until their next visit (usually), and I also don’t learn about problems until then.  People are reluctant to call with problems they are having with medications, new symptoms, or other important details, often waiting for many months to tell me things I really want to know.  Perhaps they don’t want to be “one of those patients who calls all the time,” perhaps they don’t understand what I said, or maybe they’re worried I will “force them to come in” to pay for another office visit.  Regardless of the reason, I get very limited interaction with my patients in this episodic care model...

...I keep getting new ideas of how to handle problems differently in this new model of care, but all of them benefit from the fact that it looks at patients before problems pop up, or at least at the time of the problem instead of after a potentially dangerous delay.  The waste in our system is, as has been noted often, huge.  But the assumption that episodic care is the proper model could be the most costly mistake of all.  People are afraid to engage our system because of the cost, and that fear ends up costing everyone by not dealing problems until they are “bad enough.”  Care on the continuum seems to accomplish the main goal of my care: keeping people away from the rest of the health care system unless it’s absolutely necessary.
 I posted a comment.
Very thought-provoking post. Thank you.

This is perhaps a weak analogy, but, nonetheless:


I used to work in Risk Management in a subprime credit card bank. I was the principal “portfolio management” officer/analyst. It was a big part of my job to monitor ongoing the shaky financial “health” of our financially halt and lame cardholders (we used to joke that it was like giving whiskey to alcoholics, granting credit lines to subbies). We had effective data mining pxs and predictive models for everything. Once we booked these people, he had to try to keep them profitably “healthy.”

I was a SAS and S-Plus and all-around RDBMS whiz.


I had access to tons of customer activity data every day. I could track your every transactional “move.”


The principal concerns were, of course, our “patients” “dying” on us (charging off and stiffing us), as well as the relentless outright fraud stuff (i have some funny stories).

We made successively record profits every year of the five that I was there. Data-driven, baby.

See bgladd.blogspot.com/2008/12/tranche-warfare.html

Before you go cracking on me, I quit in 2005 to go back into HIT work, at a 23% salary reduction. Today, I could make 3x my current salary (which is not quite what I earned at the bank back then when I left) were I to go back into “distressed consumer debt modeling and management.” The comp package numbers give me pause, but, I will not. Ever again. It’s just too jive. I have to sleep. And look in the mirror.


I will stay in the HIT space until I retire.


I have utter respect for clinicians. I work with them every day. I don’t see how y’all do it.
And then another, later in the discussion, in response to a prior comment:
“In the aforementioned DPC paper, the evidence suggests a significant decrease in ED visits, surgeries, hospitalizations and specialist visits. That may be good for the patient and whoever is picking up healthcare costs but obviously one person’s cost savings is another’s revenue. It’s clear why some orgs won’t embrace DPC if they see it harming their bottomline.”
___
This has long been the reform conundrum.

“Every misspent dollar in the health care system is part of someone’s paycheck.”


- Brent James, MD, M.Stat, IHC, 1995, during our CQI training sessions in SLC


Brent also noted (paraphrasing here) “Let’s not kid ourselves that we’re gonna QI our way out of the larger problem. Giving the best possible care today only ensures that you’re gonna have an older and sicker and more expensive patient down the line.”


See also “Allocating Health Care Morally,” 1994


www.law.harvard.edu/faculty/elhauge/pdf/82califlrev1449.pdf
 

It continues to be a socioeconomic and moral perplex.

Wednesday, September 12, 2012

“Federal funding of IT was a step in the right direction, but it has also created a guaranteed customer base for electronic medical records, so vendors have less incentive to improve their products to meet clinicians needs.”

Is ‘Meaningful Use’ Safe?
Despite CMS praise, clinicians are wary of health IT shortcomings
...Last November, the Institute of Medicine (IOM) released a scathing critique of HIT’s current ability to ensure patient safety. As the federal government invests billions of dollars to encourage hospitals and healthcare providers to adopt HIT, the IOM report said, improvements in care and safety are not yet established, and little evidence exists that quantifies the magnitude of the risk associated with HIT problems—partly because many HIT vendors discourage providers from sharing patient-safety concerns with nondisclosure and “hold harmless” provisions in contracts that shift the liability of unsafe HIT features to care providers...
...“Vendors typically regard usability of their products as a convenience request by clinicians; any errors are regarded as training issues for physicians,” Dr. Rogers says. “But the way that data is presented on a screen matters—if it is difficult to input or retrieve data and leads to cognitive or process errors, that’s a product redesign issue for which vendors should be held accountable.”

