On Track for Meaningful Use?

Are we on track to be a huge disappointment to our children’s children – or What?

[By Darrell K. Pruitt DDS]

When our grandchildren get the bill for the Obama administration’s subsidies benefitting primarily the health information technology industry, I bet they’re going to be really, really pissed at us for allowing today’s lawmakers to blow their 28 billion dollars to please HIT advocates who mislead consumers as well as lawmakers about the benefits of EHRs.

The Doctors Speak 

According to physicians who actually do the hard lifting in healthcare, the “meaningful use” requirements that they must prove in order to qualify for stimulus money will arguably increase both the cost and danger of healthcare – all for the benefit of stakeholders rather than principals. For one thing, “meaningful use” is meaningless if it fails to help physicians treat their patients. I think HIT stakeholders’ grandchildren should somehow be held accountable to my grandchildren.

Opposing Opinions  

Just days apart this week, two HIT reporters, Rich Daly from ModernHealthcare.com and Joseph Goedert from HealthDataManagment.com described two opposing letters the Office of the National Coordinator for Health Information Technology (ONC) recently received: One from doctors and one from patients (et al).

On Monday, here is how Daly’s article “AMA to ONC: EHR program doesn’t work for docs” began:

http://www.modernhealthcare.com/article/20110302/NEWS/303029950/1153

“Many physicians—specialists in particular—will not participate in the federal electronic health-record adoption incentive program because it requires them to include patient data that they do not otherwise collect, according to a Feb. 25 letter from 39 medical organizations letter to the Office of the National Coordinator for Health Information Technology”

On Wednesday, Joseph Goedert, writing for HealthDataManagment.com began “Consumer Groups: Hold Strong on MU” with this:

http://www.healthdatamanagement.com/news/meaningful-use-criteria-comments-consumers-42080-1.html

“A coalition of 25 consumer groups and unions is asking federal officials to hold firm on more stringent criteria for Stage 2 of electronic health records meaningful use, and expressing support for going further. For instance, because patients still trust their providers more than other information sources, holding providers accountable for actual usage of a patient Web portal ‘is entirely appropriate and we strongly urge ONC to resist pressure from the provider community to absolve them from responsibility for making these services available and useful to their patients,’ according to a comment letter to the Office of the National Coordinator”

  • AARP
  • Advocacy for Patients with Chronic Illness, Inc.
  • AFL-CIO
  • American Association on Health and Disability
  • American Hospice Foundation
  • Caring from a Distance
  • Center for Democracy & Technology
  • Childbirth Connection
  • Consumers for Affordable Health Care
  • Consumers Union
  • Families USA
  • Family Caregiver Alliance
  • Healthwise
  • Mothers Against Medical Error
  • National Alliance for Caregiving
  • National Coalition for Cancer Survivorship
  • National Consumers League
  • National Family Caregivers Association
  • National Health Law Program
  • National Partnership for Women & Families
  • National Women’s Health Network
  • OWL – The Voice of Midlife and Older Women
  • SEIU
  • The Children’s Partnership

Like the “Record Demographics” MU mandate, this is all for the “common good” I suppose. Consumer Advocasy groups wouldn’t mislead patients, would they?

I doubt many Americans represented by these 25 organizations ever imagined a new federal requirement that doctors record each patient’s demographics. (Notice of Proposed Rulemaking: Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Federal Register / Vol. 75, No. 8 / Wednesday, January 13, 2010 / page 1861; RIN 0938-AP78).

This means that the 25 stakeholder groups are doing their best to help American taxpayers hold physicians accountable to record and share their patients’ demographic information with the US government – private information about me and my family members that I personally don’t trust the government to be given – even if I’m in vulnerable need of health care.

Daly’s Article 

According to Daly’s article, the demands of MU are distractions for increasingly busy doctors and staff whose focus, I believe, should include eye-contact with patients with specific health problems rather than irrelevant data needs of third parties, including consumer advocacy groups.

On the other hand, if consumer advocacy groups have successfully defined for the federal government what clueless patients allegedly need, who will the mandate really benefit? 25 consumer advocacy groups don’t equal one consumer, so their letter isn’t grass roots at all. It’s deception wearing lipstick. Gullible and vulnerable patients are again being misrepresented by HIT stakeholders for a cut of our grandchildren’s 28 billion.

Assessment

Finally, if MU requirements are an arguably expensive and dangerous distraction for physicians, how can the law possibly be any less absurd for dentists? I’ll look at meaningful use as well at the ADA’s apparently flagging commitment to EHRs next. The ADA is abandoning state informatics departments – leaving them exposed to ADA members’ questions they are unable to answer. It looks to me that intra-ADA relationships are deteriorating quickly, but nevertheless, traditional stoicism still hasn’t been broken. “Image is everything” – ADA/IDM slogan.

Dentists

Here’s a teaser, dentists: Chances are, your state ADA organization hasn’t yet shared with you how the MU requirement of CPOE (Computerized physician order entry – page 1858) will change your practice communications. If you are a HIPAA-covered entity with an NPI number and you don’t email instructions to your denture lab rather than include a hand-written note with the relevant patient’s plaster models, you won’t qualify for stimulus money. What can possibly go wrong with that meaningful idea?

Conclusion

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On eMRs and Disease Management

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One Clinical Area Where Electronic Benefits May Exceed Paper’s Molecules

By Dr. David Edward Marcinko [Publisher-in-Chief]

www.BusinessofMedicalPractice.com

One area where technology assessments, clinical guidelines, and especially eMR aggregated data can make a true difference in patient care is in disease management.

The DMAA

The Disease Management Association of America (DMAA) defines disease management as “a system of coordinated health care interventions and communications for populations with conditions in which patient self-care efforts are significant”. 

Disease management supports the physician-patient relationship and places particular significance on the prevention of exacerbations and complications of chronic diseases using evidence-based clinical guidelines and integrating those recommendations into initiatives to empower patients to be active partners with their physicians in managing their conditions.

Disease Targets

Typically, targets for disease management efforts include chronic conditions such as asthma, diabetes, chronic obstructive pulmonary disease, coronary artery disease, and heart failure, where patients can be active in self-care and where appropriate lifestyle changes can have a significant favorable impact on illness progression.

Link: Front Matter BoMP – 3

Outcomes Measurement

The DMAA also emphasizes the importance of process and outcomes measurement and evaluation, along with using the data to influence management of the condition.

Assessment

Although claims and administrative data can be used to measure and evaluate selected processes and outcomes, eMRs will be needed to capture the full spectrum of data for analyzing illness response to disease management programs and to support necessary changes in care plans to improve both intermediate outcomes (such as lab values), and long-range goals (such as the prevention of illness exacerbations, managing co-orbidities, and halting the progression of complications).

Is this where eMRs can shine far and above traditional ink and paper medical records?

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Conclusion

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The Continuing Debate over Electronic Medical Records Systems

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Are We There Yet? – In Healthcare Organizations

[By Richard J. Mata MD, MS]

Dr. Mata

Paper-based medical records have been in existence for centuries and their gradual replacement by computer-based records has been slowly underway for over twenty years in western healthcare systems.

Computerized information systems have not achieved the same degree of penetration in healthcare as is seen in other sectors such as finance, transportation, and the manufacturing and retail industries.

Further, deployment has varied greatly from country to country and from specialty to specialty and in many cases has revolved around local systems designed for local use.

The DHHS

In a 2005 DHHS study, national penetration of electronic health records (EHRs) may have reached over 90% in primary care practices in Norway, Sweden, and Denmark (2003), but has been limited to 17% of physician office practices in the U.S. (2001-2003). By 2011, and the ACA, this number may now be approaching 20-25% in the US but adoption may actually be slowing.

The ISMS Vision

According to the Illinois State Medical Society there is a “Sweeping Vision for EHRs”:

  • EHRs will provide a comprehensive view of all patient information
  • Quality of care will be improved.
  • Physicians will more easily be able to review the “complete” medical record.
  • An appropriately configured EHR system will provide “alerts” and “notices” to help health care providers incorporate best practices into patient treatments. Ideally clinical decision support should be built in and be evidence-based.

Medical errors can be reduced:

  • Treatment and administrative costs will be reduced.
  • Public health will be improved.

Defining Electronic Records Systems

The 2003 Institute of Medicine (IOM) Patient Safety Report describes an EHR as encompassing:

  • a longitudinal collection of electronic health information for and about persons;
  • [immediate] electronic access to person- and population-level information by authorized users;
  • provision of knowledge and decision-support systems [that enhance the quality, safety, and efficiency of patient care] and
  • support for efficient processes for health care delivery.

IOM Report

A 1997 IOM report, The Computer-Based Patient Record: An Essential Technology for Health Care provides a more extensive definition:

A patient record system is a type of clinical information system, which is dedicated to collecting, storing, manipulating, and making available clinical information important to the delivery of patient care. The central focus of such systems is clinical data and not financial or billing information. Such systems may be limited in their scope to a single area of clinical information (e.g., dedicated to laboratory data), or they may be comprehensive and cover virtually every facet of clinical information pertinent to patient care (e.g., computer-based patient record systems).

The EHR definitional model document developed by the Health Information and Management Systems Society (HIMSS, 2003) includes “a working definition of an EHR, attributes, key requirements to meet attributes, and measures or ‘evidence’ to assess the degree to which essential requirements have been met once EHR is implemented.”

IOM Re-Deux

In another IOM report, Key Capabilities of an Electronic Health Record System [Tang, 2003], identifies a set of eight core care delivery functions that EHR systems should be capable of performing in order to promote greater safety, quality and efficiency in health care delivery. The eight core capabilities that EHRs should possess are:

  1. Health information and data. Having immediate access to key information – such as patients’ diagnoses, allergies, lab test results, and medications – would improve caregivers’ ability to make sound clinical decisions in a timely manner.
  2. Result management. The ability for all providers participating in the care of a patient in multiple settings to quickly access new and past test results would increase patient safety and the effectiveness of care.
  3. Order management. The ability to enter and store orders for prescriptions, tests, and other services in a computer-based system should enhance legibility, reduce duplication, and improve the speed with which orders are executed.
  4. Decision support. Using reminders, prompts, and alerts, computerized decision-support systems would help improve compliance with best clinical practices, ensure regular screenings and other preventive practices, identify possible drug interactions, and facilitate diagnoses and treatments.
  5. Electronic communication and connectivity. Efficient, secure, and readily accessible communication among providers and patients would improve the continuity of care, increase the timeliness of diagnoses and treatments, and reduce the frequency of adverse events.
  6. Patient support. Tools that give patients access to their health records, provide interactive patient education, and help them carry out home monitoring and self-testing can improve control of chronic conditions, such as diabetes.
  7. Administrative processes. Computerized administrative tools, such as scheduling systems, would greatly improve hospitals’ and clinics’ efficiency and provide more timely service to patients.
  8. Reporting. Electronic data storage that employs uniform data standards will enable health care organizations to respond more quickly to federal, state, and private reporting requirements, including those that support patient safety and disease surveillance.”

Assessment

After reviewing the above, are we there yet in – 2011?

Conclusion

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An Argument for Wikileaks in US Healthcare

On Allscripts CEO Glen Tullman

By Darrel K. Pruitt DDS

In 2008, Allscripts CEO Glen Tullman told Alex Nussbaurm of Bloomberg.com that physicians should take out loans to invest in his EHR product “to ensure that doctors have some skin in the game.” What did you expect? How much charm does it take to sell federally subsidized products when everyone knows that they’re mandated anyway?

Life Sans Blumenthal 

Yesterday, Nicole Lewis posted “Health IT’s Future without David Blumenthal” – a glowing and arguably deserved tribute to Dr. David Blumenthal who is leaving the ONC

http://www.informationweek.com/news/healthcare/leadership/showArticle.jhtml;jsessionid=0OLOEMENGCENJQE1GHRSKH4ATMY32JVN?articleID=229201216&pgno=1&queryText=&isPrev=

From where I’m sitting, it’s clear that Tullman used Lewis and InformationWeek to score more points with Washington and Wall Street, while continuing to marginalize the interests of those who actually take out loans to purchase his product: “David shepherded ONC through a very critical time . . . the creation, definition, and implementation of meaningful use, which really is a way to ensure that physicians actually use electronic records to improve care, but also that taxpayers get good value for their investment.” What about the doctor’s investment and more importantly, if a doctor is busy clicking on links to qualify for meaningful use dollars, who is accountable to the patients?

I don’t know about you, but it’s not difficult for me to recognize that like other HIT stakeholders whose careers are propped up by easy mandates rather than finicky satisfied customers, Tullman indeed has solid free-market reasons to play to investors and politicians while fearing his customers. They’re pissed at the man.

A Nationwide Survey           

HCPlexus recently partnered with Thompson Reuters to conduct a nationwide survey of almost 3,000 physicians concerning their opinions of the quality of health care in the near future considering the Patient Protection and Affordable Care Act (PPACA), Electronic Medical Records, and their effects on physicians and their patients. (See “5-page Executive Summary”)

http://www.hcplexus.com/PDFs/Summary—2011-Thomson-Reuters-HCPlexus-National-P

“Sixty-five percent of respondents believe that the quality of health care in the country will deteriorate in the near term. Many cited political reasons, anger directed at insurance companies, and critiques of the reform act – some articulating the strong feelings they have regarding the negative effects they expect from the PPACA.”

At this crucial time when Republicans are already threatening to cut off remaining HITECH funding, whose job will it be to break the news to HHS Secretary Kathleen Sebelius that the EHR savings she was counting on to fund a major portion of healthcare reform are only as valuable as CEO Tullman’s politically-correct fantasy? Pop! From what Nicole Lewis writes, my bet is that the Secretary won’t take the news well: “[Sebelius] reiterated that the successful adoption and use of HIT is fundamental to virtually every other important goal in the reform of the nation’s health care system.” Such pressure from the top down will make it even more difficult for HIT stakeholders, including insurers and politicians, to disown the most egregious. crowd-pleasin’, bi-partisan blunder in medical history since blood-letting was declared Best Practice by popular demand.

According to the HCPlexus-Reuters survey results, one in four physicians think EHRs will actually cause more harm than help in spite of Dr. Blumenthal’s best efforts. I wonder if the escalating bad press about EHRs helped Blumenthal decide to return to his academic position at Harvard. Of course, the controversy over HITECH is nothing new. There have been signs for years that EHRs, including Allscripts products, will neither improve care nor provide taxpayers (our grandchildren) a good value for their investment.

If Tullman was unaware of the highly critical HCPlexus-Reuters study when he assured InformationWeek that his subsidized product has value in the marketplace, he must have been aware of the disappointing news concerning two other recent studies performed by Public Library of Sciences (PLoS) and Stanford which also confirm that EHRs do not improve care. So imagine what it’s like to be one of Tullman’s new, naïve and trusting customers who are expected to use the product for something it’s not designed to do.

My Opinion 

It’s my opinion that Tullman’s apparently incorrigible business ethics have no place in the land of the free, and that more transparency in healthcare would help protect the nation from such politically-connected tyrants. Tullman, a long-time Chicago friend of Barack Obama and a Wall Street sweetheart, would still be just another domesticated CEO if it weren’t for the bi-partisan mandate for electronic health records that help Allscripts, Obama and Wall Street more than clueless patients.

Assessment 

If you want to seriously cut costs in US healthcare as well as cut our grandchildren’s taxes, demand transparency from not just the doctors and patients, but from stakeholders as well. Protected communications between good ol’ boys in healthcare are hardly diplomatic cables about military secrets and always increase the cost of healthcare.

Conclusion

And so, your thoughts and comments on this ME-P are appreciated. So when do you want to get the website started? I’m here to serve wherever you need me. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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Why Doctors DO NOT Need eMRs?

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Why Doctors DO NEED Patient Collaboration Tools!

By Shahid N. Shah MS

As a doctor, it seems as though you’re being told by everyone that you need to jump into electronic health records and electronic medical records software; that’s like telling you that you need to manage patients’ records and is so obvious as to be useless advice.

