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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.
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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. 
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"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.
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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.
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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.
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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."
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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.
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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.
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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.
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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.

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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.
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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
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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.


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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.

Wednesday, August 29, 2012

Single Source of Truth

The Consolidated CDA implementation guide defines nine different types of commonly used CDA documents, including:
  • Continuity of Care Document
  • Consultation Notes
  • Discharge Summary
  • Imaging Integration, and DICOM Diagnostic Imaging Reports
  • History and Physical
  • Operative Note
  • Progress Note
  • Procedure Note
  • Unstructured Documents
Each of these nine documents has a document template defined in The Consolidated CDA implementation guide, which will now be the single source of truth for implementing these CDA documents.
___

Dr. Farzad Mostashari / National Coordinator for Health Information Technology
Common Standards and Implementation Specifications for Electronic Exchange of Information: The Meaningful Use Stage 2 final rules define a common dataset for all summary of care records, including an impressive array of structured and coded data to be formatted uniformly and sent securely during transitions of care, upon discharge, and to be shared with the patient themselves. These include:
  • Patient name and demographic information including preferred language (ISO 639-2 alpha-3), sex, race/ethnicity (OMB Ethnicity) and date of birth
  • Vital signs including height, weight, blood pressure, and smoking status (SNOMED CT)
  • Encounter diagnosis (SNOMED CT or ICD-10-CM)
  • Procedures (SNOMED CT)
  • Medications (RxNorm) and medication allergies (RxNorm)
  • Laboratory test results (LOINC)
  • Immunizations (CVX)
  • Functional status including activities of daily living, cognitive and disability status
  • Care plan field including goals and instructions
  • Care team including primary care provider of record
  • Reason for referral and referring provider’s name and office contact information (for providers)
  • Discharge instructions (for hospitals)
In addition, there are a host of detailed standards and implementation specifications for a number of other transactions including quality reporting, laboratory results, electronic prescribing, immunizations, cancer registries, and syndromic surveillance (see below for a detailed list).

What does this mean? It means that we are able to break down barriers to the electronic exchange of information and decrease the cost and complexity of building interfaces between different systems while ensuring providers with certified electronic health record (EHR) technology have the tools in place to share, understand, and incorporate critical patient information. It also means that providers can improve workflow and dig deeper into the data. Certified EHR technology must be able to support identity reconciliation—matching the right record to the right person—and will give doctors the tools to reconcile a new document with the information already on file, for instance by incorporating medications and problems identified by another provider into a patient’s record,  thus creating a single source of truth. [emphases mine - BG]
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"In Information Systems design and theory, as instantiated at the Enterprise Level, Single Source Of Truth (SSOT) refers to the practice of structuring information models and associated schemata such that every data element is stored exactly once (e.g., in no more than a single row of a single table). Any possible linkages to this data element (possibly in other areas of the relational schema or even in distant federated databases) are by reference only. Thus, when any such data element is updated, this update propagates to the enterprise at large, without the possibility of a duplicate value somewhere in the distant enterprise not being updated (because there would be no duplicate values that needed updating)."

"ADT 44"

From an email I found online today, embedded in a RHIO pdf document (it's an HL7 messaging error thing):

ADT A44 (Move account information — patient account number)
The intention of these messages is to move an account number, which may or may not have associated documents, from one patient to another.
These types of messages could result from inadvertently selecting "John Doe SR", as opposed to "John Doe JR", for example. Whereas "John Doe JR" is the correct patient. Once the patient is changed/corrected, the resulting A44 message initiates a move of all the documents associated with this account to the corrected patient ID.
In this example, the correct Patient ID = "John Doe JR", and the Prior Patient ID = "John Doe SR".
Investigation
Historic data analysis for all A44 messages received for CFRHIO:
  • Total A44 messages received thru 7/31 = 6,417
  • Total "Prior Patient IDs" with associated documents = 368
  • FHO = 213
  • OH = 155
  • Total associated documents accessed = 0
Action Plan
A44 message processing moving forward:
  • Short-Term: (Complete) Manually disable the viewing of documents for the "Prior Patient ID" or MRG-1, as specified in the A44 messages.
  • Medium-Term: (In Progress) Manually process the account move for all A44 messages, both historic and new inbound.
  • Long-Term: (Investigating) Implement non-manual process to properly process new A44 messages.
Thank you for your understanding.
Interesting. Maybe it should have been subjected to the RDBMS equivalent of "rigorability." I'm not at liberty to discuss what specifically brought this issue to my attention, but, it points up the widespread chronic data linkage problem posed by a continuing lack of a unique (no-dupes, no nuls), secure national patient identifier (Like, you know, a HIC number writ large).