Dr. Koppel says many HIT systems originated from billing system applications “and were not initially designed with the clinical perspective in mind. Hospitalists have to be particularly focused on usability of HIT systems when it comes to patient-safety impacts. They’re not the canary in the coal mine, they’re the miners—often the teachers guiding other clinicians on HIT use.”...
Click the title for the link. Read the entire article. Discusses many of the issues that I've been airing since I started this blog. Per the title of this post, it's difficult to argue with critics who argue that the HITECH initiative has been in large measure a corporate welfare program in which already stressed EPs and EHs principally serve as conduits for federal dollars.

And here I am on numerous occasions, biting the hand that feeds me personally. Kinda like Jonathan Bush.

UPDATE

It being National Health IT Week in Washington, US House Rep. Phil Gingrey (R-GA), an OB/GYN and co-chair of the GOP Doctors Caucus, stopped in to express his support for EHRs, despite the fact that “lots of doctors aren’t happy with EHRs…they don’t want ‘em. There are physicians on the hill this week protesting meaningful use.” In response to an EHR vender asking exactly what could be done to help government drive adoption levels and support of EHRs among physicians, Rep. Gingrey said the equivalent of you tell me, suggesting that industry should answer the question, not Congress...
The problem isn’t that EHR technology is all bad, it’s that physicians have drastically different workflows and needs, and patient interaction in the context of EHRs only complicates thing further. It would appear that market forces alone have not sufficiently addressed these issues. Maybe Apple, which announced its iPhone 5 today, needs to get into the HIT game.
Interesting.Yeah, AppleCare America. The thought had occurred to me.
___

More from The Hospitalist.


HELP NEEDED: OPEN SYSTEMS AND MODULAR ARCHITECTURE

Today’s EHRs can be thought of as monolithic and closed, with an all-or-nothing, static set of features. On the other hand, think of your smartphone and all the apps (modules) you openly download and, if desired, you delete. This is the vision of a healthy, open, modular EHR ecosystem:
  • Imagine a busy clinician providing real-time feedback about a negative or user-hostile feature in the EHR;
  • Imagine that feedback incorporated—in days or hours—by engineers to create a new version of the application;
  • Imagine a VTE prevention QI team conducting a Google-style search of a group of patients to determine rate of pharmacologic prophylaxis and average VTE risk of that group; and
  • Imagine a hospitalist having five apps to choose from to automatically calculate the readmission risk of a patient: You could choose the best one and delete the others.
  • The Office of the National Coordinator for Health Information Technology has awarded a series of grants through the Strategic Health IT Advanced Research Projects (SHARP) program to help solve the vexing problems of our closed, innovation-stifling EHR environment. The output of SHARP will be “improvements in the quality, safety, and efficiency of healthcare, through advanced information technology.”
It won’t happen overnight, but perhaps we can hold out hope that there will be a day when EHRs help, not hinder, the QI process.
Inflexible, Big-Box EHRs Endanger the QI Movement
More...
Greg Maynard, MD, MSc, SFHM, senior vice president of SHM’s Center for Hospital Innovation and Improvement, recently provided testimony to the Office of the National Coordinator for Health Information Technology about the challenges current EHRs present to QI efforts and what features EHRs need to incorporate to better serve the needs of patients and clinicians. Dr. Maynard answered a few questions for The Hospitalist:

Q: What is it about current EHRs that make continuous improvement so difficult?

A: EHRs were built for fiscal and administrative purposes, not for quality improvement and safety. The administrative/fiscal roots of today’s IT systems lead to poor availability of clinical, quality, and safety data. In many medical centers and practices, the great majority of information available is months-old administrative data, which does not lend itself to rapid cycle improvement.

Q: Why is the PDSA cycle endangered in most systems?


A: EHRs often do not facilitate rapid-cycle, PDSA-style improvements on a small pilot scale. Most improvement teams get one shot to get the clinical decision support and data-capture tools correct after months of waiting in queue and development time. Any request for revisions and refinements is treated as a failure of the improvement team, and it is often difficult or impossible to pilot new tools in a limited setting.

Q: What features would you like to see in EHRs that would facilitate QI?


A: We need a user-friendly interface for clinicians and for data analysts/reporters. Other industries have common data formats to allow for sharing of information across disparate systems. We need the same capability for clinical information in healthcare. Also, a change in architecture of EHRs and other health IT tools that allows for not just interoperability but substitutable options is required. In the more “app”-like environment, innovation and flexibility would be the rule. An underlying architecture could have different plug-and-play modules for different functions. Some companies are overcoming the current barriers to provide wonderful, easy-to-generate and useful reports, but most are stymied by proprietary systems.
Great stuff. All true. "Other industries have common data formats to allow for sharing of information across disparate systems. We need the same capability for clinical information in healthcare." Pardon me if I don't hold my breath. Going to have to seriously reform the payment paradigm for that to happen.