Focus on Patient Care

Of course, it’s true you need tools to manage records but that’s just the first step. Try not to think about or talk about EMRs; instead, focus on patient care collaboration tools. Here are the kinds of collaboration you need to do on a daily basis and where EMRs and EHRs usually do not help you:

Collaborative Tools

  • Reach out and market to new patients and communicate with existing patients that you may have lost touch with; you need tools that will promote you and your practice so that you can convert visitors to your website into paying patients and clients.
  • Register new patients and maintain patient data – find and work with tools that make the patient fill out major portions of your EMR for you; think of it as “self-service” EMR with tools that can be exposed on your website so that patients can do it themselves.
  • Help cover your medical risks by presenting medical liability coverage information to patients via your website using tools that can prove that they read the materials like informed consent, surgical prep, preparing for a procedure, etc.
  • Allow patients to see their schedule and help manage their appointments directly; if airlines can coordinate and manage aircraft and seats you should be able to get a system that allows patients to schedule an appointment with you.
  • Encourage the use of personal health records (PHRs) and make sure you review and link to the patient’s PHRs. This allows you to be ready to pull data from the PHRs in the future and get out of daily data entry when possible.
  • Get feedback about your practice and patient satisfaction using online surveys.
  • Be able to and receive send secure e-mails and documents to colleagues instead of playing phone tag or faxing constantly.

Assessment

As you can see from the simple list above, when people tell you to use EMRs they forget that the EMR is not only not enough but may be the wrong thing to focus on if you’re looking to streamline operations.

Link: Front Matter BoMP – 3

http://www.BusinessofMedicalPractice.com

Conclusion

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How to Choose eMR and HIT Consultants

Seeking Unbiased – Not Vendor Driven – Advice

By Shahid N. Shah, MS

www.BusinessofMedicalPractice.com

When you choose to implement your medical records technology, you’ll want to be sure that you get sound and unbiased advice. If you think the selections and decisions are too complicated to do by yourself so getting help is prudent. After you’ve learned more about RECs, which can give you free advice and help, look at some paid consultants as well because most RECs will simply choose a few local consultants that marketed themselves well to the RECs and not because the consultants are necessarily good at their jobs.

Consulting Types

The kinds of consultants you will need include:

  • Meaningful Use (MU) Consultant. An MU consultant should only be needed if you’re going after government stimulus funds. This is a person that knows how a medical practice works, inside and out, and all the legal and regulatory details about Meaningful Use. This is not a typical IT contractor or technical consultant; it must be someone who is focused on MU. Because you will not get increased government reimbursements unless you meet MU, the MU Consultant is probably more important than your IT consultant. The MU consultant should help you figure out whether or not you qualify for incentives, how to take advantage of incentive program, how to use RECs, how to ensure that you can qualify for MU without disrupting your practice and losing money, and finally whether you should even care about MU.
  • A good MU Consultant will tell you when to walk away from MU and not implement certain technologies just as readily as when to implement it.
  • Another major thing to focus on when choosing an MU consultant is to be sure that they know your local area’s rules, regulations, and technology providers (not national).
  • Try to make sure that your MU Consultants are paid very little upfront and will share the risk with you as you try to achieve success. They should get paid when you get paid and should not be paid full price unless you get incentive payments from the government. 
  • EMR Consultant. If you’re ready to buy an EMR the MU Consultant can help you pick products but getting advice from an EMR Consultant who knows all the hundreds of packages (and doesn’t just know 1 or 2 that he’s seen before) and which one will be best for you may be worth investing in. Be careful if your EMR Consultant is coming from a REC or a vendor side – ask them to disclose any ties to the products they are helping you select. Some EMR consultants are business focused and others are technically focused; you should pick the one based on what your needs are: for example, if you’re great at technology, choose a business-focused consultant (and vice-versa). 
  • IT Consultant. This is something that’s obvious but you need excellent advice on hardware, software, inter-office networking, Internet connectivity, bandwidth analysis, and a whole host of other technology needs. 
  • Integration Consultant. Most people forget this consultant because it’s not obvious but in order to make sure that all the medical records data you’re collecting can be shared in between your systems, your hospital, and with the government you need an integration consultant. Their job is to know all the relevant standards like HL7, DICOM, CCR, CCD, XML, etc. along with things like HL7 routers and tools that can share medical data records between your EMR, practice management system, and health information exchanges (HIEs).

Assessment 

Front Matter BoMP – 3

Conclusion

And so, your thoughts and comments on this ME-P are appreciated. How do you select an eMR consultant? Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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Has the HIT Bubble Already Popped?

Long Before Reaching … Dentistry

[By Darrell K. Pruitt DDS]

HCPlexus recently partnered with Thompson Reuters to conduct a nationwide survey of almost 3,000 physicians about their opinions of the quality of health care in the near future considering the Patient Protection and Affordable Care Act (PPACA), Electronic Medical Records, and their effects on physicians and their patients. (See “5-page Executive Summary”)

http://www.hcplexus.com/PDFs/Summary—2011-Thomson-Reuters-HCPlexus-National-P

Results:

“Sixty-five percent of respondents believe that the quality of health care in the country will deteriorate in the near term. Many cited political reasons, anger directed at insurance companies, and critiques of the reform act – some articulating the strong feelings they have regarding the negative effects they expect from the PPACA.”

What’s more, one in four physicians think eHRs will cause more harm than help. So what’s the accepted threshold for the Hippocratic Oath to come into play?

Do you also find excitement in healthcare reform’s surprises? Experiencing the sudden, last minute turns healthcare reform has taken lately is like riding shotgun with Mayhem behind the wheel, texting. Here’s other discouraging news from the same HCPlexus-Thompston Reuters survey: “A surprising 45% of all respondents indicated they did not know what an ACO is, exposing a much lower awareness of ACOs versus the broader implications of PPACA. It appears there has been a lack of physician education in this area.”

ACOs Defined 

Since I also had no idea what an ACO is, I searched the term and came across a timely article that was posted on NPR only days ago titled, “Accountable Care Organizations, Explained.”

http://www.npr.org/2011/01/18/132937232/accountable-care-organizations-explained

Author Jenny Gold writes: “ACOs are a new model for delivering health services that offers doctors and hospitals financial incentives to provide good quality care to Medicare beneficiaries while keeping down costs.” Does that remind anyone of insurance HMO promises just before the bad idea collided with surprisingly intelligent consumers in the early 1990s? Kelly Devers, a senior fellow at the nonprofit Urban Institute, is quoted: “Some people say ACOs are HMOs in drag,” There’s a sharp turn nobody warned us about.

HMO Differentiation 

Further blurring the difference between ACOs and HMOs, Gold adds “An ACO is a network of doctors and hospitals that shares responsibility for providing care to patients. Under the new law, ACOs would agree to manage all of the health care needs of a minimum of 5,000 Medicare beneficiaries for at least three years.” I wonder if we’ll see a resurrection of HMO gag orders preventing physicians from discussing effective but expensive treatment alternatives not offered by the ACO.

As expected, not only are hospitals and doctors competing for the opportunity to run ACOs, but so are former HMO insurance agents. Devers explains, “Insurers say they can play an important role in ACOs because they track and collect data on patients, which is critical for coordinating care and reporting on the results.” As a provider, do you trust UnitedHealth’s Ingenix data mining tendencies? A few years ago, NY State Attorney General Andrew Cuomo spanked the company for selling insurers pseudo-scientific excuses to cheat out-of-network physicians.

Just like Health Maintenance Organizations don’t maintain health, insurer-based Accountable Care Organizations will not bring accountability to care any more than the Patient Protection and Affordable Care Act provides patient protection and affordable care. And since I’m exposing blatant bi-partisan deceptions, there is no privacy or accountability in the Health Insurance Portability and Accountability Act, and the “HIPAA Administrative Simplification Statute and Rules Act” doesn’t.

HITECH Funding

Gold suggests that because HITECH rules were written intentionally vague in order to push the envelope of stakeholders’ imaginations, similar to HIPAA’s ineffective security rules I suppose, the doctors’ predictable ignorance of ACOs is understandable.

But then again, all this may not even matter in a few months. According to Howard Anderson, Executive Editor of HealthcareInfoSecurity.com, HITECH funding itself is threatened. He recently posted “GOP Bill Would Gut HITECH Funding – Unobligated HITECH Act Funds Would be Eliminated.”

http://www.govinfosecurity.com/articles.php?art_id=3306

Assessment

While Obama’s healthcare reform teeters between two houses, I encourage consumers to plead with their lawmakers to stop being suckered in by cheap, meaningless buzzwords sprinkled in the titles of bills. I’m hoping we can at least get them to read a little deeper. Be on your toes. Mayhem is “recalculating.”

Conclusion

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[Do] eHRs Fail to Improve Healthcare Quality?

I told you so … wow! That felt really, really good!

By D. Kellus Pruitt DDS 

If you haven’t been following the bad news for electronic health records that has broken in the popular media in the last few days, you may be unaware of recent studies that are about as welcome in Washington DC as Wikileaks revelations of diplomatic farts – but much more serious. Healthcare reform itself is in the balance, and President Obama’s credibility with mandates is already shot.

Records will show that a few politically-incorrect troublemakers knew all along that EHRs will fail to save money or improve the quality of healthcare – ever – unless doctors and patients are involved in their development. This troublemaker warned dentists 5 years ago about how HIT stakeholder and former Speaker of the House Newt Gingrich deceived naïve ADA Delegates about benefits of eHRs to dental patients. In turn, 3 years later, the ADA’s HIT stakeholder, Dr. Robert Ahlstrom, deceived Bush’s HHS Secretary Michael Leavitt with biased, self-serving testimony he gave to the NCVHS. (See “Dr. Robert H. Ahlstrom’s controversial HIPAA testimony” that I posted in 2008.)

http://community.pennwelldentalgroup.com/forum/topics/dr-robert-h-ahlstroms

Do you still not agree that long ago, I told you so?

At a time when President Obama’s healthcare reform is teetering between the Houses, just wait until lawmakers catch the news I’m bringing to you hours, days or even weeks ahead of Fox News: Transparency just caused a huge chunk of anticipated funding for reform to evaporate like American’s property values. After billions of stimulus dollars have been gleefully spent benefiting influential healthcare stakeholders rather than principals, the bi-partisan feel-good digital fantasy is bankrupt. Pop goes the bubble.

Although there have been minor news reports of growing disappointment in eHRs for years, the results of two recent studies by Public Library of Sciences (PLoS) and Stanford clearly expose the lack of value of eHRs for Americans. We’ve been had.

The WSJ 

On January 21, the Wall Street Journal posted an article titled, “Study Looks For, Can’t Find Much Evidence of E-Health’s Benefits,” by Katherine Hobson.

http://blogs.wsj.com/health/2011/01/21/study-looks-for-cant-find-much-evidence-of-e-healths-benefits/

Hobson writes: “With the U.S. and the U.K. heading full steam towards electronic medical records and other health IT applications, how much evidence is there that they improve care?

Not a whole lot, according to a review of existing research on the topic published this week by PLoS Medicine. While governments and other proponents are claiming that digitizing health records can save lives and increase efficiency, the review’s ‘key conclusion is that these claims need to be scrutinized before people invest quite large sums of money in these technologies,’ Aziz Sheikh, lead author of the study and a professor of primary care research and development at the Center for Population Health Sciences at the University of Edinburgh, tells the Health Blog.’”

US News & World Report

And; only hours ago, US News & World Report posted a story titled “Electronic Record-Keeping Alone May Not Boost Health Care.” (no byline).

http://health.usnews.com/health-news/managing-your-healthcare/policy/articles/2011/01/25/electronic-record-keeping-alone-may-not-boost-health-care

“Electronic health records have so far done little to improve the quality of health care in the United States, a new study states.

Researchers from the Stanford University School of Medicine analyzed data on use of electronic records from 2005 through 2007. The data came from a nationwide physician survey that encompassed nearly 250,000 outpatient visits.”

The ADA 

So how does the truth about eHRs affect ADA leadership’s stubborn push for paperless practices in dentistry? Well, if as a trusting ADA member, you haven’t already swallowed the propaganda, now wouldn’t be a good time to convert to paperless.

eDRs

Though my unpopular but accurate statements about eDRs eventually got me in secret trouble with vetted, anonymous Texas Dental Association officials, I predicted this week’s bad news years ago on the TDA online forum. Unfortunately, my warnings to other TDA members about the ADA’s biggest blunder in history were censored by the TDA Executive Director without warning or explanation. Why? She isn’t accountable to anyone and “Image is everything.” (ADA/IDM slogan).

Just how difficult can it be to recognize that eHRs are inefficient in dental practices for simple, common sense reasons? First of all, dental records which involve prevention and treatment of disease in the lower third of the face rarely include laboratory test results like medical records which concern the whole body. In addition, dentists maintain tenfold fewer thin patient charts than physicians’ thick ones. So if the value of eHRs are questionable for hospital care involving millions of charts, I think dentists are safe to ignore Presidential eHR mandates. The bottleneck in dental offices isn’t the front desk, it’s the dentist … or at least it should be. As for thumbing your nose at a Presidential mandate, I wouldn’t get too concerned. Obama also mandated that the prison at Guantanamo Bay was to be closed over a year ago. It didn’t happen, and nobody went to jail.

Unfunded Mandates 

Unfunded mandates just don’t carry the respect they once did when they were less common and actually made sense. Considering the absurdity of eHRs in dentistry, worse things could happen for trusting, clueless Americans.

Those who represent our concerns in government probably don’t yet realize that in the last four days, the price of healthcare reform skyrocketed even further out of reach, and we simply cannot borrow any more money from our grandchildren just to throw it away on expensive hi-tech crap. As for myself, I’m sending this ME-P to my national and state representatives: Cornyn, Hutchison, Barton, Burgess, Harris, Davis, Patrick and Veasey, I hope you will contact your representatives as well. The Internet makes it so easy these days to educate those who would otherwise determine our future based on deception from healthcare stakeholders.

Assessment 

I publicly challenge Dr. Robert Ahlstrom, who is currently a member of the ADA Council on Dental Practice and chair of the Members Advisory Group to an Internet discussion concerning electronic health records in dentistry. It’s the same unanswered challenge I issued to the influential dentist over 3 years ago: I still say electronic dental records are an expensive hobby paid for by dental patients in higher fees, and they do nothing to improve patient care. What do you have to say about that, Dr. Robert Ahlstrom? You know you’re going to have to face me again and again, so please don’t disappoint ADA members by continuing to hide. It makes the whole ADA look cowardly.

Conclusion

Always remember: I told you so, Dr. Robert Ahlstrom. And so, your thoughts and comments on this ME-P are appreciated. How do you select an eMR consultant? Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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Doctor – “The eMR Made Me Do It?”

Podiatrist Disciplined for Inaccurate eHR Records

Source: James T. Mulder: The Post-Standard [1/21/11]

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What

The state Education Department has taken disciplinary action against a Liverpool foot doctor charged with professional misconduct.

Who

Dr. Bryan Gregory Popovici, a podiatrist, was fined $2,500 and placed on probation for two years by the state Education Department. Popovici admitted in a signed consent agreement that he failed to keep accurate patient records.

Why

The state said Popovici failed to document diagnostics performed, whether treatment options were discussed with a patient, and his rationale for placing a patient in a hard cast rather than a soft cast. 

The Defense

Meghann N. Roehl, Popovici’s attorney, said the problems stemmed from Popovici’s new electronic medical record system. “Dr. Popovici was an early adopter of electronic medical records,” Roehl said. “The earlier versions had software glitches which he is working hard to correct.”

Editor’s Note: The potential for increased liability because of eMR use has been discussed elsewhere on this ME-P.

Conclusion

And so, your thoughts and comments are appreciated. Do eMRs increase medical malpractice liability? Will eMRs be used as a plaintiff / defense argument in other disciplinary or liability actions? Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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The Rising Tide of EHR Vendors

Electronic Health Records (EHRs)

By Don Fornes

[Founder & CEO, Software Advice]

EHR software vendors aren’t churning out profits like you might expect. You’d think that the Federal subsidies for EHR implementation would create a rising tide that lifted all boats in the EHR software industry. In reality, some vendors are about to capsize.