NO DUPES, NO NULS, 
AUTHENTICATED PRIMARY KEY IDENTIFIER


What shall be the reliable identifier? to wit, the much unloved SSN:
What happens to the money assigned to people using false identities, or names matched with the wrong Social Security Number (SSN), or newlyweds who forgot to register their name changes with the Social Security administration?

The answer lies in a little-known aspect of the Social Security behemoth known as the Earnings Suspense File (ESF).
A necessarily dynamic probabilistic combination of Last/First/DoB/Gender/SSN?

I worked for a number of years in the Risk Management Department of a credit card bank. Among my duties was ongoing portfolio modeling, management, and fraud monitoring, all which entailed a good bit of data mining, repeatedly running SAS code against millions of customer account records.

Wherein, as I wrote in 2002,
...our department has the endless and difficult task of trying to statistically separate the “goods” from the “bads” using data mining technology and modeling methods such as factor analysis, cluster analysis, general linear and logistic regression, CART analysis (Classification and Regression Tree) and related techniques.

Curiously, our youngest cardholder is 3.7 years of age (notwithstanding that the minimum contractual age is 18), the oldest 147. We have customers ostensibly earning $100,000 per month—odd, given that the median monthly (unverified self-reported) income is approximately $1,700 in our active portfolio.
Yeah. Mistakes. We spend a ton of time trying to clean up such exasperating and seemingly intractable errors. Beyond that, for example, we undertake a new in-house credit score modeling study and immediately find that roughly 4% of the account IDs we send to the credit bureau cannot be merged with their data (via Social Security numbers or name/address/phone links).

I guess we’re supposed to be comfortable with the remaining data because they matched up -- and for the most part look plausible. Notwithstanding that nearly everyone has their pet stories about credit bureau errors that gave them heartburn or worse...

In addition to credit risk modeling, an ongoing portion of my work involves cardholder transaction analysis and fraud detection. Here again the data quality problems are legion, often going beyond the usual keystroke data processing errors that plague all businesses. Individual point-of-sale events are sometimes posted multiple times, given the holes in the various external and internal data processing systems that fail to block exact dupes. Additionally, all customer purchase and cash advance transactions are tagged by the merchant processing vendor with a 4-digit “SIC code” (Standard Industrial Classification) categorizing the type of sale. These are routinely and persistently miscoded, often laughably. A car rental event might come back to us with a SIC code for “3532- Mining Machinery and Equipment”; booze purchases at state-run liquor stores are sometimes tagged “9311- Taxation and Monetary Policy”; a mundane convenience store purchase in the U.K. is seen as “9711- National Security”, and so forth.

Interestingly, we recently underwent training regarding our responsibilities pursuant to the Treasury Department’s FinCEN (Financial Crimes Enforcement Network) SAR program (Suspicious Activity Reports). The trainer made repeated soothing references to our blanket indemnification under this system, noting approvingly that we are not even required to substantiate a “good faith effort” in filing a SAR. In other words, we could file egregiously incorrect information that could cause an innocent customer a lot of grief, and we can’t be sued.

 He accepted uncritically that this was a necessary and good idea.
I spent inordinate episodic FoxPro and SAS coding time (re) "cleaning the data," cross-referencing and correcting thousands of bad entries (Last, First, DOB, Gender, SSN) -- chiefly and most important among them bad "Socials" (the result of the legion input keystroke errors).