ONC UPDATES

New interactive "Cybersecurity Game" launched.


Pretty nice, actually (notwithstanding that the animated graphics are about three generations back). Good for staff who are visual learners. Has a lot of embedded links to authoritative resources in the scoring summary you get after completing it. You don't have to ID yourself (I signed in as "Charlie Tweeder"), and you can re-take it at will. You can get through it in 20-30 minutes. Worth your time if you work with ePHI.

ONC HIT ADOPTION DASHBOARD
Providers Nationwide Adopt Health IT

Check Out How HITECH Programs Are Helping
Are you interested in better understanding health IT and the transformative changes that electronic health/medical records are having in our nation's health care system? The Health IT Dashboard presents key information and data to enable collaborative monitoring of the impact of federal policies, programs, and research activities related to health IT. Return to this web site regularly to explore and download new datasets and statistics as they become available.

Top of the heap: Minnesota (with Wisconsin 1% behind, right on their heels). Bottom of the barrel: Puerto Rico, Louisiana, New Jersey, Mississippi, and my state, Nevada (at 23%).

Very nicely put together. You can drill down fairly far state-by-state, e.g., my service area to date:



Great job, ONC
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DANNY LIEBERMAN, PATHCARE

Twitter is turning up many HIT nuggets for me.
Let’s make physicians more productive instead of stimulating health IT revenues
...Most of the CMS Meaningful Use reporting requirements do not contribute to the quality of patient care. That vacuum is a classic market opportunity for innovative healthcare startups to focus on physician needs for better physician-patient management, stress reduction and improved communications with less effort using modern tools like private social networking for healthcare.
Very busy, prolific HIT writer and doer. Like I don't already have enough to read and fathom.
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UPDATE

ONC pushes back on the naysayers.

Now is the Time for Meaningful Use!
Dr. Farzad Mostashari, National Coordinator for Health Information Technology ,
Mat Kendall, Director, Office of Provider Adoption Support, ONC , and
Robert Tagalicod, Director, Office of E-Health Standards and Services, CMS


Recognizing the need to strike a balance between the urgency of modernizing our health care system and the pace of change that can be absorbed by providers and health IT vendors, CMS and ONC have implemented the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs in three stages, with each stage adding increased functionality and advanced concepts designed to improve patient care, enhance care coordination, and increase patient and family engagement. Released in July 2010, the final rules for Stage 1 focus on functionalities that support the electronic capture of data and allow patients to receive electronic copies of their own health record.

It’s important that providers take the steps now to register for the EHR Incentive Program on the CMS website. October 3, 2012, is the last day for eligible professionals who want to collect the maximum Medicare EHR incentive payment to begin their 90-day reporting period in 2012. Eligible professionals who wait until next year can still participate but will receive reduced incentives.

How Meaningful Use Can Improve Outcomes and Efficiencies

Many providers are already seeing how meaningful use of health IT like EHRs can help to improve outcomes and result in efficiencies, such as those who are working with the regional extension center (REC) established by the North Carolina Area Health Education Center Program (NC AHEC). Through the use of EHRs and features like clinical decision support and point of care reminders, the positive impact on quality of care has been significant...

Meaningful Use Stage 2


The Stage 2 Meaningful Use final rules we recently issued were intentionally designed to help providers implement health IT that will allow them to improve care and transform delivery. The Stage 2 rules focus on increasing standards-based health information exchange between providers and with patients. We expect that future stages of meaningful use will continue to advance health IT capabilities by focusing on advanced clinical decision support and patient engagement tools. The staged implementation of the meaningful use criteria is being leveraged to harmonize quality measures across federal agencies—all with the goal of improving care for patients and resulting in better health more generally and to simplify the process for providers so that they can focus on the needs of their patients....
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Click the post title for the link.

More to come. Next week. Off to my niece's wedding.

Tuesday, September 11, 2012

A sad anniversary

 
Cancer Connection to 9/11 Dust Is No Surprise
REPORTER's NOTEBOOK
By LIZ NEPORENT
Sept. 11, 2012


When the doctor diagnosed me with kidney cancer this past spring, I wasn't surprised, not one bit. I had known it was coming for nearly 11 years.