Based on data points I’ve observed in the market over the past few months, I think some vendors are facing a cash flow crunch. They’re thrilled to have the wind at their backs for once, but the pace is proving hard to maintain as market evolution has accelerated under the unnatural effect of government subsidies.

Here’s the problem.

EHR Vendors Are Spending Money Like Crazy

Most software markets evolve over a twenty or thirty-year period. Consider the enterprise resource planning (ERP) market: the first ERP vendors were founded in the early 1970s, but rapid growth and innovation continued until about the year 2000. The EHR market, however, will mature in the next five years. This is because healthcare providers are buying EHR systems sooner than they otherwise would, to make the most of massive federal subsidies and avoid penalties. Consequently, EHR vendors are in a mad rush to gain market share.

Those that win will own a massive customer base paying recurring support fees. Those that lose will become irrelevant from a market share standpoint and will be ingested into a larger vendor (if they’re lucky; some will just go broke). As a result, EHR vendors are increasing their R&D budgets to develop new features and meet meaningful use criteria. Their marketing colleagues are spending heavily on demand generation and brand building. These vendors have no choice but to win today’s market share battle.

But Medical Providers Are Gun Shy

Almost a year and a half passed between when the American Recovery & Reinvestment Act (ARRA) was signed in 2009, and the final definitions of “Meaningful Use” and “Certified EHR” were issued in July 2010. Certainly that process was no small task, but during that time, most providers took a wait-and-see approach to EHR adoption. There have been tens, maybe hundreds, of thousands of practices out kicking tires, but fewer than expected are writing checks to buy an EHR system. Furthermore, a disproportionate share of these deals – I’m estimating >60% – are going to the top ten market leaders, which is typical of enterprise software markets.

With meaningful use criteria now defined, I believe demand trends have improved. Providers now have the clarity necessary to make purchase decisions with confidence. That can’t happen soon enough, however. EHR spending has to catch up with the investments these vendors have been making over the past two years.

And Subscription Pricing Constrains Cash Flow

To complicate matters further, the software industry as a whole is shifting to cloud computing. Providers have not yet embraced the Cloud en masse, but they have embraced the subscription pricing model popularized by Cloud vendors. Why make a large, up-front investment in a perpetual license when you can just pay monthly for what you consume? Subscriptions are even more logical in light of a five-year subsidy payout.

To meet physician demands, the major EHR players are now offering low monthly pricing and publishing it right on their home pages. EHR vendors love this recurring subscription revenue, but their cash flow is spread out into the future as a result. It takes a healthy balance sheet to withstand this transition.

So what do we have so far?

  • EHR vendors are investing lots of money;
  • providers are writing fewer checks than expected; and,
  • checks that are written are smaller and spread out.

The result is a very difficult cash flow scenario for many, but not all, EHR vendors. Lately, I’ve seen some EHR vendors stretching their payables out 90 or even 120 days. Meanwhile, I’ve been surprised to hear that some leading vendors are operating between breakeven and just a few points of profit margin. Both practices represent good financial discipline considering the pace of market evolution. In reality, however, some vendors are struggling – “taking on water,” to stick with our nautical imagery.

Buyers Beware

The EHR and practice management markets have always been highly fragmented into hundreds of software vendors, largely as a result of the need to service small and demanding local practices. As a result, providers have seen plenty of vendors fail to reach critical mass, then close up shop or sell out. Anecdotally, I also know that some of the leading EHR vendors grew their top line 30% to 60% last year, while laggards foundered. Gaps between winners and losers are expanding quickly, so expect to see more consolidation.

Vendor size is important, but isn’t the deciding factor for success and viability. In this intense market, success will result from execution. The winners and losers will be determined by the competency and discipline of their management. EHR vendors must spend with discipline and generate a strong return on their investments. It wouldn’t hurt to raise capital, either, but not all vendors will need to take this step.

It’s tough for providers to assess the financial viability of private EHR vendors. Software Advice offers our Guide to Assessing Medical Software Vendor Viability, but the industry really needs a trusted third-party to evaluate the 400 plus vendors. Organizations like CCHITInfoGard and ICSA Labs are all certifying EHRs against functional criteria. However, buyers also need the equivalent of an A.M. Best orMoody’s to rate the financial health of EHR vendors. Okay, maybe without the negligence and bias the later demonstrated during the mortgage bubble.

Assessment

Link:  http://www.softwareadvice.com/medical/electronic-medical-record-software-comparison/

There will be some big EHR winners within the next five years and consolidation will be a net positive for the industry. However, buyers must be careful not to become collateral damage as the fierce battle for market share plays out. It’s important to determine which vendors are closing businesses, growing their revenue and building a sustainable, profitable business. Providers should keep in mind that their success is tied to the success of the software vendor that will enhance and support their EHR system in years to come.

Conclusion

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Do Patients Really Believe in eMRs?

Not Necessarily

By Dr. David Edward Marcinko MBA CMP™

[Publisher-in-Chief]

A NPR / Kaiser / Harvard School of Public Health patient opinion poll of more than a year ago [Aril 2009], demonstrated that for the most part, patients believed that just spending money on eMR’s was not going to improve their health or bring down health care costs.

The Personal Touch

In fact, the most important part, it seems, is their relationship with their doctor [ie, trust].

Link: Harvard

Assessment

So, how does this square with the following tends?

  • Patient-Doctor face time is decreasing.
  • Doctors avoid eye contact because of poor keyboarding computer input skills.
  • Some medical schools may abandon courses in physical diagnosis.

Conclusion

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Looking to Convert to a Paperless Dental [Medical] Practice?

Why Does the ADA Promote eDRs?

By Darrell K. Pruitt DDS

Not so Fast!

Before a dentist trustingly accepts the recommendation of the American Dental Association and unwittingly converts his or her practice to paperless, one should read the story I copied below which was posted on VillageSoup.com yesterday.

Unlucky dentist loses everything …

http://waldo.villagesoup.com/business/brief/business-services/unlucky-dentist-loses-everything/373672

Worst Way to Start Off the Year

I have been on my own for last 7 yrs. We have a small business server (windows 2003) 6 work stations, completely paperless using Dentrix 11 and Vixwin platinum. One morning, when we returned to work, we could not access the server. Went into panic mode! Not able to get anything! Not knowing the schedule. Who is coming what they are coming for, etc. It was decided that my server crashed. It was set up w/2 hard drives to mirror each other and also had an external drive back up (Seagate). We ended up rushing the drives to a data recovery company in (data doctors). They sounded very promising claim 90% success). I agreed to pay additional $4100 to rush case! We were led to believe all is well once they diagnosed case. A few hrs later every thing changed. We got the bad news that both drives are not recoverable since they found a minute scratch on one of the plates. Also we are not able to recover anything from the external drive.

At this point I have lost all patient records including x rays going back 7 yrs. I have no access to schedule, ledgers, notes, insurance, X-rays, anything. This is leading both me and my wife into depression. We are very stressed, at a loss. This is a catastrophic loss. Not sure how to move forward?

I am worried about the liability on top of everything else. How do I tell my patients? How do I know who paid for what balances on work that needs to be done, etc. I keep waking up at night thinking of all the possible problems.

This is the lowest point in my career. I don’t even want to go into the office from stress. If any one can offer any advice I would really appreciate it. I know in the past you guys lifted me up. I love forum name.

Thank you.

Assessment

On top of the anguish this person already suffers, the HIPAA violation must be reported to the Department of Health and Human Services. Thanks to HITECH, an expensive inspection is likely to follow. The dentist’s letter reminds me of a desperate private note from a dentist a few months ago describing his HIPAA violation. He lost a laptop computer he was using as a daily backup device. Since there were thousands of his patients’ unencrypted PHI on the computer, he was similarly paralyzed by the same cold and lonely panic a professional feels when optimistic career plans suddenly crumble into a dark void that includes abject business failure. People sometimes hurt themselves and others when even choosing to do the right thing leads to ruin. A person with any compassion can tell from reading the dentist’s plea for help that the newer harsher penalties from HHS and state Attorneys General for data breaches will only further destroy the lives of innocent dentists and their families. HITECH is cruel nonsense in dentistry and ADA leaders are stone-cold heartless.

Although encryption is strongly advised in the “ADA Practical Guide to HIPAA Compliance,” If ADA officials dared to keep track of their failure in promoting safe digital dental records, I bet their own data would show that less than 3% of US dental patients’ PHI is encrypted. Yet proud leaders in my profession remain stoically unresponsive to members’ and patients’ concerns about risks of data breaches. They call their aloofness “professionalism.” It infuriates me that shy ADA officials hide from personal accountability for the careless harm they cause dentists and dental patients.

“Image is everything” ADA/IDM slogan

The nation’s ambulatory healthcare providers – including dentists, podiatrists, chiropractic doctors and physicians – cannot continue to blindly trust our professional organizations to protect our practices from the dangers of the electronic health records they promote for their personal benefit. We’ve been sold out.

Assessment

As far as I can tell, selfish ADA leaders with careers invested in dental informatics just can’t tolerate truth. When I consider the pain they cause at no risk to themselves, I say the parasites should be encouraged to move on down the road and look for their power in a field where they won’t endanger others.

Conclusion

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PhysAssist Scribes for eMRs [Necessity or Frivolity?]

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On Human eHR Input Devices [aka Personal Secretaries]

By Dr. David Edward Marcinko MBA CMP™

[Publisher-in-Chief] www.CertifiedMedicalPlanner.org

What it Is – How it Works?

According to their website, PhysAssist Scribes provide turn-key solutions, recruits, interviews, trains and certifies staff, schedules and maintains highly-trained human eHR input scribes for their clients [$8-10/hour wages]. Emergency room departments and physicians were an initial target market.

Data Input Services

Scribes provide real-time charting for physicians by shadowing them throughout their shifts and performing a variety of tasks including recording patients’ history and chief complaints, transcribing the physical exam, ordering x-rays, recording diagnostic test results, and preparing plans for follow-up care, etc.

Typical Clients

Clients are mostly hospital based physicians, but one can imagine progressing down the food chain to large medical practices and even to solo practitioners as technology advances and HR costs are reduced. So, give em’ a click, and tell us what you think.

http://iamscribe.com

Reported Benefits

  • Increase physician performance
  • Increase physician job satisfaction
  • Increase overall patient satisfaction
  • Improve chart accuracy
  • Decrease patient length of stay
  • Increase communication among ED staff
  • Improve physician recruiting and [retension] retention.

Related story: http://www.hhnmag.com/hhnmag_app/jsp/articledisplay.jsp?dcrpath=HHNMAG/Article/data/12DEC2010/1210HHN_FEA_staffingissues&domain=HHNMAG

Assessment

  • It seems implausible to me that in order to facilitate the widespread use of eMRs, one has to hire another layer of bureaucracy in order to input the patient encounter. Is this an indictment of the various speech recognition systems or physician keyboarding ability? I am not a technophobe but eHRs are not yet up to pragmatic-use snuff. This is reminiscent of jeweled encrusted “buggy-whips” of the 1850’s. They were expensive, cumbersome and added no utility; but were “nice-to-have” devices for the affluent until the internal combustion engine came along [i.e. non-solo or small group medical practitioner].
  • Of course, injecting another human resource [i.e. personal secretary] into the data input equation increases privacy breach possibilities for this protected health information [PHI]. And, it is not exactly the model of a contemporary and lean micro-medical office.
  • Does a secretary-scribe really have to be “certified”? Won’t a good typist do just as well? Is this an example of vertical integration in the PhysAssist business model?  How long till the scribes join the labor-union movement and seek employment benefits?
  • What happens to the doctor, patient and data input chain when a scribe quits, or is a no-show for work?
  • What ever happened to Occam’s razor (or Ockham’s razor), often expressed in Latin as the lex parsimoniae (translating to the law of parsimony, law of economy or law of succinctness), which is a principle that generally recommends selecting a hypothesis that makes the fewest new assumptions. IOW: KISS
  • Of additional interest to note is the misspelling of the word retention, as “retension” on the www.IAmScribe.com website. Not a very good impression for a transcribing firm; or am I just an aging editorial curmudgeon?
  • Are e-MR scribes a necessity or mere frivolity?

Conclusion

And so, your thoughts and comments on this ME-P are appreciated. Are such secretary scribes a “covered entity” or “business associate” under the HIPAA laws with the needed paperwork, etc? Or, is this an Obama administration job creation initiative?

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eMR Privacy versus Healthcare Efficiency [A Voting Opinion Poll]

The Electronic Controversy Continues

By Anonymous

Medicine may be the last industry to resist the digital revolution as many doctors still use paper medical records.

Framing the Debate

Privacy advocates worry that if the move to eMRs is rushed, patient privacy will suffer. Supporters, on the other hand, argue that health information technologies have advanced to the point that such concerns are vastly overblown. Any loss of privacy will, they insist, be more than offset by efficiency gains. Who is right?

Link: http://www.economist.com/debate/debates/overview/189

Assessment

Will any privacy loss from eMRs be compensated for by commensurate welfare gains from increased medical delivery efficiency?

Conclusion

And so, your thoughts and comments on this ME-P are appreciated. Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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Grading Texas Lawmakers on Patient Privacy

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Grade Spread Runs Gamut from F to A+

[By D. Kellus Pruitt DDS]

Are the interests of my dental patients in Fort Worth, Texas being adequately represented by their elected officials in Austin and Washington DC? Starting a few months ago, I’ve sent multiple emails concerning patient privacy and identity theft to my elected government officials on state and national levels; as a test of responsiveness.

The Elected Officials

These include:

  • Texas US Senators John Cornyn and Kay Bailey Hutchison
  • US Representatives Joe Barton and Michael Burgess
  • Texas State Senators Wendy Davis and Chris Harris
  • Texas State Representatives Diane Patrick and Marc Veasey.

Of the 8 lawmakers I contacted through their Websites, I received no response from state officials Davis, Harris, Patrick and Veasey. However, from my national representation, only Joe Barton failed to reply. I simply have to give those 5 a grade of F. I assumed my state representatives would be more patient-friendly than members of the US Congress. But, I was wrong.

Texas US Senators 

US Senator Cornyn has responded twice: Once in September and again on December 6. In both emails he says,

“Dear Darrell Pruitt,

Thank you for contacting my offices. Your correspondence has been received, and we will respond to you as quickly as possible.”

I suppose there’s still hope for a response, but he also failed. Cornyn also earned an F.

On the other hand, I’m more disappointed with Kay Bailey Hutchison’s staff than John Cornyn’s. In all 3 of her identical responses to my emails, she addresses me as “Dear Friend,” before wasting my time with a vanilla lecture about the origin and intention of the HITECH Act that I can get from HHS:

“The HITECH Act includes privacy and security provisions to expand current requirements under the Health Insurance Portability and Accountability Act (HIPAA) and strengthens the HIPAA privacy rule, blah, blah, blah.”

If Hutchison’s staff member had read the first paragraph of any of the three emails I sent before he or she assigned me the same canned response all three times, the bonehead would have recognized that an explanation of HIPAA was not what I needed from his or her boss. I’m pretty sure I know more about HIPAA than the Senator, and that is the reason I wrote her in the first place.

Senator Hutchison closed all three emails with,

“I appreciate hearing from you, and I hope that you will not hesitate to contact me on any issue that is important to you. Sincerely, United States Senator Kay Bailey Hutchison”

Then she added,

“PLEASE DO NOT REPLY to this message as this mailbox is only for the delivery of outbound messages, and is not monitored for replies.”

Although I should have known better, following her dead-end reply, I returned to her Website and complimented the Senator for being my patients’ first elected official to respond to my emails. I told Kay Bailey how special her personal attention made me feel as an American… which attracted the same response, which quickly stopped that special feeling. Compared to Hutchison’s predictable responses, Senator Cornyn’s thin promises of a meaningful response some day don’t look so bad. Hutchison gets an F, but I’ll upgrade Cornyn to a D for incomplete.

Enter Dr. Michael Burgess 

And then there is Michael C. Burgess. Compared to this man, everyone else is just a failing politician, in my opinion. Dr. Burgess gets an A+.