Then, we hired this enthusiastic but in some ways hapless H-1B crew to establish an Oracle data warehouse, and they thereupon had the brilliant idea to store SSNs as integers in lieu of character strings. So, were a cardholder Social to have been something like "012-34-5678," you now gotta write logic that will take #12345678 and convert/parse/substring re-concatenate it back to char(11) "012-34-5678" for proper ASCII collation and ease of view.

Now, in those circumstances of crapped-up but unremediated primary keys maybe the worst case upshot (in addition to my recurrent cube rants) would have been someone being denied a credit line increase or APR decrease.

In the case of a HL7 "ADT 44," on the other hand, someone could get the wrong meds dose and die from it.**

Close Only Counts in Horseshoes and Hand Grenades.
** and, yes, to be fair, I know that "Last+First+DoB+Gender+Social" would itself be imperfect (and highly variable; See Latanya Sweeney's work). Maybe someday we'll have Genes+Retinal Scan ID proxies. Maybe. But, we can do way better than the current cludgy "Master Patient Index" databases currently in use.
apropos,
MY LIGHT BEDTIME READING FOR TONIGHT


CMMI® for Development, Version 1.3
CMMI-DEV, V1.3 CMMI Product Team
Improving processes for developing better products and services
November 2010 TECHNICAL REPORT
CMU/SEI-2010-TR-033
ESC-TR-2010-033
Software Engineering Process Management Program
Unlimited distribution subject to the copyright.
http://www.sei.cmu.edu
and


Close to another 1,200 pages of reading Now, with respect to the former, my interest has been piqued by this "Agile" thing. The Fad of The Year?


From CMMI V1.3:
All of the notes begin with the words, “In Agile environments” and are in example boxes to help you to easily recognize them and remind you that these notes are examples of how to interpret practices and therefore are neither necessary nor sufficient for implementing the process area.

Multiple Agile approaches exist. The phrases “Agile environment” and “Agile method” are shorthand for any development or management approach that adheres to the Manifesto for Agile Development [Beck 2001].