On the morning of Sept. 11, 2001, I watched from my living room window as terrorists drove the second plane into the south tower of the World Trade Center. I will never forget how the plane disintegrated into the side of the building and then shortly after, tiny dots began shooting outward into the sky. Those dots were people falling and jumping from the top floors and as I looked closer, I could make out skirts and ties flying up over their heads and shoes slipping from their feet.

I felt I had to do something.

I ran out of my apartment and down the street until I saw an ambulance and some EMTs. When I offered to help, an EMT simply handed me a pair of latex gloves and told me to start assessing the condition of people sitting and lying on the ground.

Just as I was helping a woman named Linda who was having trouble breathing into the ambulance, one of the EMTs abruptly grabbed my arm. Without explanation, he hauled me up the street and threw me against the side of a building. I didn't have time to think about what was happening. Then everything went black.


Suddenly, all the air was gone. In its place was a black, viscous solid. It was so thick I couldn't pull it into my lungs. It was like trying to breathe underwater. After a few desperate seconds I thought to peel off one of my latex gloves, place it over my mouth and hyperventilate into it.

Eventually the EMT and I felt our way along the buildings, broke into a card shop and were able to find better air.

Over the years I've thought a lot about that black sludge. I realized immediately it would be a problem. When I reunited with my husband several hours after the attacks and we walked out of lower Manhattan, I remember telling him that this would come back and bite me in the ass someday. Even then, I was sure of it.

So despite living a healthy lifestyle and have no family history, the cancer diagnosis was not unexpected. I didn't know when it would come but I knew that it would...
9/11 health program to cover 50 types of cancer; Stricken responders get enhanced coverage
09/11/2012

NEW YORK - The federal government has added about 50 types of cancer to the list of Sept. 11 World Trade Center-related illnesses that will be covered by a program to pay for health coverage.

The National Institute for Occupational Safety announced the change Monday, the eve of the 11th anniversary of the terrorist attacks.


The publication of this final rule marks an important step in the effort to provide needed treatment and care to 9/11 responders and survivors through the WTC Health Program, NIOSH director Dr. John Howard said in a statement.


The institute said last June that it favored expanding the existing $4.3 billion Sept. 11 health program to include people with more than 50 types of cancer. That move followed years of lobbying by construction workers, firefighters, police officers, office cleaners and others who fell ill in the decade after the terror attack, which destroyed the 110-story twin towers, spewing toxic dust.


NIOSH acted after an advisory committee made up of doctors, union officials and community advocates recommended that cancer be added. Previously, the aid effort had covered only people with mostly less-serious ailments, including asthma, acid reflux disease and chronic sinus irritation...

Monday, September 10, 2012

Draft 2014 CEHRT Certification Testing Stds Issued

2014 Edition Draft Test Procedures
The Office of the National Coordinator for Health Information Technology (ONC) has posted the first wave of draft Test Procedures and applicable test data files for the 2014 Edition EHR certification criteria. The Test Procedures, once finalized and approved by the National Coordinator, will be used for testing and certifying EHR technology under the ONC HIT Certification Program (formerly referred to as the Permanent Certification Program or PCP). The Test Procedures are being developed in collaboration with the National Institute of Standards and Technology (NIST).
I'm not seeing much new here, conceptually, at first blush. More "user acceptance testing." But, I will review all of the drafts when I get to the office. One fundamental example:

CPOE
This test evaluates the capability for a Complete EHR or EHR Module to enable a user to electronically record, change, and access the following order types, at a minimum:

(i) Medications; 

(ii) Laboratory; and 
(iii) Radiology/imaging.

The test procedure is not prescriptive about the method [emphasis mine] used to change an order. For example, changing an order does not require changing an existing instance of an order. 


Change may be accomplished through discontinuing/canceling an existing order and entering a new order.
 

This test procedure is organized into three sections:
Record - evaluates the capability to electronically enter orders for medications, laboratory, and radiology/imaging within the EHR system
  • The Tester enters the ONC-supplied Test Data orders for medications, laboratory, and radiology/imaging
  • The Tester verifies that the orders are recorded in the EHR
Change - evaluates the capability for a user to electronically change entered orders for medications, laboratory, and radiology/imaging in the EHR
  • The Tester displays the entered orders for medications, laboratory, and radiology/imaging
  • Tester changes the medications, laboratory, and radiology/imaging orders
  • The Tester verifies that the changed orders are accurate and complete
Access - evaluates the capability to access and display the orders that have been previously entered into the EHR
  • The Tester displays the orders for medications, laboratory, and radiology/ imaging entered during the test
  • The Tester verifies that the displayed order data are accurate and complete
This is all yet again just about "functionality" in the "capability" sense. If it takes the tester 8 seconds or 80 minutes is irrelevant to certification here (that pesky "usability" thing). After reviewing all 10 pages of this draft cert procedure, I find nothing about grading "ease of use."