In response to both emails I sent to US Representative Michael Burgess MD in the last few weeks, I received sincere, personalized responses. This week, I sent Dr. Burgess a copy of the timely comment I posted Tuesday on this Medical Executive-Post, “Is ‘encryption of PHI’ discussed in dentistry?”

https://medicalexecutivepost.com/2010/12/07/%e2%80%9cthe-ada-practical-guide-to-hipaa-compliance%e2%80%9d/#comment-9242

While Senator Hutchison is unaware that her staff is asleep, and while I’ve been waiting for John Cornyn to get back in touch with me for months, Congressman Burgess’ meaningful and personalized response arrived within 48 hours on Thursday:

Dear Dr. Pruitt:

Thank you for your continued correspondence regarding your concerns for privacy as it relates to health information technologies (HIT). I appreciate hearing from you on this matter.

I assure you that I understand the concerns you have that the implementation of HIT will have harmful effects on patients’ privacy, specifically as it relates to dentistry. As problems arise, I will work closely with the Department of Health and Human Service as well as organized dentistry to make sure that these problems are dealt with quickly and efficiently so that patients continue to receive the rights guaranteed to them in HIPAA.

As one of the few Members of Congress who have run a medical practice and been required to meet HIPAA, I take your concerns to heart and will be vigilant in my oversight.

Again, thank you for taking the time to contact me. I appreciate having the opportunity to represent you in the U.S. House of Representatives. Please feel free to visit my website (www.house.gov/burgess) or contact me with any future concerns.

Sincerely,

Michael C. Burgess, MD

[Member of Congress]

—————————–

So of those 8 elected officials from the Dallas /Ft. Worth area, who you think, I should trust with my patients’ interests next time I vote?  As for my state representatives whom I could run into almost anywhere in my community, they never bothered responding at all.

For months, I’ve emailed Diane Patrick more times than any other lawmaker. Long ago, I assumed that since she is married to a dentist, she might have natural interest in the welfare of dental patients. I was wrong. Even though the Fort Worth District Dental Society supports her campaigns, I have to wonder why?

Assessment 

And as for Marc Veasey, I met the man once, but I don’t think he remembers me. His campaign office is four doors down the hall from me as I type Tip O’Neal’s quote. “All politics is local.”

Conclusion

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Of WikiLeaks, Politics and eMRs [A Voting Opinion Poll]

Is Reporting for “Accidental” Political Downloads a HIT Security Game-Changer?

By Dr. David Edward Marcinko MBA CMP™

[Publisher-in-Chief]

Recently, I read in The New York Times that Federal workers are being told to avoid the website WikiLeaks and stay away from those classified cables leaked from the US State Department! Classified information, whether or not already posted on public websites or disclosed to the media, remains classified, and must be treated as such by federal employees and contractors”,  the Office of Management and Budget [OMB] said in a notice sent out last Friday.

Link: http://www.msnbc.msn.com/id/40512200/ns/us_news-wikileaks_in_security

Of Advice … Not Threats?

According the release, The New York Times was told by a White House official that it does not advise agencies to block WikiLeaks or other websites on government computer systems. Nor does it bar federal employees from reading news stories about the leaks! But – and this is a big one – if they “accidentally download” any leaked cables, they are being told to notify their “information security offices.”

Too Many Conflicting Questions 

  • Is document leaker PFC Bradley Manning a hero and a real patriot – not the mislabeling of an ACT as THE PATRIOT ACT – or traitor goat? What about Julian Assange – is he a full-disclosure hero or guilty of treason – should he be treated as an enemy combatant of the US Government?
  • How could a mere PFC download a quarter million classified documents without raising a red flag? Is the government incompetent? Has it just issued a not so thinly veiled threat to its own citizens with this admonishment? Are we becoming more like China in our use and restrictions of the Internet? Was the big brother prescience of George Orwell’s 1984, correct?
  • Is the admonishment of security officer notification following “accidental download” akin to the “don’t ask – don’t tell” policy on gays in the armed forces? So much for the transparency we were told our current administration wanted.
  • Should we forget about, or modify, the eMR privacy debate and/or should HIPAA be modernized?
  • Should Hillary Clinton resign?

Health Care Security Questions

  • Who exactly is a government employee anyway? And, does this include workers in the VA system, prison health system, Indian Health Service, postal workers, Medicare and Medicaid recipients, school kids with government meal subsidies and/or independent contractors and recipients of budgetary pork projects, US tax credits or federal unemployment benefits, etc?
  • Have these employed folks signed a HIPAA-like “business associate agreement” with Uncle Sam? Should government workers close their eyes and ears, too! And, with the expansion of federal government, does this mean that even more folks will have access to classified information [and more accidental downloads] than ever before? Who is left and allowed to read WikiLeaks and who is actually immune, or not?
  • If government can not protect its own data, records, confidential information or websites with certainty, how does it expect a solo medical professional [DPM, DO, DDS, DC, etc] to do the same with eMRs, and at what cost! HIPAA rules and regulations spell ou very specific health policy mandates and onerous legal punishments and fines for protected health information [PHI] data breach don’t they; not just the notification of a Chief Medical Information Security Officer [CMISO]. Is this a federal double standard?

Historical Re-Do

Federal employees were told to not read the Pentagon Papers. The leaker, economist Daniel Ellsberg PhD, precipitated a national controversy in 1971 when he released them. The right of the press to publish the papers was upheld in New York Times Co. v. United States. As a response, the Nixon administration began a campaign against further leaks – and  a smear campaign against Ellsberg personally – by creating the White House “plumbers”, which in turn led to the Watergate burglary of the LA office of Dr. Lewis Fielding MD [Ellsberg’s psychiatrist] in an effort to discredit him. According to Ellsberg;

“The public is lied to every day by the President, by his spokespeople, by his officers. If you can’t handle the thought that the President lies to the public for all kinds of reasons, you couldn’t stay in the government at that level, or you’re made aware of it, a week … The fact is Presidents rarely say the whole truth—essentially, never say the whole truth—of what they expect and what they’re doing and what they believe and why they’re doing it and rarely refrain from lying, actually, about these matters.”

Note: “Presidential Decisions and Public Dissent”, Conversations with History, July 29, 1998].

Now … Four Decades Later

Has anything changed since the above scandal? Almost forty years later, those with security clearance across the board were given this same directive about WikiLeaks. Will they comply; nope! Did little Johnny refrain when his mother told him not to read Playboy magazine; of course not! The surest way to perusal, or unwanted behavior, is prohibition. Just tell someone NOT to do something, and watch that activity increase.  Human nature is human nature. Recall, the 18th. amendment [1919-1933] was repealed by the 21st. amendment whose 77th. anniversary is celebrated just this week.  

Assessment

Look, like most traditional news organizations and journalists, we at the ME-P fiercely advocate for our First Amendment Rights. Anyone looking at classified information without clearance, while not necessarily illegal when posted by a media organization, is considered to be making an “ethics” violation of the rules of secrecy as established by the intelligence community. And, we always strive to be ethical as part of our Judeo-Christian heritage.

But, citizens and members of the fourth estate are not in the intelligence community. What does this mean for average citizens and private doctors … nothing at all. What a HIPAA breach means to a medical professional however, is another serious matter! Fear the government’s admonition: Do as I say – Not as I do. Use paper medical records; eschew eMRs?

Voting Poll and Survey

Conclusion

Is reporting for “accidental” downloads, or security breaches, an HIT security game-changer? Your thoughts and comments on this ME-P are appreciated. Is WikiLeaks like eMR security; more potentially legal and economically damaging to the leaker than the outed? What about Julian Assange and the need to revise the HIPAA statutes? Is there an analogy here; or not?Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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Do Passwords Protect the Identity of Patients?

Essay on eDR and eHR Data Integrity

By D. Kellus Pruitt DDS

“ADA Tip: Password protection is the responsibility of each workforce member. Strong alphanumeric passwords provide a strong defense against unauthorized electronic system intrusion. Passwords that cannot be guessed, that are not publicly posted, and that are changed on a regular basis will help your practice avoid the occurrence of security incidents.”

– 2010 ADA Practical Guide to HIPAA Compliance, Chapter 4, page 26.

Not So Fast, ADA 

I read a recent article on lifehacker.com titled “How to Break into a Windows PC (And Prevent It from Happening to You).” The unnamed author tells a different story.

http://lifehacker.com/5674972/how-to-break-into-a-windows-pc-and-prevent-it-from-happening-to-you

Running on Windows®  

Apparently, if a healthcare provider’s office computer runs on Windows and it is not encrypted, password protection is worse than ineffective security. Passwords are false security. If lifehacker.com is correct, all a dishonest employee needs to download thousands of patient identities to sell for a few hundred bucks is a Linux CD and 10 minutes of snuggle-time with an office terminal.

What’s more, it is unlikely that if the thief will ever be caught if he or she sports common sense. Months or years following the silent heist, the doctor could learn of a rash of neighborhood identity thefts from a federal investigator with a badge – waiting in the reception room for the doc’s next break between patients. Please remember this gaping hole in security the next time a HIT stakeholder like the ADA assures Americans that HIPAA is swell protection from identity theft. HIPAA empowers identity theft. The amendments to the 1996 Rule in 2002 gave too much away to campaign contributors, in my opinion.

About De-identification 

Now then; since you’ve made it this far, is anyone ready to consider a different path to the benefits of electronic dental records? It’s called de-identification. My goal has always been to stimulate open discussion of de-identifying dental records because it is so common sense to remove fuses from bombs. In 5 years, I’ve had very little success attracting sincere discussion about de-identification other than privately. Nevertheless, over the years I entertained an adequate amount of ridicule that stopped a few months ago. Like Charlie Brown and his persevering faith in the Great Pumpkin, I’m resolute.

HIPPA Data-Breach Liability 

Physicians might not be able to get away with sidestepping HIPAA and data-breach liability using de-identification because it is so easy to re-identify owners of medical records. And insurance company CEOs who don’t know the difference between cost control and quality control will fight de-identification of dental records before giving up the exclusive right to bend proprietary algorithms toward bonuses.

Here Comes the Pitch!  

Is America interested in better dental care through a transparent 2.0 platform that incentivizes value-based competition for dental patients instead of paid ads? I have a better solution than HIPAA: Drop the PHI identifiers from dental records and store volatile health histories on one or two well-guarded flash drives. It’s that simple. Want to see miracle discoveries in dentistry? Offer the boring but safe raw, de-identified dental data to anyone who cares to perform Evidence-Based Dental research. Interoperability will still be incredibly tedious and expensive, but at least the effort won’t be doomed by dangerous and expensive HIPAA regulations.

Assessment

So how about it? Imagine the incentives for self-improvement if dentists could privately compare their treatment results with competitors’ – without risk of harming their patients or practices – on an “opt-in” basis rather than a mandated fantasy of a “pay-for-performance” [P4P] model run by stakeholders with investors to answer to. If our grandchildren are to benefit from unbiased Evidence-Based Dental research mined from facts rather than manicured dental claims, passwords won’t allow them a return on ARRA investment and encryption is just one more layer of expensive and futile complication.

Conclusion

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Should Doctors Make the Patient Internet Portal Leap?

An ME-P Readers Survey

By Staff Reporters

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Patient Portals

In healthcare, for example, the use of patient website portals is a hotly debated topic. These are [should be]  sophisticated HIPPA compliant and secure Web sites offered by medical practices to help engage patients electronically, with the promise of better service and care for patients — and less hassle for the medical practice, doctors and nurses. Often clinical, insurance and financial data gathering and scheduling functions are included, along with separate patient log-in, e-prescribing, and laboratory result features, etc. The promise of eMRs only increases the sophistication of these burgeoning sites.

Use Still in Infancy

But, according to www.MedicalBusinessAdvisors.com unscientific sampling of our clients and technically sophisticated practices [skewed cohort], physicians note that the uptake of portal use by patients outside of tech savvy urban centers is still small, although use by senior citizens is rapidly increasingly. And, tech savvy youngsters are typically not in need of healthcare.

The Survey Question

So, this raises the question, unanswered by other professionally focused websites like Physicians Practice, should you make the patient portal leap?

Definitions

Before we answer that question, let’s provide a bit more historical detail on this technology. In contrast to a traditional [first generation – health 1.0] practice Web site, which provides smiling pictures of the physicians, directions, hours of operation, policies, and maybe a smattering of educational materials, a patient portal is designed for active interaction between patient and practice [second generation – health 2.0].

Example:

As an example, a patient portal typically provides secure e-mail, allowing the patient to make a quick query of the physician (and presumably receive a reasonably quick response) without the delay and inconvenience of attempting to catch the physician on the phone between visits or after hours. Patient portals can also be used for open-source scheduling, allowing patients to make requests for particular times and days.

Assessment

Finally, the newest and most sophisticated patient e-MR engaged portals will allow patients to take a peek inside their patient record, giving them online (and secure) access to their medication list, recent labs, and other data that might be useful in self management, or if the patient is seeing another provider, etc. 

Conclusion

And so, your thoughts and comments on this ME-P are appreciated. Should doctors and medical clinics make the patient portal leap? Feel free to review our top-left column, and top-right sidebar materials, links, URLs and related websites, too. Then, subscribe to the ME-P. It is fast, free and secure.

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eHRs by 2014?

How’s the $19-B eHR Mandate Going?

By D. Kellus Pruitt DDS

In 2004, President Bush declared that all Americans’ health records will be digital by 2014. Upon taking the office 2 years ago, President Obama also adopted the popular, HIT industry-supported bi-partisan goal. Will the mandate make a difference – even if we kick in our grandchildren’s money?

Not without the cooperation of doctors and patients. What were you thinking, Mr. Presidents?

Looking Pretty Doubtful

Yesterday, even FierceHealthIT editor Neil Versel declared,

“It’s looking pretty doubtful that the Bush/Obama goal of 2014 will happen, whether you’re shooting for ‘most’ or ‘all’ Americans.”

http://www.fiercehealthit.com/story/amia-2010-five-10-years-away-always-seems-five-10-years-away/2010-11-15#ixzz15TianByl

My Two Cents

In my opinion, the eHR mandate was doomed on delivery when the consumer-friendly 1996 HIPAA Rule was amended in 2003 – taking control of healthcare from patients and doctors and granting it to reckless healthcare stakeholders who cannot be held accountable for harming Americans.

Assessment

In 2003, our privacy was sold for bi-partisan contributions. If Americans don’t trust digital health records, they’ll be worse than worthless. They’ll be dangerous.

Conclusion

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Is ARRA Stimulus Money for Dentists?

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Now is the Time to Say “No Thank You” to the ADA

[By D. Kellus Pruitt DDS]

A few days ago on Twitter, @techguy said: “@Dentrix, Are you guys helping dentists get access to the ARRA EHR Stimulus money?” This morning I “retweeted” his question to the electronic dental record giant: “That’s a great question, @Dentrix. What are you doing to help dentists receive stimulus money?

Of Faded Promises  

Dentrix officials no longer shop faded promises of free stimulus money to help dentists purchase their software. The truth is, without taxpayer help, Dentrix’s product offers dentists no return on investment, and it’s unlikely that the profession will ever see a cent of stimulus money. In fact, if American Dental Association President Raymond Gist wants to be a national hero, now would be the time to purchase a press release to tell the nation, “American dentists graciously decline your offer of stimulus money, taxpayers. We say, let our grandchildren keep it for themselves.” The deficit-weary public is very interested in that kind of good news these days. But, the ADA’s PR opportunity has a shelf life. The sooner they jump on this minor deception the more generous American dentists will appear. A year from now, the chunk of faux-generosity won’t work.

Too Late for Cash Give-Aways 

For one thing, it’s simply too late for dentists to take part in the cash giveaway. And even if there was time for a significant number of dentists to convert from paper to digital before September 2011, to receive promised stimulus money, a dentist’s practice has to be 30% Medicaid. That qualification rules out almost all dental practices right off, and here in Texas last week, Governor Perry threatened to opt my state out of Medicaid (and stimulus money) completely. A year ago, Perry threatened secession from the Union. It sounds to me like you are softening him up, Washington.