Such approaches are characterized by the following:
  • Direct involvement of the customer in product development
  • Use of multiple development iterations to learn about and evolve the product
  • Customer willingness to share in the responsibility for decisions and risk
Many development and management approaches can share one or more of these characteristics and yet not be called “Agile.” For example, some teams are arguably “Agile” even though the term Agile is not used. Even if you are not using an Agile approach, you might still find value in these notes. PDF pg 70
___
  • In Agile environments, configuration management (CM) is important because of the need to support frequent change, frequent builds (typically daily), multiple baselines, and multiple CM supported workspaces (e.g., for individuals, teams, and even for pair-programming). Agile teams may get bogged down if the organization doesn’t: 1) automate CM (e.g., build scripts, status accounting, integrity checking) and 2) implement CM as a single set of standard services. At its start, an Agile team should identify the individual who will be responsible to ensure CM is implemented correctly. At the start of each iteration, CM support needs are re-confirmed. CM is carefully integrated into the rhythms of each team with a focus on minimizing team distraction to get the job done. PDF pg 151
  • In Agile environments, product integration is a frequent, often daily, activity. For example, for software, working code is continuously added to the code base in a process called ―continuous integration.‖ In addition to addressing continuous integration, the product integration strategy can address how supplier supplied components will be incorporated, how functionality will be built (in layers vs. ―vertical slices‖), and when to ―refactor.‖ The strategy should be established early in the project and be revised to reflect evolving and emerging component interfaces, external feeds, data exchange, and application program interfaces. PDF pg 270
  • In Agile environments, the sustained involvement of customer and potential end users in the project’s product development activities can be crucial to project success; thus, customer and end-user involvement in project activities should be monitored. PDF pg 287
  • For product lines, there are multiple sets of work activities that would benefit from the practices of this process area. These work activities include the creation and maintenance of the core assets, developing products to be built using the core assets, and orchestrating the overall product line effort to support and coordinate the operations of the inter-related work groups and their activities. In Agile environments, performing incremental development involves planning, monitoring, controlling, and re-planning more frequently than in more traditional development environments. While a high-level plan for the overall project or work effort is typically established, teams will estimate, plan, and carry out the actual work an increment or iteration at a time. Teams typically do not forecast beyond what is known about the project or iteration, except for anticipating risks, major events, and large-scale influences and constraints. Estimates reflect iteration and team specific factors that influence the time, effort, resources, and risks to accomplish the iteration. Teams plan, monitor, and adjust plans during each iteration as often as it takes (e.g., daily). Commitments to plans are demonstrated when tasks are assigned and accepted during iteration planning, user stories are elaborated or estimated, and iterations are populated with tasks from a maintained backlog of work. PDF pg 294
  • In Agile environments, teams tend to focus on immediate needs of the iteration rather than on longer term and broader organizational needs. To ensure that objective evaluations are perceived to have value and are efficient, discuss the following early: (1) how objective evaluations are to be done, (2) which processes and work products will be evaluated, (3) how results of evaluations will be integrated into the team’s rhythms (e.g., as part of daily meetings, checklists, peer reviews, tools, continuous integration, retrospectives). PDF pg 315
  • In Agile environments, customer needs and ideas are iteratively elicited, elaborated, analyzed, and validated. Requirements are documented in forms such as user stories, scenarios, use cases, product backlogs, and the results of iterations (working code in the case of software). Which requirements will be addressed in a given iteration is driven by an assessment of risk and by the priorities associated with what is left on the product backlog. What details of requirements (and other artifacts) to document is driven by the need for coordination (among team members, teams, and later iterations) and the risk of losing what was learned. When the customer is on the team, there can still be a need for separate customer and product documentation to allow multiple solutions to be explored. As the solution emerges, responsibilities for derived requirements are allocated to the appropriate teams. PDF pg 339
  • In Agile environments, requirements are communicated and tracked through mechanisms such as product backlogs, story cards, and screen mock-ups. Commitments to requirements are either made collectively by the team or an empowered team leader. Work assignments are regularly (e.g., daily, weekly) adjusted based on progress made and as an improved understanding of the requirements and solution emerge. Traceability and consistency across requirements and work products is addressed through the mechanisms already mentioned as well as during start-of-iteration or end-of-iteration activities such as ―retrospectives ‖ and ―demo days. ‖ PDF pg 354
  • In Agile environments, some risk management activities are inherently embedded in the Agile method used. For example, some technical risks can be addressed by encouraging experimentation (early ―failures ‖) or by executing a ―spike ‖ outside of the routine iteration. However, the Risk Management process area encourages a more systematic approach to managing risks, both technical and non-technical. Such an approach can be integrated into Agile’s typical iteration and meeting rhythms; more specifically, during iteration planning, task estimating, and acceptance of tasks. PDF pg 362
  • In Agile environments, the focus is on early solution exploration. By making the selection and tradeoff decisions more explicit, the Technical Solution process area helps improve the quality of those decisions, both individually and over time. Solutions can be defined in terms of functions, feature sets, releases, or any other components that facilitate product development. When someone other than the team will be working on the product in the future, release information, maintenance logs, and other data are typically included with the installed product. To support future product updates, rationale (for trade-offs, interfaces, and purchased parts) is captured so that why the product exists can be better understood. If there is low risk in the selected solution, the need to formally capture decisions is significantly reduced. PDF pg 386
  • In Agile environments, because of customer involvement and frequent releases, verification and validation mutually support each other. For example, a defect can cause a prototype or early release to fail validation prematurely. Conversely, early and continuous validation helps ensure verification is applied to the right product. The Verification and Validation process areas help ensure a systematic approach to selecting the work products to be reviewed and tested, the methods and environments to be used, and the interfaces to be managed, which help ensure that defects are identified and addressed early. The more complex the product, the more systematic the approach needs to be to ensure compatibility among requirements and solutions, and consistency with how the product will be used. PDF pg 414

I have much yet to learn. In particular, a simple explanation of the foregoing graphic as it pertains to an effective methodology for HIT development. Dubiety endures, and suspicion of bamboozlement reeks more broadly.

concern, to wit:
Because the companies using QFD [Quality Function Deployment] are already fairly sophisticated in their approaches to quality control, the apparent success of QFD as a software quality approach may be misleading. 