I also have to chuckle that they "give you the answers in advance," too (the supplied "test data") for each criterion. Gives me that recurrent Clinic Monkey Moment.
Public Review and Comment Process

The draft Test Procedures and applicable test data files are posted on the ONC website and made available for public review and comment. (If there is no test data link, test data are either not required or supplied by the vendor.) The first wave is posted below; additional waves will be added to this website on a weekly or bi-weekly basis until all have been posted. A two-week comment period will follow
each wave [emphasis mine] throughout September and October 2012.

Comments and suggestions should be submitted to ONC.Certification@hhs.gov. All submissions should include "Test Procedure" in the subject line.

After draft Test Procedures have been through the public comment and review process, ONC will revise and finalize them. The final set of Test Procedures is expected to be available for use in testing and certification in early 2013.
That's a pretty small review and comment window. I would exhort everyone working in this area to review the drafts and make your opinions known. 
___

"MEDKAZ"?

This is curious. Came my way via Twitter.




A "crowdsourcing" venture capital initiative.
Fuel $10,000 or more:
Any contribution of $10,000 receives: a featured listing on our Web site as a MedKaz Strategic Partner. This tells the world that you support our unique approach to making sure people control their “damn records!” Pick your support level: Silver - $10,000, Gold - $20,000, Platinum - $50,000. Open to corporations, other business organizations, non-profits and individuals.
Wow.
___

BOBBYG GETS A BIT OF HIT PRESS "INK"


Should HIE vendors follow HIPAA rules?
Patrick Ouellette,  September 10, 2012

After posting a health information exchange (HIE) security best practices article last week, a reader posed an interesting question: Where do HIE vendors fit into the equation?...

...Bobby Gladd, senior meaningful use adoption support project coordinator and HIPAA staff resource for HealtHIE Nevada, thinks that the requirements need to be in line with what HIEs and healthcare providers have to deal with. He believes that the language in Sec. 13401 of the HITECH Act applies to vendors and they should obey security rules without HIEs requiring them to do so:

“(a) Application of Security Provisions. — Sections 164.308, 164.310, 164.312, and 164.316 of title 45, Code of Federal Regulations, shall apply to a business associate of a covered entity in the same manner that such sections apply to the covered entity. The additional requirements of this title that relate to security and that are made applicable with respect to covered entities shall also be applicable to such a business associate and shall be incorporated into the business associate agreement between the business associate and the covered entity.”


The wording in this section of the act certainly looks like it should apply to both vendors and HIEs. Gladd, as an HIE and EHR consultant, works with vendors all the time that don’t need to follow HIPAA rules by the book. He said that vendors have access to ePHI and should adhere to the same standards as HIEs, which don’t even store data. What if a vendor’s employee is unhappy with his job or wants to steal information? He said that while vendors aren’t the sole reason for data breaches, there should be HIPAA audits for these companies as well to reduce risk...
Thanks, Patrick. I would just add that a close read of my prior post shows that I support making all EHR vendors submit to 45 CFR 164.3, not simply HIE vendors.
___

INTERESTING TWITTER FIND TODAY


I just signed up with this site. Ran across it via a tweet. Maybe nothing will ever come of it. But, one the other hand, perhaps there will be some good EHR "usability" nuggets here and there.
Boxes and Arrows is devoted to the practice, innovation, and discussion of design; including graphic design, interaction design, information architecture and the design of business. Since 2001, it’s been a peer-written journal promoting contributors who want to provoke thinking, push limits, and teach a few things along the way.

If you’re interested in improving the way information architecture is done, if you find yourself sparking provocative conversation on interaction design topics in your spare time, and if you go out of your way to help everyone in your office think differently about everything from the design process to software, we want to work with you.
See their latest post "Designing Screens Using Cores and Paths. Designing from the inside out." It just might be that HIT interfaces are simply too necessarily cognitive-load heavy to lend themsleves wholly to principles appropriated from other business spaces. Dunno.

ONC USABILITY UPDATE

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IT'S NATIONAL HEALTH IT WEEK!