Meaningful Use Requirements 

That’s not all. Before a dentist can qualify to be reimbursed up to $44,000 dollars, the practice must show “meaningful use” of certified electronic dental records. However, meaningful use of digital records in dentistry has not yet been determined and perhaps does not actually exist. Nevertheless, the best minds in the ADA and HHS are searching for the next best thing – humorous rationalizations. For example, imagine the convenience of the speed-dial on the telephone compared to logging on to a highly secure, password-protected, HIPAA-compliant, encrypted computer just to tell the lab you have a pick up – just to show the Department of Health and Human Services that you are making “meaningful use” of your Dentrix product and spending taxpayer money wisely.

Assessment 

Do you know what is scary about the leadership in my profession? I’m apparently the only dentist in the nation who dares admit that as far as ARRA stimulus money goes, American dentists are out of luck and clueless. Even @techguy is in the dark for crying out loud!

Conclusion

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Front Matter BoMP – 3

Useful Managed Care Patterns and Procedural Utilization Trends

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Part One of Two

By Dr. David Edward Marcinko MBA

[Publisher-in-Chief]

If you read this ME-P regularly or have read my earlier blogs, you know that I am writing a book on practice management for the private medical practitioner.

The Business of Medical Practice [Transformational Health 2.0 Skills for Doctors]; third edition: www.BusinessofMedicalPractice.com

Link: Front Matter BoMP – 3

And, a recent story in the Chicago Tribune on the difficult business life of private practitioners today reminds me that I need to keep my nose to the grindstone.

For example, knowing your medical contract negotiation objectives, gathering information on the choices of contracts and discount payment systems, and understanding the pitfalls to watch for when evaluating a contract are the keys to any successful negotiation process.

Reimbursement Contract Negotiations

According to the sanofi-aventis Pharmaceutical Company Managed Care Digest Series, for 2008-10, the following pattern and trend comparative information has been empirically determined and may provide a basic starting point for practitioners to share business management, facilities, personnel, and other records for enhanced contract negotiation success.

www.managedcaredigest.com

hos

Procedural Utilization Trends

  • Among all physicians in a single-specialty group practice, invasive cardiologists averaged the most encounters with total hospital inpatient admissions down from the prior year. However, encounters rose for cardiologists in multispeciality group practices.
  • Echocardiography was the most commonly performed procedure on HMO seniors, followed by coronary artery bypass graft surgery. Group practices performed cardiovascular stress tests for circulatory problems most often.
  • CT studies of the brain and chest were the most common studies for HMO seniors, while MRI head studies were the most common diagnostic test on commercial HMO members.
  • Colonoscopy was the most common digestive system procedure on senior HMO members, while barium enemas were more common on commercial members.
  • Hospital admission volume decreased for allergists, family practitioners, internists, OB/GYNs, pediatricians, and general surgeons.
  • Internists ordered more in-hospital laboratory procedures than any other physicians in single-specialty groups.
  • Non-hospital MD/DOs used in-hospital radiology services most frequently, continuing a three-year upward trend.
  • Pediatricians averaged the most ambulatory encounters, down from the prior year.
  • Non-hospitalist internists ordered a higher number of in-hospital laboratory procedures than any other single medical specialty group, but allergists and immunologists increased their laboratory usage.
  • The number of ambulatory encounters increased for general surgeons, while group surgeons had the most cases. Capitated surgeons, of all types, had a lower mean number of surgical cases than surgeons in groups without capitation. Surgeons in internal medical groups also had more cases than those in multi-specialty groups.
  • The average number of total office visits per commercial and senior HMO visits fell, along with the number of institutional visits for both commercial and senior HMO members.
  • The average length of hospital stay for all commercial HMO members increased to 3.6 days but decreased to 6 days for all HMO members.
  • The total number of births increased for commercial HMO members served by medical group practices, and decreased for solo practitioners.
  • More than one-third of all medical groups use treatment protocols, rising from the year before. Multi-specialty groups were more likely to use them than single-specialty groups, who often develop their own protocols. The use of industry benchmarks to judge the quality of healthcare delivery also increased.
  • Outcome studies are most common at larger medical groups, and multi-specialty groups pursue quality assurance activities more often than single-specialty groups.
  • Provider interaction during office visits is increasingly coming under scrutiny. Patients approve of cardiologists more frequently than allergists and ophthalmologists.

Assessment

Obviously, the above information is only a gauge since regional differences, and certain medical sub-specialty practices and carve-outs, do exist.

Part Two: Useful Managed Care Provider, Staffing, Activity and Financial Trends

Conclusion

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Brief Summary of “Meaningful-Use” for eHRs

Objectives Listed

By Shahid N. Shah MS

www.BusinessofMedicalPractice.com

In 2009, the ARRA HITECH bill coined the term “meaningful use” and was a game-changer in the healthcare IT industry. In a series of regulations, the Recovery Act specifically required the following.

Summary of MU

Here are the substantive Meaningful Use objectives of the new ARRA HITECH bill:

  • Use Computer Provider Order Entry (CPOE).
  • Implement drug-drug, drug-allergy, drug-formulary checks.
  • Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®.
  • Maintain active medication list.
  • Maintain active medication allergy list.
  • Record demographics.
  • Record and chart changes in vital signs.
  • Record smoking status for patients 13 years and older.
  • Incorporate clinical lab-test results into EHR as structured data.
  • Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, and outreach. This is a common feature in EHRs.
  • Report ambulatory quality measures to CMS or the States.
  • Implement 5 clinical decision support rules relevant to specialty or high clinical priority, including diagnostic test ordering, along with the ability to track compliance with those rules.
  • Check insurance eligibility electronically from public and private payers.
  • Submit claims electronically to public and private payers.
  • Provide patients with an electronic copy of their health information upon request.
  • Capability to electronically exchange key clinical information among providers of care and patient-authorized entities.
  • Perform medication reconciliation at relevant encounters and each transition of care.
  • Provide summary care record for each transition of care and referral.
  • Capability to submit electronic data to immunization registries and actual submission where required and accepted.
  • Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
  • Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities
  • Generate and transmit permissible prescriptions electronically.
  • Send reminders to patients per patient preference for preventive/follow-up care.
  • Provide patients with timely electronic access to their health information within 96 hours of information being available to the EP.
  • Provide clinical summaries for patients for each office visit.

Conclusion

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Content Exchange and Vocabulary Standards for eMRs

Understanding Terms and Definitions

By Shahid N. Shah MS

As per the HHS rules, vocabulary standards are standardized nomenclatures and e-code sets used to describe clinical problems and procedures, medications, and allergies for eMRs. Some commons terms and definitions are listed below:

Terms and Definitions

  • ASTM’s CCR – for most of your basic patient summary exchange needs the CCR will meet your needs. If you’re moving from low or no interoperability today to some interoperable capabilities then CCR is your best starting place.
  • International Classification of Diseases, 9th Revision, Clinical Modifications (ICD-9- CM) or SNOMED CT® should populate a problem list. If you’re not familiar with both standards and are unsure where to start, go with ICD-9 for problem lists. SNOMED is not commonly supported in the broad EMR industry but ICD-9 support is quite common so start there.
  • Health Level Seven (HL7) Clinical Document Architecture (CDA) Release 2 (R2) Level 2 CCD – for more advanced patient summary exchange needs the HL7 CDA is recommended. If you’re already supporting CCR exchange and it’s not meeting your needs then HL7 CDA is the next logical place to go.
  • For patient summary exchanges, HHS expect the following fields to be populated: problem list; medication list; medication allergy list; procedures; vital signs; units of measure; lab orders and results; and, where appropriate, discharge summary.
  • ICD-9-CM [ACD-10] or American Medical Association (AMA) Current Procedural Terminology (CPT®) Fourth Edition (CPT–4) to populate information related to procedures. Both of these standards are support broadly by most existing vendors so going with either or both is good.
  • For medication lists, HHS requires the use of codes from a drug vocabulary the National Library of Medicine has identified as an RxNorm drug data source provider with a complete data set integrated within RxNorm.
  • For lab results, HHS requires the use of LOINC® to populate information in a patient summary record related to lab orders and results when LOINC® codes have been received from a laboratory and are retained and subsequently available in your EMR. HHS states that in instances where LOINC® codes have not been received from a laboratory, the use of any local or proprietary code is permitted. HHS does not require these local or proprietary codes to be converted to LOINC® codes in order to populate a patient summary record.
  • For the purposes of electronic prescribing, your vendor must be capable of using NCPDP SCRIPT 8.1 or NCPDP SCRIPT 8.1 and 10.6. With respect to a vocabulary standard, your vendor must use codes from a drug vocabulary currently integrated into the NLM’s RxNorm. For the purposes of performing a drug formulary check, your vendor must be capable of using NCPDP Formulary & Benefits Standard 1.0 adopted by HHS (73 FR 18918).
  • There are standards required for insurance data like eligibility checking and submissions of claims. ASC X12N and NCPDP standards (Versions 4010/4010A and 5010 and Versions 5.1 and D.0, respectively) should be used for these transactions. It’s important to realize that Version 4010 is being phased out in favor of Version 5010 so your vendors need to support both at this time and must be able to move exclusively to Version 5010 in the future.
  • For the purposes of electronically submitting calculated quality measures required by CMS or by States, your vendor must be capable of using the CMS PQRI 2008 Registry XML Specification. Going forward, HL7 Quality Reporting Document Architecture (QRDA) Implementation Guide based on HL7 CDA Release 2 may be allowed but for now focus on the CMS PQRI requirements until HHS provides more guidance in the future.
  • For the purposes of submitting lab results to public health agencies, your vendor must be capable of using HL7 2.5.1.
  • For the purposes of electronically submitting information to public health agencies for surveillance and reporting, your vendor must be capable of using HL7 2.3.1 or HL7 2.5.1 as a content exchange standard. At this time HHS not required adverse event reporting nor have they adopted a specific vocabulary standard for submitting information to public health agencies for surveillance and reporting.
  • For the purposes of electronically submitting information to immunization registries your vendor must be capable of using HL7 2.3.1 or HL7 2.5.1 as a content exchange standard and the CDC maintained HL7 standard code set CVX -Vaccines Administered18 as the vocabulary standard.

Assessment

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Conclusion

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Understanding the Medical Records R[e]Volution

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It’s Not All about Electronic Records

By Dr. David Edward Marcinko; MBA, CMP™

[Editor-in-Chief]

Introduction

To understand the medical records revolution that has occurred this decade, put your self for a moment in the position of a third-party payer; ie; a private insurance company, Medicare or Medicaid etc.

For example, you want to know if Dr. Joel Brown MD actually gave the care for which he is submitting a [super] bill or invoice. You want to know if that care was needed. You want to know that the care was given to benefit the patient, rather than to provide financial benefit to the provider beyond the value of the services rendered.

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Of Doubts and Uncertainty

Can you send one of your employees to follow Dr. Brown around on his or her office hours and hospital visits?  Of course not! You cannot see what actually happened in Dr. Brown’s office that day or why Dr. Black ordered a PET scan on the patient at the imaging center. What you can do however, is review the medical record that underlies the bill for services rendered from Dr. Blue. Most of all, you can require the doctor to certify that the care was actually rendered and was indicated. You can punish Dr. White severely if an element of a referral of a patient to another health care provider was to obtain a benefit in cash or in kind from the health care provider to whom the referral had been made. You can destroy Dr. Rose financially and put him in jail if his medical records do not document the bases for the bills he submitted for payment.

The Payment Paradigm Shift

This nearly complete change in function of the medical record has precious little to do with the quality of patient care. To illustrate this medical records evolution/revolution point, consider only an office visit in which the care was exactly correct, properly indicated and flawlessly delivered, but not recorded in the office chart. As far as the patient was concerned, everything was correct and beneficial to the patient. As far as the third-party payer is concerned, the bill for those services is completely unsupported by required documentation and could be the basis for a False Claims Act [FCA] charge, a Medicare audit, or a criminal indictment.  We have left the realm of quality of patient care far behind.

mobile EHR health

Provider Attitude Adjustments Required

Instead, medical practitioners must adjust their attitudes to the present function of patient records.  They must document as required under pain of punishment for failure to do so. That reality is infuriating to many since they still cling to the ideal of providing good quality care to their patients and disdain such requirements as hindrances to reaching that goal. They are also aware of the fact that full documentation can be provided without a reality underlying it. “Fine, you want documentation?  I’ll give you documentation!”

Computer Charting and eMRs

Some doctors have given in to the temptation of “cookbook” entries in their charts, canned computer software programs or eMRs listing all the examinations they should have done, all the findings which should be there to justify further treatment.  Many have personally seen, for example, hospital chart notes which describe extensive discussion with the patient of risks, alternatives and benefits in obtaining informed consent when the remainder of the record demonstrates the patient’s complaint that the surgeon has never told her what he planned to do; operative reports of procedures done and findings made in detail which, unfortunately, bear no correlation with the surgery which was actually performed.

Assessment

Whether electronic medical records (eMRs) will be helpful regarding fraud prevention, in the future is still not known. But, it is at best naive and more frequently closer to a death wish to think that a practitioner can beat the system, with handwritten notes, computer generated records, or fabricated eMR documentation.

Conclusion

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Seeking Your Favorite Health 2.0 Patient Story

Collaborative Care – Not Yet So Collaborative

Ann Miller RN MHA

[Executive-Director]

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Dear ME-P Medical Readers

Please send in your favorite story [serious, humorous, poignant, personal, etc] or anecdote on participatory medicine and electronic patient connectivity. If selected, it may be posted on the ME-P or used in our new book in a blinded or named fashion; or on an individual or aggregated basis.

ME-P Support

Editorial support is available, as your input would not only assist your colleagues, but be illustrative in an erudite and credible fashion. Your synergy in this space also seems ideal.  Length is up to you in a prose writing style. And, be sure to address health 2.0 modernity. 

Definition: https://healthcarefinancials.wordpress.com/2008/09/12/emerging-healthcare-20-initiatives

Please contact me for more details, if interested. Regardless, we remain apostles promoting your core vision whenever possible.

Ann Miller: MarcinkoAdvisors@msn.com

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On e-Confidentiality Conflicts in Medicine

Understanding the Potential Role of eMR Compromise

By Render Davis MHA CHE

www.BusinessofMedicalPractice.com

Whether it is an employer interested in the results of an employee’s health screening; an insurer attempting to learn more about an enrollee’s prior health history; the media in search of a story; or health planners examining the potential value of national health databases, the confidential nature of the traditional doctor-patient relationship may be compromised through demands for clinical information by parties other than the patient and treating caregivers. 

Impact of eMRs

In addition, without clear safeguards the growth in use of electronic medical records may put personal health information at risk of tampering or unauthorized access.  Clearly, employers and insurers are interested in the status of an individual’s health and ability to work; but does this desire to know, combined with their role as payers for health care, constitute a right to know?  The patient’s right to privacy remains a volatile and unresolved issue.

Assessment

Counter to this concern is the recognition that electronic records may dramatically improve communications by offering greater accessibility of information to clinicians in the hospital or office potentially reducing medical errors through elimination of handwritten notes, increased use of built in prompts and clinically-derived triggers for orders and treatments, and development of pathways for optimal treatments based on clinically valid and tested best practices.

Conclusion

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Understanding Disease Management

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How Technology Affects Patient Care

By Brent A. Metfessel MD, CMP™ [Hon]

www.BusinessofMedicalPractice.com

One area where technology assessments, clinical guidelines, and EMR data can make a true difference in patient care is in disease management.

DMAA Definition

The Disease Management Association of America (DMAA) defines disease management as “a system of coordinated health care interventions and communications for populations with conditions in which patient self-care efforts are significant”.  Disease management supports the physician-patient relationship and places particular significance on the prevention of exacerbations and complications of chronic diseases using evidence-based clinical guidelines and integrating those recommendations into initiatives to empower patients to be active partners with their physicians in managing their conditions.

Usual Conditions

Typically, targets for disease management efforts include chronic conditions such as asthma, diabetes, chronic obstructive pulmonary disease, coronary artery disease, and heart failure, where patients can be active in self-care and where appropriate lifestyle changes can have a significant favorable impact on illness progression.

Outcomes Measurement

The DMAA also emphasizes the importance of process and outcomes measurement and evaluation, along with using the data to influence management of the medical condition.