QFD is a very formal, structured group activity involving clients and product development personnel. QFD is sometimes called “the house of quality” because one of the main kinds of planning matrices resembles the peaked roof of a house. 

In the course of the QFD sessions, the users’ quality criteria are exhaustively enumerated and defined. Then the product’s quality response to those requirements is carefully planned so that all of the quality criteria are implemented or accommodated. 

For the kinds of software where client quality concerns can be enumerated and where developers can meet and have serious discussions about quality, QFD appears to work very well: embedded applications, medical devices, switching systems, manufacturing support systems, fuel-injection software controls, weapons systems, and the like. 

Also, QFD requires development and QA personnel who know a lot about quality and its implications. QFD is not a “quick and dirty” approach that works well using short-cuts and a careless manner. This is why QFD and Agile are cited as being “antagonistic.” 

The QFD software projects that we have examined have significantly lower rates of creeping requirements and also much lower than average volumes of both requirements and design defects than U.S. norms. However, the kinds of software projects that use QFD typically do not have highly volatile requirements.

Jones, Capers; Bonsignour, Olivier (2011-07-19). The Economics of Software Quality (Kindle Locations 3299-3311). Pearson Education (USA). Kindle Edition.
All very interesting.
QFD requires development and QA personnel who know a lot about quality and its implications. QFD is not a “quick and dirty” approach that works well using short-cuts and a careless manner. This is why QFD and Agile are cited as being “antagonistic.” 

UPDATE

Ran across an interesting website and blog post:

Leadership Skills: Building Collaborative Teams
Work teams can be very effective. They can also be a disaster, as anyone with even a passing knowledge of organizational dynamics understands. In today’s world of instant information, many of these impediments to real team performance are being overcome, while new challenges are emerging. New teams must be highly communicative, collaborative, mutually supportive, multitalented, and quick to respond, often without having a complete picture of the “facts.” New teams must be able to act with relative autonomy, demanding higher levels of accountability, unparalleled access to information, and commensurate authority. Team leadership can shift as demands for expertise change, although accountability remains with the titular team leader. The new team leader, therefore, must be both highly talented and politically savvy to survive and thrive as organizations adapt to new models. He or she must either have the stature or authority to withstand great pressure to avoid producing the “same old stuff,” which is tantamount to team failure.

In organizations with traditional structures and loyalties, teams are easily compromised by the often divergent pull from multiple constituencies that provide lip service to team success while providing minimum support or even actively working to sabotage team efforts. Teams that cannot pull themselves loose through the efforts of a strong, grounded leader or who have a patron high up in the organization often are teams in name only...

I forwarded this around our shop. We suffer from having too many "teams," all frequently busily doing "Work About The Work About the Work." A rather common affliction, unfortunately (including ASQ Divisions).

ERRATUM...


OK...
AGILE LEAN SIX SIGMA QFD RAPID-CYCLE PDSA CQI TQM!



One of my long favorite philosophers is the late Alan Watts, who once wryly observed something to the effect that "a problem with Christianity is that people have replaced the religion of Jesus with a religion about Jesus."

"Six Sigma" accords us a couple of lovely metaphors: [1] the boundary within plus or minus six standard deviations around a process average, assuming a perfectly Gaussian ("bell curve") dispersion, and [2] all those cool martial-arts green and black "Belts."

A "religion" "about."

In the software realm, "Agile" ups the allusive ante.


Will this be a hot new business line of professional certifications? Lordy. Agile Grasshoppers to Agile Samurai? And, to further jumble the metaphors, will they be donning rubgy attire for "scrums" and track gear for "sprints"?

Back to Jones and Bonsignour:
The phrase Six Sigma, which originated at Motorola, refers to defect densities of 3.4 “opportunities” for defects per million chances. The approach was originally used for complex manufactured devices such as cell phones but has expanded to scores of manufactured products and software, too. 