I'd have liked to have been in DC this week. Lots of cool events going on. Hope I can get to catch a few of the online events. Our REC is not doing any local stuff in support of it. We dropped the ball on that, IMO.
___


Mostashari calls for vendors to add Blue Button quickly
September 11, 2012 | Mary Mosquera, Government Health IT


Farzad Mostashari, MD, the national health IT coordinator, has challenged vendors to make it easy for consumers by early 2013 to view, download and transmit to another party their health information in the form of a Blue Button feature.
The Office of the National Coordinator for Health IT has established a Twitter hashtag of #VDTnow for companies and organizations to post their commitment to establishing the feature.

Implementing the functionality for view, download and transmit (VDT) to a third party, “I think, is underappreciated for how significant that’s going to be to the concept of consumer-mediated health information exchange,” Mostashari said at a Sept. 10 ONC summit on consumer health IT...
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More to come...

Tuesday, September 4, 2012

45 CFR 164.308 and HIT vendors

ARRA/HITECH Sec. 13401. Application of Security Provisions and Penalties to Business Associates of Covered Entities; Annual Guidance on Security Provisions.

(a) Application of Security Provisions.—Sections 164.308, 164.310, 164.312, and 164.316 of title 45, Code of Federal Regulations, shall apply to a business associate of a covered entity in the same manner that such sections apply to the covered entity. The additional requirements of this title that relate to security and that are made applicable with respect to covered entities shall also be applicable to such a business associate and shall be incorporated into the business associate agreement between the business associate and the covered entity.

(b) Application Of Civil And Criminal Penalties.—In the case of a business associate that violates any security provision specified in subsection (a), sections 1176 and 1177 of the Social Security Act (42 U.S.C. 1320d–5, 1320d6) shall apply to the business associate with respect to such violation in the same manner such sections apply to a covered entity that violates such security provision.

(c) Annual Guidance.—For the first year beginning after the date of the enactment of this Act and annually thereafter, the Secretary of Health and Human Services shall, after consultation with stakeholders, annually issue guidance on the most effective and appropriate technical safeguards for use in carrying out the sections referred to in subsection (a) and the security standards in subpart C of part 164 of title 45, Code of Federal Regulations, including the use of standards developed under section 3002(b)(2)(B)(vi) of the Public Health Service Act, as added by section 13101 of this Act, as such provisions are in effect as of the date before the enactment of this Act.


§160.103 Definitions

Business Associate:
(1) Except as provided in paragraph (2) of this definition, business associate means, with respect to a covered entity, a person who:

(i) On behalf of such covered entity or of an organized health care arrangement (as defined in §164.501 of this subchapter) in which the covered entity participates, but other than in the capacity of a member of the workforce of such covered entity or arrangement, performs, or assists in the performance of:

(A) A function or activity involving the use or disclosure of individually identifiable health information, including claims processing or administration, data analysis, processing or administration, utilization review, quality assurance, billing, benefit management, practice management, and repricing; or

(B) Any other function or activity regulated by this subchapter; or

(ii) Provides, other than in the capacity of a member of the workforce of such covered entity, legal, actuarial, accounting, consulting, data aggregation (as defined in §164.501 of this subchapter), management, administrative, accreditation, or financial services to or for such covered entity, or to or for an organized health care arrangement in which the covered entity participates, where the provision of the service involves the disclosure of individually identifiable health information from such covered entity or arrangement, or from another business associate of such covered entity or arrangement, to the person.

(2) A covered entity participating in an organized health care arrangement that performs a function or activity as described by paragraph (1)(i) of this definition for or on behalf of such organized health care arrangement, or that provides a service as described in paragraph (1)(ii) of this definition to or for such organized health care arrangement, does not, simply through the performance of such function or activity or the provision of such service, become a business associate of other covered entities participating in such organized health care arrangement.

(3) A covered entity may be a business associate of another covered entity.
HIPAA §164.308 Administrative safeguards.
(a) A covered entity must, in accordance with §164.306:

(1) (i) Standard: Security management process. Implement policies and procedures to prevent, detect, contain, and correct security violations.

(ii) Implementation specifications:

(A) Risk analysis (Required). Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the covered entity.

(B) Risk management (Required). Implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to comply with §164.306(a).

(C) Sanction policy (Required). Apply appropriate sanctions against workforce members who fail to comply with the security policies and procedures of the covered entity.

(D) Information system activity review (Required). Implement procedures to regularly review records of information system activity, such as audit logs, access reports, and security incident tracking reports.

(2) Standard: Assigned security responsibility. Identify the security official who is responsible for the development and implementation of the policies and procedures required by this subpart for the entity.