Assessment

Although claims and administrative data can be used to measure and evaluate selected processes and outcomes, EMRs will be needed to capture the full spectrum of data for analyzing illness response to disease management programs and to support necessary changes in care plans to improve both intermediate outcomes (such as lab values), and long-range goals (such as the prevention of illness exacerbations, managing co-morbidities, and halting the progression of complications).

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Conclusion

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A Poll on RECs

Five Reasons We Think Regional Extension Centers are Reckless

By Houston Neal

Software Advice

http://www.softwareadvice.com/medical

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Hi Dr. Marcinko and all ME-P Readers

I hope you are doing well. I am hosting a poll about RECs on my blog at: http://www.softwareadvice.com/articles/medical/five-reasons-we-think-recs-are-reckless-1092310/#survey 

I’m hoping to get as many participants as possible to make this a meaningful survey. I’d really appreciate your help spreading the word to your ME-P membership.

Digital White e-Paper

The poll coincides with an article I wrote on “5 Reasons We Think Regional Extension Centers are RECkless.” I’m excited to see progress of HITECH Act initiatives, but I’m skeptical that throwing money at the problem will lead to efficient and successful adoption of EHRs.

Assessment

It would also be interesting to read any anecdotes you might have about Regional Extension Centers. Please let me know what you and your readers think:

(512) 364-0117 (office)
(800) 918-2764 (toll free)
houston@softwareadvice.com

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More About Regional Extension Centers

RECs Explained

By Shahid N. Shah; MS 

www.BusinessofMedicalPractice.com

The Meaningful Use and Certification requirements along with the myriad of government regulations around Medicare and Medicaid reimbursements will be too complicated for most physicians to understand and manage on their own. To help out small practices, one of the interesting things funded by the HITECH Act was the creation of the Health Information Technology Extension Program. Via that program, the Department of Health and Human Services is required to invest in Regional Extension Centers (called “RECs” and pronounced like “wrecks”). RECs are designed to offer consulting and technical support to physicians in order to help accelerate adoption of Electronic Health Records (EHRs).

Purpose

The purpose of the RECs is to provide guidance on which products to buy, help reduce prices of software through group purchase agreements, and give technical assistance on implementation and deployment. These services will be free of charge to physicians. However, keep in mind that all RECs are non-profit organizations and most have little or no inherent knowledge about EMRs, EHRs, implementations, deployments, computer skills, etc.; initially they are groups that responded to the grant request in a manner that fulfilled documentation required by the government and will be provided government money to help Physicians become meaningful users [MUs].

No Cost Advice

In the short run no RECs will be very good because they will all be inexperienced. Over the long run, some RECs will become very good at their jobs while other RECs will be mediocre or not good at all; only time will tell which ones will be superb and helpful vs. not. Since RECs will be paid by the government for each physician they sign up, RECs will be very eager to approach and conduct outreach to sign you up. And, it will not cost you anything to sign up and the advice and assistance will be free to MDs.

Assessment

Keep in mind, though, that whenever something is free to you, always think about why it’s free. What does the organization get out of providing you free advice, assistance, knowledge, etc. – in the case of RECs, it’s is money from the government. The good news is that RECs are being told by the government that will only be paid if you become a “meaningful user.” However, the bad news is that some RECs will not be able to do a good job and may give you bad advice.

Conclusion

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More on the Meaningful Use of eMRs

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Final Meaningful Use Rules Released by HHS on July 13, 2010.

[By Shahid N. Shah MS]

Link: http://shahid.shah.org

For ambulatory care practices and physicians there are about 25 objectives and measures that must be met to become a “meaningful user”. Keep in mind that meaningful use is not tied to a certified EHR alone; in fact, unless you use the EHR properly and in all the ways the government wants you to, you will not be a “meaningful user”. Don’t be fooled by EHR vendors guaranteeing that they will make you a “meaningful user” – no vendor’s software, no matter how nice, can get your staff to use the software in the way the government wants. You, as the CIO of your practice, are the only one that can guarantee that. In fact, you don’t even need an EHR from a vendor to meet the requirements – you can even roll your own, use open source, or find any other means. But, in general, as long as you can attest and send data to the government that they require you can do it in any way that you want. Be aware that some unscrupulous vendors are scaring practices and making promises that they cannot keep.

Final MU Rules

The final Meaningful Use (MU) Rule was published by HHS on July 13, 2010. It defines 24 objectives for and measures eligible hospitals that could be met to become a meaningful user and qualify for incentive funding. There is a “core set” that must be met by all institutions and a “menu set” of from which organizations must implement at least 5 objectives.

Core Set Objectives

These are the “core set” of 14 objectives that must be met by all institutions and a “menu set” of 10 from which organizations must implement at least 5 objectives (at least 1 public health objective must be chosen from that set).

  1. Use Computer Provider Order Entry (CPOE).
  2. Implement drug-drug, drug-allergy, and drug-formulary checks.
  3. Record demographics.
  4. Implement one clinical decision support rule.
  5. Maintain a problem list of current and active Dxs based on ICD-9-CM or SNOMED CT.
  6. Maintain active medication list.
  7. Maintain active medication allergy list.
  8. Record and chart changes in vital signs.
  9. Record smoking status for patients 13 years or older.
  10. Report hospital clinical quality measures to CMS or States.
  11. Provide patients with an electronic copy of their health information, upon request.
  12. Provide patients an e-copy of discharge instructions at time of discharge, upon request.
  13. Exchange key clinical e-information among providers and patient-authorized entities.
  14. Protect electronic health information.

Menu Set Objectives

These are the “menu set” of 10 objectives from which organizations must implement at least 5. At least one public health objective must be chosen from this set as well (numbers 8, 9, or 10).

  1. Drug-formulary checks.
  2. Record advanced directives for patients 65 years or older.
  3. Incorporate clinical lab test results as structured data.
  4. Generate lists of patients by specific conditions.
  5. Use certified eHR technology to identify patient-specific education resources and provide to patient, if appropriate.
  6. Medication reconciliation.
  7. Summary of care record for each transition of care/referrals.
  8. Capability to submit electronic data to immunization registries/systems.
  9. Capability to provide electronic submission of reportable lab results to public health agencies.
  10. Capability to provide electronic syndromic surveillance data to public health agencies.

Assessment

As can be seen in the link below, the Office of the National Coordinator for Healthcare IT (ONCHIT) is a component of the Department of Health and Human Services (HHS). ONCHIT, usually abbreviated just ONC, is the principal policy group of the Federal Government that defines and manages NHIN.

  • ONC is responsible for coordinating with the Department of Commerce’s National Institute of Standards and Technology (NIST) on the specifications for the NHIN standards.
  • The HIT Policy and HIT Standards Committees are the working groups that advise ONC on what to put in the standards.
  • NIST is responsible for coming up with the test materials (assertions, procedures, methods, tools, data, and so on) that will be used to certify working systems.

Conclusion

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Avoiding Managed Care Contract Pitfalls

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By Staff Reporters

There are several key pitfalls to watch out for when evaluating a managed care organization contract, as noted and continually revised by the Advisory Board Company, and others.

  • Profitability — Less than 52% of all senior physician executives know whether their managed care contracts are profitable. “Many simply sign up and hope for the best.”
  • Financial Data — 90% of all executives said the ability to obtain financial information was valuable, yet only 50% could obtain the needed data.
  • Information Technology — IT hardware and sophisticated software is needed to gather, evaluate, and interpret clinical and financial data; yet it is typically “unavailable to the solo or small group practice.”
  • Underpayments — This rate is typically between 3 – 10% and is usually “left on the table.”
  • Cash Flow Forecasting — MCO contracting will soon begin yearly (or longer) compensation disbursements, “causing significant cash flow problems to many physicians.”
  • Stop-Loss Minimums — SLMs are one-time up-front premium charges for stop-loss insurance. However, if the contract is prematurely terminated, you may not receive a pro rata refund unless you ask for it!
  • Automatic Contract Renewals ACRs or “evergreen” contracts automatically renew unless one party objects. This is convenient for both the payor and payee, but may result in overlapping renewal and re-negotiation deadlines. Hence, a contract may be continued on a sub-optimal basis, to the detriment of the providers.
  • Eliminate Retroactive Denials — Eliminate the rejection of claims that were either directly or indirectly approved, initially.  Sample: “MCO reserves the right to perform utilization review [prospective, retrospective and/or concurrent] and to adjust or deny payments for medically inappropriate services.”  
  • Define “Clean” and “Dirty Claims” — Eliminate the rejection of standard medical claim formats like CMS-1450, CMS-1500 or UB-92 for non-material reasons. Make payment of appropriate clean claims within some specific time period, like 30 days, in order to enhance free cash flows.
  • Reject Silent or Faux HMO or PPs, etc — Eliminate leased medical networks or affiliates and reject further payment discounts to larger subscriber cohorts than originally anticipated.
  • Include Terms for Health Information Technology — Eliminate the economic risk of leading edge electronic advancements like EMRs, PHRs, CPOEs, and so on.  
  • Establish ability to recover payments after contract termination — Eliminate financial carry forward for an excessive period of time.
  • Preserve Payment Ability — Provide medical services if requested by patients, who are then billed directly.
  • Minimize Differentials — Establish a standardized rate structure [fee schedule] for all plans and then grant discounts for administrative or other efficiencies; rather than have different schedules for each individual plan.

Certified Medical Planner

Conclusion

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An Open Letter to the TDA Council on Ethics

And … Judicial Affairs

By Darrell K. Pruitt DDS

Dear Dr. Roy N. Burk – Chairman

In your email to me on Thursday, you informed me that you would call my office this week at your convenience to discuss the as yet to be defined complaints about my “unprofessional conduct” from unnamed origins – some of which are rumored to be as old as three years. Also in your reply that was days late, you confirmed my suspicion that you rarely check your email (even though you provided your address). That is why I asked the manager of the TDA Twitter account to send you the message not to call my office. I’ve given her another message today to tell you to check you email. You said you prefer to have a phone conversation with me. However, I naturally decline because of obvious reasons such as inconvenience, misinterpretations and limited exchange of information.

Foundation of our Nation

The foundation of our nation was defined in carefully chosen words written by Thomas Jefferson, Thomas Paine and others. You have to admit that writing is a much more meaningful and efficient way to resolve the TDA’s mistake than with a 5 minute phone conversation. In addition, by working out our misunderstanding in meaningful sentences that can be viewed by all, both of us are much less likely to say something we might regret if our conversation gets heated… which it will. After all, you threatened my reputation in my community, Dr. Roy Burk. And for that reason, I intend to hold you personally accountable in your community if Judicial Case No. 12-2010-3 is not dismissed. Fair is fair.

Let’s Talk 

Things said in anger help nobody, and can be completely avoided with the written word. In short, there is no reason for either our phone conversation or the meeting you have planned for me on September 18. We can all do something else on that Saturday rather than waste the morning in an Omni Fort Worth hotel room. That is, if you are more interested in resolution than punishment. So let’s negotiate this mistake quickly and quietly, but in a transparent manner, Dr. Burk. As Dr. David May said (but did not mean) when he took over as TDA President in 2007, “Let’s talk.”

TDA Censorship? 

The issue at hand is clearly TDA censorship for political reasons rather than “unprofessionalism.” Trust me when I tell you that nobody who is following us is fooled by the kangaroo court you propose. Considering the recent NLRB decision against the TDA for mistreating employees, the TDA is no longer considered an ethically run organization by many. That means your credibility is shot from the beginning. This week, Jan Jarvis, whom I’m sharing this email with, published “Fort Worth medical clinic spends $15,000 notifying patients of theft” in the Fort Worth Star-Telegram.”

http://www.star-telegram.com/2010/08/06/2389717/fort-worth-medical-clinic-spends.html#ixzz0wIaU5AQa

My Community 

This is my community. Some of my patients are (or rather were) also patients of the local allergy clinic where computers containing 25,000 patients’ PHI were stolen in a burglary. In the end, the data breach will cost the clinic hundreds of thousands of dollars in lost customers because of the bad publicity, in addition to possible HIPAA fines and perhaps a lawsuit from Texas Attorney General Gregg Abbott. Yet, the TDA has still failed to warn members of the liability of their computers. There is simply no excuse for the TDA’s neglect, and punishing me for revealing the truth will not help anyone, and it aggravates me. That said, please allow me to show you exactly how the TDA’s censorship is hurting dentists as well as endangering their patients in Texas – even as we speak: One year ago today, I posted the following article concerning the liabilities of data breaches on the TDA’s Facebook. It is one of many cautionary articles I contributed about data breaches, electronic dental records and HIPAA. However, the TDA as well as the ADA has ignored the exploding identity theft problem because of undisclosed allegiances to entities other than dentists and patients. The behavior of my professional organization is counter to the Hippocratic Oath and indefensible.

In October, an unnamed person in the TDA determined that TDA members should be prevented from reading the following information.

TDA Facebook, August 11, 2009

HITECH/HIPAA Breach notification

On August 18, American dentists will hear from HHS that HITECH-empowered HIPAA now requires that patients be notified if a breach includes their identifiers. Most will be surprised to learn that the notification requirement is nothing new. The law has been there for years. Besides the law, everyone has to admit that notifying those whose welfare is at risk is the only ethical thing to do, even if it bankrupts a practice. And that is the problem. Breach notification will bankrupt a dental practice. The law has been around for years. It simply never was enforced by either HHS or CMS because it would be so devastating to small medical and dental practices. I assume that the shoddy enforcement is why the ADA did not see a need to distribute discouraging information about the HIPAA requirement. For some reason, the ADA supported the adoption of HIPAA. Some day we’ll know why.  This is not the first time I’ve brought up the breach notification topic on a TDA publication. At the first of 2007, the TDA ventured into the blogosphere with “Ask a Colleague” Forum as part of the TDA’s Website. I began to take over the forum with a contribution posted on January 13, 2008 which I copied below. It is a snail-mail letter I received from President-elect Dr. John S. Findley, describing for the only time in ADA history, the ADA’s Data Breach protocol.

ADA Resources? 

As you can see from the hard work put into the letter, it took a considerable amount of ADA dues to produce this response for only one ADA member. Nevertheless, my question was not taken lightly because they probably assumed it would show up again. And, they were correct. Even though the leaders failed to share it with other ADA members, before it was forgotten, it was cc’d to

  • Dr. S. Jerry Long, trustee, Fifteenth District
  • Dr. James Bramson, executive director
  • Ms. Mary Logan, chief operative officer
  • Ms. Tamra Kempf, chief legal counsel
  • Ms. Mary Kay Linn, executive director, Texas Dental Association

Two and a half years later, Findley’s letter is current enough to be posted with only minor changes. For example, Dr. James Bramson and Ms. Mary Logan no longer work for the ADA.

One more note about Dr. Findley’s response to my question, I did not misrepresent myself in my email to him that I had a computer stolen. He knew from six months earlier when I first emailed him my question that it was a hypothetical question about an obscure topic that ADA leaders did not want to talk about.

Posted: 13 Jan 2008 10:05 AM on the TDA.org Forum

Data breach protocol announced

On January 8th, Dr. John S. Findley, President-elect of the American Dental Association, signed the letter below which defines a data breach, describes a dentist’s obligation under the law in Texas to notify patients involved and the penalty for failing to do so. This is the first time this information has been made available to dentists anywhere in the nation in the 12 years of the HIPAA rule. Dr. Findley and his team are to be congratulated for working through an arduous and unpopular task. It demanded courage.

Darrell

ADA

American Dental Association

http://www.ada.org

John S. Findley, D. D. S. President-Elect

January 8, 2008

Dr. Darrell Pruitt

6737 Brentwood Stair Rd., Ste. 220

Fort Worth, Texas 76112-3337

Dear Doctor Pruitt:

I received your email of December 26th and regret to learn of the loss of your computer. I did inquire as to appropriate procedures upon the occurrence of such an event and am copying below an excerpt from the response of out legal department. “It appears that under these circumstances the dentist may wish to notify affected patients that their information may have been compromised so that they can take necessary steps to protect themselves (i.e. cancel credit cards, notify social security about potentially stolen social security numbers…). (This communication is informational and personal consultation between the dentist and his or her attorney is recommended.) They should also check their state breach notification laws to determine if there is anything else that is required. In this case, the Texas Identity Theft Enforcement and Protection Act (Texas Code Sec. 48 et seq) (the “Act”) covers data breach notification. The Act protects both “Personal Identifying Information,” which is defined as any information that alone, or in conjunction with other information, can be used to identify an individual and an individual’s:

A) name, social security number, date of birth, or government-issued identification number;

B) mother’s maiden name;

C) unique biometric data, including the individual’s fingerprint, voice print, and retina or iris image;

D) unique electronic identification number, address, or routing code; and

E) telecommunication access device.