The original Six Sigma approach was formal and somewhat expensive to deploy. In recent years subsets and alternatives have been developed such as “lean Six Sigma” and “Six Sigma for software” and “design for Six Sigma.” 

Because the Six Sigma definition is hard to visualize for software, an alternative approach would be to achieve a cumulative defect removal efficiency rate of 99.999999% prior to delivery of a product. This method is not what Motorola uses, but it helps to clarify what would have to be done to achieve Six Sigma results for software projects. 

Given that the current U.S. average for software defect removal efficiency is only about 85%, and quite a few software products are even below 70%, it could be interpreted that software producers have some serious catching up to do. Even top-ranked software projects in the best companies do not go beyond about 98% in cumulative defect removal efficiency.

Jones, Capers; Bonsignour, Olivier. The Economics of Software Quality (Kindle Locations 3381-3384).
"[D]efect densities of 3.4 “opportunities” for defects per million chances." Yeah, as a process average, one assuming a perfectly Gaussian distribution,


which, of course, exists only on college chalkboards and in textbooks (and, of course, on Wall Street -- and, we see where that got them).


Color me presumptively Chebyshev-ista.


"Chance is lumpy." - Abelson's Laws

Consequently, your outer bound is 2.78% defect rate at 6 sigma (percent, not per million) under Chebyshev.

It gets worse when you go all 3+ dimensional. Think about it.


I guess here's the cut-to-the-chase point (in addition to and beyond the Watts analogy): I can pretty quickly convey the essentials of "Lean" to the average assemblage of high school- educated clinic front office staff. Priesthoods of belt-laden QI In-Tongue speakers, well, on the other hand, makes for a nice market in books and webinars.
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REMINDER


Money on the table.
___

INTERESTING NEWS


Demand for meaningful use (MU) assistance has exploded, increasing competition between third-party consulting firms--most of whom are excelling in MU-related work.
Not one word about RECs.

We just can't get any love these days. In my email inbox this morning:


MORE NEWS

 Which components of health IT will drive financial value?
A framework that describes the ability of specific health information exchange (HIE) and EHR functionalities to drive financial savings could help efforts to develop meaningful use measures and measure the financial impact of health IT, according to research published in the August issue of the American Journal of Managed Care.

“Previous work in this area has largely modeled the financial effect of whole health IT applications, assuming that the effects of those applications were similar across different contexts,” wrote lead researcher Lisa M. Kern, MD, MPH, of Weill Cornell Medical College in New York City, and colleagues. “This assumption may not be true because health IT is an inherently heterogeneous intervention. EHRs and HIE are themselves applications composed of functionalities that are variably implemented, configured and used.”...  
Courtesy of Cardiovascular Business. Full Journal article here.

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BTW - 
"We support technology enhancements for medical health records and data systems while affirming patient privacy and ownership of health information."

- GOP 2012 Platform. That's it. The only reference to Health IT.
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AUGUST 31 UPDATE:
YET ANOTHER "HEALTHCARE TRANSFORMATION" INSTITUTE


I got a LinkedIn email heads-up about these people today. Pretty interesting report, actually (in light of what I've perused thus far).

Like a person suffering from a debilitating disease, healthcare delivery in the United States is ailing. The U.S. spends significantly more per capita and a higher percentage of GDP on healthcare than other developed nations, yet our patient outcomes (e.g., mortality, safety, access to medical care) are disparate and inconsistent. Moreover, the rapidly rising costs of healthcare delivery are making medical care increasingly unaffordable to the average citizen and threaten our national financial viability.

How did we get here? Although unhealthy lifestyles and the growing and aging population are undoubtedly contributing to the rise in healthcare costs, two key factors must not be underestimated: a) advances in medical technology and b) powerful system incentives that inadvertently advance unchecked utilization throughout the healthcare delivery system.

So what can we do?

Where do we start? Read some Dr. John Toussaint (e.g., see my August 4th post), along with this report.

Read on.
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TROUBLEMAKER in the TWITTERVERSE


Details shortly.

SEPT 2nd REC ASS'N AMBER ALERT

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More to come...