(3) (i) Standard: Workforce security. Implement policies and procedures to ensure that all members of its workforce have appropriate access to electronic protected health information, as provided under paragraph (a)(4) of this section, and to prevent those workforce members who do not have access under paragraph (a)(4) of this section from obtaining access to electronic protected health information...
HIPAA / Meaningful Use security compliance, it's not just for EPs and EHs any more.

I've been reviewing the text of the HIPAA/HITECH Omnibus Rule, frustrated that some federal entity has reeled it back in from final release after it had been sent to OMB. As noted on Lexology.com (it may be firewalled; I am a subscriber):

We have seen substantial delay in publication of the long-awaited HIPAA/HITECH Omnibus Final Rule, sometimes affectionately referred to as the “Mega Rule.” Health Data Management reported on June 6 of this year that Farzad Mostashari, national coordinator for health information technology, had said that the HIPAA Mega rule, which will include modifications to the privacy and security rule, breach notification and enforcement, “should’ be published by “the end of summer.” After previous disappointments and delays in regulations in other contexts from the U.S. Department of Health and Human Services, however, it may be noteworthy that Mr. Mostashari was said to have used the word “should,” and did not specify the summer of what year, e.g., 2012, 2013, 2014, etc.   

Now there has been some scuttlebutt that the Mega Rule may not surface until after Election Day, November 6, 2012, perhaps because of concerns about potential political implications...
 "After Election Day?" Why should I be surprised? They're all afraid of the potential re-election blowback, I guess.

Whatever. HITECH Sec 13401 et seq are pretty clear. Vendors are in fact BAs to CEs (given that they necessarily routinely have access to CEs' PHI), and, as such, are bound by the Security Rule and everything it entails of relevance. I was assisting a clinic this morning with some MU Core Measures items, and watched as the O.M. got Support on the phone and gave him VPN entry into their server.

I intend to press the point. It's not a popularity contest for me. It's really no "contest."
___

August 5th quickie a.m. update

BEHAVIORAL HEALTH and MEANINGFUL USE

Really nice HITRC Privacy and; Security CoP presentation yesterday by Sharon Bari of NYeC.


Very nicely done. Issues having to do with 42 CFR 2. Difficult area.
___

INTERESTING NEWS BITE FROM KFF
Latest Round Of Health IT Regs Will Be Topic Of Capitol Hill Hearing
CQ HealthBeat: Next Stage Of Meaningful Use Regulations Drawing Hill Scrutiny. Consumer advocates are giving good marks to the latest round of federal rules designed to spur the use of information technology to improve the quality and efficiency of health care. Hospitals and vendors? Not so much — but each for different reasons. For their part, lawmakers haven't had much so to say so far, but at least one House committee may hold a hearing later this month to review the rulemaking program, which aims to promote the "meaningful use" of health IT by paying providers who employ the technology higher Medicare and Medicaid payments and paying less to providers who don’t (Reichard, 9/4).
The full article is firewalled at CQ HealthBeat.


A sales rep told me their subscriptions start at $2,500. No sale, bro'. That's public information, basically. I'll find it (I already emailed my Congressman).

UPDATE

I got a phone call today from Ryan McBride, one of my Congressman's aides (Dr. Joe Heck, R-NV). We had a great chat. Ryan gave me his email address, and promised to keep me in the loop should a hearing be scheduled.

I offered to come to DC on my own dime and testify at such a hearing, from a front-line HIT/Meaningful Use grunt POV.

ALSO NEWSWORTHY

September 4, 2012

Marilyn B. Tavenner 

Centers for Medicare & Medicaid Services 
Acting Administrator 
U.S. Department of Health and Human Services 
Hubert H. Humphrey Building,
Room 445-G 200 Independence Ave SW
Washington, DC 20201