The Act also protects “Sensitive Personal Information,” which is defined as an individual’s first name or first initial and last name in combination with any one or more of the following items, if the name and the items are not encrypted:

i) social security number;

ii) driver’s license number or government-issued identification number; or

iii) account number or credit or debit card number in combination with any required security code, access code, or password that would permit access to an individual’s financial account.

Sec. 48.102 of the Act creates a duty for businesses to protect and safeguard information through creating and implementing procedures for such purpose. If there is a breach in the security of information, the Act requires a business that maintains ‘Sensitive Personal Information” to notify the owners of such information as soon as possible that a breach has occurred. The Act specifies one of the following modes of notice to be provided:

1) written notice;

2) electronic notice, if the notice is provided in accordance with 15 U.S.C. Section 7001 (which basically requires that a consumer must consent to receiving such notice in electronic form); or

3) notice as provided by Subsection (f) (see below).

(f) If the person or business demonstrates that the cost of providing notice would exceed $250,000, the number of affected persons exceeds 500,000, or the person does not have sufficient contact information, the notice may be given by:

1) electronic mail, if the person has an electronic mail address for the affected persons;

2) conspicuous posting of the notice on the person’s website; or

3) notice published in or broadcast on major statewide media.

Violations

“A person who violates the Act is liable to the state for a civil penalty of at least $2,000 but not more than $50,000 for each violation.” The information pertaining to your question was found in the Identity Theft Enforcement and Protection Act, Chapter 48 of the Business and Commerce Act of Texas.

We hope this information helps.

Sincerely,

John S. Findley, D.D.S.

President-elect

JSF:cac

cc: Dr. S. Jerry Long, trustee, Fifteenth District

  • Dr. James Bramson, executive director
  • Ms. Mary Logan, chief operative officer
  • Ms. Tamra Kempf, chief legal counsel
  • Ms. Mary Kay Linn, executive director, Texas Dental Association

Assessment

Dr. Findley’s letter to me was also deleted from the now closed TDA.org Forum.  The TDA’s actions are a lot like burning books, Dr. Roy Burk.

Conclusion

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How Expensive are Healthcare Data Breaches?

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Estimating Financial Damage Often Difficult 

By D. Kellus Pruitt DDS

Dom Nicastro just posted an article on HealthLeaders Media titled “HITRUST: HIPAA Breaches Near $1 Billion.”

http://www.healthleadersmedia.com/content/TEC-255015/HITRUST-HIPAA-Breaches-Near-1-Billion##

“Covered entities and business associates reporting breaches of unsecured personal health information (PHI) affecting 500 or more individuals to the Office for Civil Rights (OCR) together could spend nearly $1 billion because of those breaches.”  Nicastro continues:

“HITRUST used the 2009 Ponemon Institute study that found the average cost for a compromised record to be approximately $144 in indirect costs and $60 of direct costs, for a total cost of $204.”

Fort Worth Star-Telegram

Just days ago, Jan Jarvis described a data breach in the Fort Worth Star-Telegram titled “Fort Worth medical clinic spends $15,000 notifying patients of theft.”

http://www.star-telegram.com/2010/08/06/2389717/fort-worth-medical-clinic-spends.html#ixzz0wIaU5AQa

Jarvis writes,

“In June, employees at a Fort Worth allergy clinic discovered that the office door had been kicked in and four computers containing patients’ personal information including Social Security numbers and birth dates had been stolen.”

Jarvis reports that 25,000 records were involved, and it only cost $15,000 to notify them. That’s only 60 cents per record instead of 60 dollars each as estimated by the Ponemon Institute. Instead of it costing the clinic $1.5 million for direct costs, it only cost them $15,000. That’s a savings of 99%.

Assessment

So what’s the deal? Is the Ponemon Institute that far off in their estimates?

Conclusion

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A Voting Poll on eMRs as a Balance Sheet Item?

A Real or Economically Stimulated Need?

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Many doctors – and their CPAs – view an in office electronic medical record [eMR] system as a balance sheet item to purchase for a medical practice; much like any other piece of business equipment or medical instrumentation.

Of course, ARRA and the HITECH Acts also treat eMRs like an asset that the Federal government can motivate doctors to purchase thru their “meaningful use” economic stimulus and rebate program … sort of a social engineering fiscal health policy for medical professionals. 

And so, the question for doctors really is: do you believe in eMRs as a stand-alone item above and beyond their rebate earning capacity?

THINK “cash for clunkers”, or the first time home buyer “mortgage credit rebate program”.

In other words, sans this Federal economic rebate program externality, would you purchase an eMR system despite the HITECH Act? Will you purchase one once the rebate period has expired. Are eMRs a depreciating or appreciating asset?

Please opine with your vote!

Conclusion

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Dr. David Blumenthal Spins “Professionalism”

My Take on “Meaningful Use”

D. Kellus Pruitt DDS

Recently, lawmakers complained that the federal criteria for “meaningful use” of eHRs – usage required before providers who risk purchasing electronic health record systems can be reimbursed – aren’t strict enough to justify the billions of dollars in incentive payments that the government promised physicians and hospitals. Matthew DoBias, writing for ModernHealthcare, quoted Rep. Wally Herger (Calif.) – the senior Republican on the Ways and Means Committee’s health subcommittee – who said:

“The new HIT regulations are a step in the right direction and should put Medicare on a path to improved quality and efficiency. However; by watering down the final regulations, we have missed an opportunity to advance healthcare delivery and ensure wise use of taxpayer money.”

http://www.modernhealthcare.com/article/20100721/NEWS/100729995/1153

Rep. Wally Herger

“Improved quality” you say, Rep. Herger? That proves that politicians like Herger will say whatever it takes to get elected, even if it’s transparently misleading. Herger’s confident claim of improved quality of care from using eHRs is typical of Washington even though quality claims are widely disputed in most medical circles. And if eHRs were as efficient as Herger and his campaign donor’s claim, then the billions of dollars in incentive payments that have already been billed to our grandchildren wouldn’t be wasted to bribe physicians to purchase eHR systems that are too lousy to move off the shelves. If HIT stakeholders’ products offered value for Americans in the land of the free, they would sell for natural reasons of consumer demand and wouldn’t require a government mandate and Herger’s deception. Besides, what does any politician know about “wise use of taxpayer money” even outside of the medical field, Mr. Herger?

[picapp align=”none” wrap=”false” link=”term=doctor+computer&iid=107036″ src=”http://view3.picapp.com/pictures.photo/image/107036/medical-professional-using/medical-professional-using.jpg?size=500&imageId=107036″ width=”337″ height=”506″ /]

The Criteria

The criteria for meaningful use have been cut down to 15 issues allegedly because demanding all 25 risked improving care and saving money far too ambitiously. Tony Trenkle, director of the Office of E-Health Standards and Services at CMS, puts his special spin to the “watering down” of requirements. He is quoted in an article by Emily Long in NextGov:

“We set the bar where we felt it was appropriate and also signaled for future stages that we would be setting the bar much higher, We’re going along with ways we can modify to reflect real-life experiences we hit once the program begins.”

Why didn’t Trenkle just say, “We at CMS are making this sucker up as we go”?

http://www.nextgov.com/nextgov/ng_20100720_9874.php?oref=topnews

Dr. David Blumenthal

Dr. David Blumenthal, the national coordinator for health IT, has given up apologizing for bankrupt ideas like the CMS’s criteria for “meaningful use” of electronic health records – as if they made sense. They don’t, and Blumenthal must know that the clicking-for-cash busywork plan he inherited is a waste of time and money. Otherwise, the AMA wouldn’t be complaining.

(See “AMA Weighs in on ‘Meaningful Use’ Requirements For E-Records” – Wall Street Journal Blog)

http://blogs.wsj.com/health/2010/07/21/ama-weighs-in-on-meaningful-use-requirements-for-e-records/  

Surely Dr. Blumenthal recognizes that naive lawmakers like Rep. Wally Herger are foolishly demanding unwanted and dangerous micromanagement of healthcare, not in the interest of patients’ welfare, but for political power. (Do Americans really want Wally Herger from California regulating healthcare?) Rather than attempting to sell systems to doctors based on disingenuous claims of unproven value, Blumenthal chose to punt. All he could offer was a lame appeal to pride: “Much more important than incentives will be a professional sense of obligation,” (Emily Long, NextGov, ibid).

The Oath

Doesn’t the Hippocratic Oath, as well as business survival trump the dangerous nonsense Dr. Blumenthal calls “professional obligations”? As if to emphasize that point, just hours ago, some relevant news was posted concerning the danger of eHRs: “A Massachusetts hospital is under scrutiny after hundreds of thousands of patient and employee records went missing earlier this year. The missing files underscore the problems health care providers face when balancing patient privacy and the need to store massive amounts of data, especially as new federal rules for electronic health records come into play.” (See “Massachusetts Hospital Reports 800,000 Personal Records Missing” by Brian T. Horowitz for eWeek, 7/21/10).

http://www.eweek.com/c/a/Health-Care-IT/Massachusetts-Hospital-Reports-800000-Personal-Records-Missing-638660/ 

Assessment

How does risking such harm to patients rise to the level of a “professional obligation”? I think Dr. Blumenthal might be confusing professionalism with patriotism. They are both traditional, flexible buzzwords that start with the letter “P” and are often used for just about any bureaucratic chore – even so far as to prove diametrically opposing views.

Conclusion

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Understanding HIT Security Risks – The Ugly Truth!

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On the Privacy and Security of Healthcare Records

Dr. Mata

[By Richard J. Mata, MD, CIS]

There is no privacy …  get over it.

Scott McNealy, Former Sun Microsystems CEO

Storing and transmitting health information in electronic form exposes it to risks that do not exist, or exist to a lesser extent, when the information is maintained in paper.  For example, although both paper-based and electronic systems need protection from fire, water, and wear and tear because of aging, electronic data is also vulnerable to hardware or software malfunctions that can make data inaccessible or become corrupt, and to non-secure policies that can make data vulnerable to illegal access.  In addition, cyber-crimes, and unauthorized intrusions originating both internally and externally, are increasing dramatically every year, costing companies millions of dollars.  Nonetheless, electronic medical records (EMRs) are usually considered more secure than paper patient charts because paper records lack an audit trail, papers are easily lost, and their contents can be illegible.

Take Care the Risks

Healthcare organizations must take the new risks seriously, however, because health information is a vital business asset, and protecting it preserves the value of this asset.  In addition, securing patients’ information protects their privacy and enhances the organization’s reputation for professionalism, patient well-being, and trustworthiness.  Hospitals, emerging healthcare organizations (EHOs), physicians, and healthcare entities long ago recognized the value of health information, and implemented security policies and procedures, but as they move more into the electronic arena, it is vital to revise and update policies and procedures to acknowledge the different risks inherent in the digital age.

Three Components of Security

The three classic components of information security are confidentiality, integrity, and availability.  Donn B. Parker, a pioneer in the field of computer information protection,[1] added possession, authenticity, and utility to the original three.  These six attributes of information that need to be protected by information security measures can be defined as follows:  

  • Confidentiality: The protection and ethics of guarding personal information — for example, being cognizant of verbal communication leaks beyond conversation with associated healthcare colleagues.
  • Possession: The ownership or control of information, as distinct from confidentiality — a database of protected health information (PHI) belongs to the patients.
  • Data integrity: The process of retaining the original intention of the definition of the data by an authorized user — this is achieved by preventing accidental or deliberate but unauthorized insertion, modification or destruction of data in a database.  Make frequent backups of data to compare with other versions for changes made.
  • Authenticity: The correct attribution of origin — such as the authorship of an e-mail message or the correct description of information such as a data field that is properly named.  Authenticity may require encryption.
  • Availability: The accessibility of a system resource in a timely manner — for example, the measurement of a system’s uptime.  Is the intranet available?
  • Utility: Usefulness; fitness for a particular use — for example, if data are encrypted and the decryption key is unavailable, the breach of security is in the lack of utility of the data (they are still confidential, possessed, integral, authentic and available).

Ethics

When these attributes are considered in the healthcare context, another factor comes into play: ethics.  According to Dr. J. A. Magnuson, professor of public health informatics at Oregon Health Science University’s Medical Informatics Program, privacy,[2] security, and ethics are inextricably intertwined, and all are critical to public health’s role as a trustee of the public’s data.  As public health becomes increasingly involved in Electronic Data Interchange (EDI;[3]), the information aspects of privacy, security, and ethics become ever more critical.  All doctors take an ethical oath to protect the patient, and the obligation to uphold this oath extends to health data management, even for employees who do not take an oath.

The fields of medicine and information technology (IT) each have separate and related ethical considerations.  Ethics may prohibit technology, for example, when using a specific application that would make a security breach likely.  However, ethics may also demand technology.  Suppose that a new surveillance application would improve public health — is it not ethically imperative to utilize it to save countless lives?  But suppose it also almost guarantees a security breach — what does the ethical position on use of the application become then?  That is an extreme example, though not completely unrealistic.

FISA

Varied Uses

Complicating the picture is the fact that IT in the healthcare arena has so many and varied uses.  For instance, office-, clinic-, and hospital-based medical enterprise resource planning (ERP) is based on the same back-end functions that a company requires, including manufacturing, logistics, distribution, inventory, shipping, invoicing, and accounting.  ERP software can also aid in the control of many business activities, like sales, delivery, billing, production, inventory management, quality management, and human resources management.  However, other applications particular to the medical setting include the following:

  • The EMR, which has the potential to replace medical charts in the future, is feasible.[4]
  • Healthcare application service providers (ASPs)[5] are available via Internet portals.
  • Custom software production may produce more solution-specific applications.
  • Medical speech recognition systems and implementation are replacing dictation systems.
  • Healthcare local area networks (LANs), wide area networks (WANs), voice-over Internet protocol (IP) networks, Web and ATM file servers are ubiquitous.
  • The use of barcodes to monitor pharmaceuticals is decreasing the chance of medication errors and warns providers of potential adverse reactions.
  • Telemedicine and real-time video conferencing are already a reality.
  • Biometrics will be used more often for data access.
  • Personal digital assistant (PDA) wireless connectivity, which relies on digital or broadband technology including satellites, and radio-wave communications are increasingly common.
  • The use of wireless technology in medical devices will be increasing.

No Healthcare Standardization

All of these applications offer advantages, but the security of these IT methods and devices is not yet fully standardized or familiar to health professionals; despite the CCHIT, Office of the National Coordinator for Health Information Technology, etc.  They all involve inherent security and privacy risks, and the prudent healthcare organization will want to ensure that these risks are identified and contained.  For instance, a single firewall or intrusion detection system (IDS) may not be enough.

The process must begin by conducting a security risk assessment — that is, doing a thorough assessment of current systems and data, and performing checks such as real-time intrusion testing, validation of data audit trails, firewall testing, and remediation when gaps or failed systems are exposed.  These activities are part of developing a healthcare security plan, including disaster recovery.

Privacy Officers

To ensure that the risk assessment is thorough, hospital network administrators and Privacy Officers should have a working knowledge of federal regulations and of the following security mechanisms:

  • vulnerability assessment;
  • security policy development;
  • risk management;
  • firewall assessment;
  • security application assessment;
  • network security assessment;
  • incident response and recovery assessment;
  • authentication and authorization systems;
  • security products;
  • firewall implementation;
  • public key infrastructure (PKI) design;
  • virtual private network (VPN) design and implementation
  • intrusion detection systems;
  • penetration testing;
  • security program implementation;
  • security policy assessment; and
  • security awareness training.

The federal government has recognized the importance of health information security by establishing regulatory guidance with its Health Insurance Portability and Accountability Act of 1996 (HIPAA).