RE: Medicare Program; Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2013

Dear Administrator Tavenner:
...CMS anticipates, barring changes to current law, an approximate 27 percent cut in physician payment rates for 2013 under the sustainable growth rate (SGR) methodology. The 27 percent rate cut is based on a March 2012 analysis from CMS. This massive cut will have catastrophic consequences on medical group practices and the patients they serve. Although Congress has repeatedly taken action to override most of the SGR’s prescribed fee schedule reductions, these temporary “fixes” have increased both the size of future cuts and the cost of repealing the flawed payment system. As a consequence, the frequent need to override increasingly steeper cuts is undermining confidence in the Medicare program and jeopardizing the financial stability of medical practices. The current environment is forcing group practices to make operational changes that severely challenge their ability to provide quality care to Medicare beneficiaries...
  • MGMA urges CMS to use its regulatory authority to deem all physicians that meet meaningful use requirements (and therefore electronically prescribe and report clinical quality measures under that program) as also successfully meeting all e-prescribing and PQRS requirements in each corresponding performance year. Eligible professionals (EPs) that successfully meet the meaningful use requirements should automatically earn the bonus for PQRS and avoid penalties for both e- prescribing and PQRS.
  • MGMA objects to imposing financial penalties on physician practices for unsuccessfully participating in incentive or quality reporting programs, such as e-prescribing, PQRS and the value- based payment modifier. If penalties must exist, the government should only apply them after taking into account performance during the relevant year, rather than previous years...
Sixteen pages of articulate detail. Some of it is pretty arcane even to me, but, yes, there's too much going on all at once. Add in all of CMS 5010, PQRS, Stage 2, ICD-10, the gamut of CMS QIO initiatives, well. we run the risk of burning clinicians out.
___

ONC CERTIFIED EHRs, as of Sept 5th 2012



We extracted all 2011-2012 EHR Certs to date from the CHPL site (they don't make it easy) and whacked on them in Excel briefly (.xls). There are 5 tabs, a couple of them simple pivot tables summarizing Cert product counts by vendor (modular and complete aggregated by Outpt/Inpt for now -- and, Cerner is far and away the Big Dog here, both ambulatory and inpatient).

Had we a SAS account we'd have ground this stuff up 16 ways to Sunday by now. We gotta get up to speed on the "R Language".

So, let's see 1,295 complete outpatient systems alone to date, times the average Cert fee:


~$44.4 million.
 ___

SPEAKING OF $$$, UPDATE, JUST OUT,
MU PAYMENTS THRU JULY 2012 (pdf)


$6.6 billion thus far.

In others words, 10x the entire 4-year REC funding potential. I have to think we've added value.

___

SEPT 6TH NEWS UPDATE


Best Care at Lower Cost: The Path to Continuously Learning Health Care in America

381 pages of more light bedtime reading. I mounted a copy here (5 mb), and annotated it with PDF "yellow highlighter" first-pass markups on a number of keywords/phrases, e.g.,
  • Electronic medical record(s)
  • Electronic health record(s)
  • Meaningful use
  • Health information exchange(s)
  • Workflow(s)
  • Affordable Care Act
  • HIPAA
  • Six Sigma
  • Lean
  • PDSA
  • Regional extension center(s) -- no hits, sadly
Just getting started in review.
___

ERRATUM: "HEALTHCARE SOCIAL MEDIA"


Cute logo. They hooked up with me via Twitter. Not sure exactly what they do.
___

SEPT 7TH UPDATE

 
Federal Privacy Officer Offers Insights

Article and mp3 Interview (10:28) with ONC's Joy Pritts.
I emailed her regarding the Security Rule 164.308 concerns I expressed at the outset of this post. Be very interested in her response. She is, after all, an attorney.
___

AND I QUOTE YOU...
“Established technology is being given a federally funded new lease on life. Traditional health software now is on Medicare, being kept alive like grandma.” [It's a] cash for clunkers program for health IT."

“I know of no industry where technology is as despised as it is in health care. It’s a statement that it took government money to incentivize healthcare providers to finally do what virtually every other industry has done .”
- AthenaHealth CEO Jonathan Bush
___

SILVER STATE HIT NEWS NUGGET



And, in other Nevada HIT news regarding how this stuff is actually beginning to get done:
HealtHIE Nevada Provides eHGT's eHealth Image Exchange Capability to Community-Based Health Information Exchange Users
Steinberg Diagnostic leads, reducing costly duplicate exams and unnecessary radiation exposure for patients
___

GOOGLING ON A SATURDAY MORNING
(Sept 8th)

@ARCHealthIT
Yeah, but, I'm a newbie "Tweep" myself, only been actively doing it a couple of months as well. These Things Take Time.


___

More to come...

Monday, September 3, 2012

One month to go before risking missing the 2012 Attestation boat


You had better be checking your EHR dashboards at least weekly starting this week. After October 3rd, there will be some criteria regarding which you will be unable to make up any ground.

On the Medicare side, having to attest in 2013 (no, it does not traverse the calendar year) will cost you $5,000 per EP, $3,000 of that in year one. I have one exasperating 11-doc Internal practice Med that may well miss the ferry. $55k lost total, $33k at the end of 2013.