The International Standards Organization

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IT system managers in healthcare settings are also familiar with the comprehensive security model offered by the International Standards Organization (ISO).  For instance, using ISO’s 17799 Code of Practice for Information Security Management, versions 2000, 2005, or 2010 information security is achieved by implementing a suitable set of controls to govern policies, processes, procedures, organizational structures and software and hardware functions.  The Code requires the IT manager to establish, implement, monitor, review, and where necessary, improve these controls to ensure that the specific security and business objectives of a healthcare organization are met.

Assessment

The work of the National Institute of Science and Technology (NIST) in developing innovative technology for the healthcare sector is also of interest to IT system managers.  For instance, research on a computer note-writing system that captures clinical data automatically and a data repository system that captures patient data and integrates it with clinical decision support and knowledge bases are two of the initiatives that have originated with NIST.  In addition, the organization publishes numerous Special Publications that provide guidance on how to establish and maintain IT security.

CASE MODEL: HIT Security

Conclusion

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References:


[1]   Donn B. Parker developed the so-called Parkerian Hexad Principles, which discuss the attributes of information security.

[2]   Privacy generally refers to a ‘people’ context, a state of being free from unauthorized intrusion or invasion.  This concept is as applicable to medical records as it is to your own house.  Confidentiality is viewed more in the context of information, usually dealing with accessing and sharing information or data.

[3]   EDI involves electronic transmission methods, often utilizing networks or the Internet.[3]  The benefits of EDI include speed, data entry savings, and reduction of manual errors; the risks are legion.

[4]   Terms used in the field include electronic medical record (EMR), electronic patient record (EPR), electronic health record (EHR), computer-based patient record (CPR), etc.  These terms can be used interchangeably or generically, but some specific differences have been identified.  For example, an EPR has been defined as encapsulating a record of care provided by a single site, in contrast to an EHR, which provides a longitudinal record of a patient’s care carried out across different institutions and sectors.  However, such differentiations are not consistently observed.

[5]   An application service provider (ASP) is a business that provides computer-based services to customers over a network.

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What is the Cost of eHRs?

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A Retrospective Look-Back

By Richard J. Mata; MD CIS CMP™

Studies by the Organization for Economic Cooperation and Development (OECD) show that healthcare spending in the U.S. accounts for 16-17% of GDP, which is more than six-seven percentage points higher than the average of 8.9% in other OECD countries.  This translates into per capita health spending of $5,635 in the U.S. compared with median costs of $2,280 in other OECD countries.[1]  Suggestions as to the economic drivers of U.S. health spending include excessive service use, administrative complexity, population aging, threats of malpractice litigation, defensive medicine practices, and the lack of patient waiting lists.  In further comparisons with the OECD countries, it appears the U.S. overpays for physician visits, hospital stays, and pharmaceuticals.

In the Year 2004

A 2004 OECD paper suggested that one way of improving performance would be to move towards EHR:

Health systems should invest in automated health-data systems, including electronic medical records and systems to automate medication orders in hospitals. Better systems for recording and tracking data on patients, health and health care are needed to make major improvements in the quality of care.[2]

In the U.S., possible savings from the adoption of EHR have been projected to reach $142 billion in physician office visits, and $371 billion in hospital costs over a 15-year period.  These projections have not been validated by the experience in other OECD countries where the adoption movement is ahead of U.S. efforts by anything from four to thirteen years.

Nevertheless, the U.S. began its quest to move towards EHR in 2004 as medical software companies began actively marketing their systems, although funding for this endeavor did not come through until 2006.  In spite of this effort, the U.S. has the lowest percentage of physician providers using any EHR compared to Germany, Canada, United Kingdom, and Australia.  The U. S. physicians’ low adoption rate involves fear of the loss of productivity, lack of financial incentives, and high startup costs of as high as $40,000 per physician EHR adoption.

When spending on IT implementation in the healthcare system is compared on an international level, the U.S. lags dramatically behind the major OECD countries.  The U.S. spends $0.43 per capita compared to a high of $193 in the U.K.  This difference is even more dramatic when compared with the German experience, where IT adoption in the healthcare system is almost universal.  In thirteen years, Germany has spent $1.88 billion.  Their annual per capita cost has been $1.63.  The U.S. has reached only 25% of that expenditure so far.

Barriers to Adoption

The greatest barrier to adoption of EHR in most OECD countries has been the need to simplify the health insurance contracts payment structures with standard nomenclatures that can be adapted to EHR.  The major OECD countries also report that there must be a national adoption of IT standards in the healthcare system as well as a national effort to focus on privacy and confidentiality standards.  This assures better coordination of implementation and provides better strategies for adoptions through public incentives and grants.

 

Domestic 5 Year Costs

In the U.S., the five-year costs for a national IT healthcare network have been estimated to be as high as $103 billion in capital and $53 billion in interoperability.  Hospital costs for functionality were estimated to be $51 billion, skilled nursing facilities would bear $31 billion of costs, and physician offices would bear $18 billion of the costs. (Anderson, 2006)  EHR systems that have been implemented have been used mainly for administrative rather than clinical purposes.

In the Year 2005

A 2005 study by Richard Hillestad and colleagues at RAND[3] estimates that implementation of a nationwide EHR network would take about 15 years and cost hospitals about $98 billion and physicians about $17 billion.  Over the 15-year period, the average annual cost to hospitals would be $6.5 billion and the average annual cost to physicians would be $1.1 billion (CQ HealthBeat [1], 9/14). However, if 90% of providers adopted such a network, annual savings would total $81 billion, including $77 billion from improved efficiency and $4 billion from reduced medical errors, the RAND study found.  The study estimates that an EHR network would reduce adverse drug events in inpatient hospital settings by 200,000 annually and reduce such events in ambulatory settings by two million annually, saving $1 billion annually in hospitals and $3.5 billion in ambulatory settings.  For hospitals, about 60% of these savings would be from reduced adverse drug events in patients ages 65 and older, while 40% of savings to ambulatory practices from reduced medication errors would be in patients 65 and older (CQ HealthBeat [1], 9/14).

Assessment

In addition, the study estimates that a national EHR network would save Medicare about $23 billion annually and save private insurers about $31 billion annually.  The study projects that the estimated total annual savings of $81 billion would double if providers followed all checkup reminders and other prompts from the system (AP/Las Vegas Sun, 9/14).  Currently, about 20% to 25% of hospitals and 15% to 20% of physician offices have EHR systems, according to the study (CQ HealthBeat [1], 9/14).

But, what is the estimated cost in 2010?

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Conclusion

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References:


[1]    For details of the report, see http://www.oecd.org/dataoecd/29/52/36960035.pdf.

[2]   OECD, Towards High-Performing Health Systems, see http://www.oecd.org/document/26/0,2340,en_2649_37407_31734042_1_1_1_37407,00.htm.

[3]   See http://www.rand.org/health/feature/2006/060414_shekelle.html.  The report is also discussed in some detail in Neergaard, AP/Las Vegas Sun, 9/14/05.  See http://www.ihealthbeat.org/index.cfm?Action=dspItem&itemID=114707.

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Health Information Privacy Breaches

Breaches Affecting 500 or More Individuals

By Staff Reporters

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As required by section 13402(e)(4) of the HITECH Act, the DHHS Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals. The following breaches have been reported to the Secretary.

www.hhs.gov/ocr/privacy/hipaa/administrative/breachnotificationrule/postedbreaches.html

Conclusion

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The Pros and Cons of eMRs

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Delving Deeper into the Historic Origins of Debate

Dr. Mata

[By Richard J. Mata MD, CIS, CMP™]

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According to Wager, Ornstein, and Jenkins, in 2005, the perceived advantages of an EHR system include the following:

  •  Quality of the patient records (legible, complete, organized) — 86%
  •  Better access to patient records (available, convenient, fast) — 86%
  •  Improved documentation for patient care purposes — 93%
  •  Improved documentation of preventive services — 82%
  •  Improved documentation for quality improvement activities — 82%

Items viewed as an advantage by fewer respondents include the following:

  •  Administrative cost savings — 38%
  •  Improved efficiency — 61%
  •  Security of patient records — 64%

Nothing directly was said about cost savings or increased medical care quality. These topics have become more contentious issues during the past few years.

The Gurley Opinion

According to HIT expert Lori Gurley, in 2006, of the American Academy of Medical Administrators:

“The EHR provides the essential infrastructure required to enable the adoption and effective use of new healthcare modalities and information management tools such as integrated care,  evidenced-based medicine, computer-based decision support, care planning and pathways, and outcomes analysis” (Schloefell et al).  Although the benefits that support implementation of an EHR are clear, there are still barriers too, therefore the concept is still not accepted. “However, this could also be said of almost every other area of positive change and improvement within healthcare systems […]” (Schloefell et al).  There must be more involvement by the government and the private sector “to make changes where possible to instigate, motivate, and provide incentives to accelerate the development of solutions to overcome the barriers” (Young).

THINK: ARRA and HITECH, today. Of course, there are obviously advantages and disadvantages to both the paper medical record and the EHR.

Multi-Factorial Issues

Many factors must be considered before any healthcare organization or medical practice should implement an EHR.  The organization must first obtain as much information as possible about this new concept, and then the information must be carefully reviewed and the pros and cons discussed. Only then should the organization make their decision about this very important issue.

“The [EHR] as a part of a Clinical Information System (CIS) is a powerful tool which ties together documentation of the patient visit (clinical information), coding (diagnosis, and treatment procedures), which then translates into more accurate billing processes, reduces reprocessing of medical claims, and that translates into increased customer satisfaction with a provider” (Koeller). Although the technology is available, progress towards an EHR has been slower than expected. “Widespread use of [EHRs] would serve both private-and public-sector objectives to transform healthcare delivery in the United States” […] EHRs would also “enhance the health of citizens and reduce the costs of care” (Dick, Steen, and Detmer).

The MRI Study

According to a 2005-07 survey by the Medical Records Institute, the following factors are driving the push towards EHR systems within medical organizations:

Motivating Factors 2005 Ambulatory
The need to improve clinical processes or workflow efficiency. 89.3% 91.2%
The need to improve quality of care. 85.0% 85.3%
The need to share patient record information among healthcare practitioners and professionals. 81.1% 66.9%
The need to reduce medical errors (improve patient safety). 76.1% 69.1%
The need to provide access to patient records at remote locations. 67.9% 65.4%
The need to improve clinical documentation to support appropriate billing service levels. 67.1% 76.5%
The need to improve clinical data capture. 64.6% 61.0%
The need to facilitate clinical decision support. 60.7% 50.7%
The requirement to contain or reduce healthcare delivery costs. 54.6% 61.8%
The need to establish a more efficient and effective information infrastructure as a competitive advantage. 53.6% 53.7%
The need to meet the requirements of legal, regulatory, or accreditation standards. 50.0% 44.1%
Other 5.7% 5.1%
Totals 280 136
Margin of Error +/- 5.8% +/- 8.4%

Now, compare this with the results of the 2007 survey that focused on the factors driving hospitals to expand their use of EHR.

Driving Factors in a Hospital 2007
Efficiency and convenience, e.g., better networking to the medical community and patients and remote access 57.8%
Satisfaction of physicians and clinician employees 42.2%
The need to survive and thrive in a much more competitive, interconnected world. 41.0%
Regulatory requirements of JCAHO or NCQA. 35.6%
Savings in the Medical Record Department and elsewhere, including transcription. 24.0%
Value-based purchasing/pay for performance 17.7%
Pressure from payer groups, such as Leapfrog Group 15.2%
Possibility of subsidized purchase of HER, e-prescribing systems, etc. by purchasers/payers/large health systems. 8.8%
Totals 329
Margin of Error +/- 5.4%

Assessment

How have these motivating and driving factors changed today; have they really changed in 2010?

Does this deeper dive reveal any other truths; political, social, business or economic? Is this historical review helpful in understanding the reluctance or eagerness for EMR acceptance, or not?

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Conclusion

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About Regional Health Information Organizations

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The RHIO Concept – Defined

Dr. Mata

[By Richard J. Mata MD, CIS, CMP™]

Regional Health Information Organizations (RHIOs), or data exchanges, are multi-stakeholder organizations.  They might include groups of hospitals, medical societies, payers, major employers, and other healthcare organizations.

Generally, these stakeholders are developing RHIOs with the goal of affecting the safety, quality, and efficiency of healthcare as well as improving access to healthcare by expanding the use of health information technology.  It is expected that RHIOs will be responsible for motivating and causing integration and information exchange in the nation’s revamped healthcare system

Assessment

Regions in the U.S. continue to use various definitions of “multi-stakeholder organizations.”  For instance, in Wichita, Kansas, the Clinics Patient Index is a software architecture as well as support environment that facilitates integration among outpatient clinics and hospital emergency departments.

And, what will be the affect of [HR 3590], or the Patient Protection and Affordable Care Act, on RHIOs?

Conclusion

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Defining Electronic Medical Record Systems

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Does Linguistic Obfuscation Exacerbate our Use Ambivalence?

[By Dr. Richard J. Mata; CIS, CMP™]

[By Dr. David E. Marcinko; MBA, CMP™]

The 2003 Institute of Medicine (IOM) Patient Safety Report [1] described an EHR [2] as encompassing:

  • a longitudinal collection of electronic health information for and about persons;
  • [immediate] electronic access to person- and population-level information by authorized users;
  • provision of knowledge and decision-support systems [that enhance the quality, safety, and;
  • efficiency of patient care] with support for efficient processes for health care delivery.

The IOM Report

A 1997 IOM report, The Computer-Based Patient Record: An Essential Technology for Health Care, provides a more extensive definition:

A patient record system is a type of clinical information system, which is dedicated to collecting, storing, manipulating, and making available clinical information important to the delivery of patient care. The central focus of such systems is clinical data and not financial or billing information. Such systems may be limited in their scope to a single area of clinical information (e.g., dedicated to laboratory data), or they may be comprehensive and cover virtually every facet of clinical information pertinent to patient care (e.g., computer-based patient record systems).

The HIMSS Model

The EHR definitional model document developed by the Health Information and Management Systems Society (HIMSS, 2003) includes:

“a working definition of an EHR, attributes, key requirements to meet attributes, and measures or ‘evidence’ to assess the degree to which essential requirements have been met once EHR is implemented.”

 

The IOM Model

Another IOM report, Key Capabilities of an Electronic Health Record System [Tang, 2003], identifies a set of eight core care delivery functions that EHR systems should be capable of performing in order to promote greater safety, quality and efficiency in health care delivery:

8 Core Principles

Today, we realize that the eight core capabilities that Electronic Health [Medical] Records should possess are:

  1. — Health information and data. Having immediate access to key information – such as patients’ diagnoses, allergies, lab test results, and medications – would improve caregivers’ ability to make sound clinical decisions in a timely manner.
  2. — Result management. The ability for all providers participating in the care of a patient in multiple settings to quickly access new and past test results would increase patient safety and the effectiveness of care.
  3. — Order management. The ability to enter and store orders for prescriptions, tests, and other services in a computer-based system should enhance legibility, reduce duplication, and improve the speed with which orders are executed.
  4. — Decision support. Using reminders, prompts, and alerts, computerized decision-support systems would help improve compliance with best clinical practices, ensure regular screenings and other preventive practices, identify possible drug interactions, and facilitate diagnoses and treatments.
  5. — Electronic communication and connectivity. Efficient, secure, and readily accessible communication among providers and patients would improve the continuity of care, increase the timeliness of diagnoses and treatments, and reduce the frequency of adverse events.
  6. — Patient support. Tools that give patients access to their health records, provide interactive patient education, and help them carry out home monitoring and self-testing can improve control of chronic conditions, such as diabetes.
  7. — Administrative processes. Computerized administrative tools, such as scheduling systems, would greatly improve hospitals’ and clinics’ efficiency and provide more timely service to patients.
  8. — Reporting. Electronic data storage that employs uniform data standards will enable health care organizations to respond more quickly to federal, state, and private reporting requirements, including those that support patient safety and disease surveillance.” [3]

Assessment

With all the confusion surrounding terms like quality improvement and “meaningful use” which can mean major Federal dollars to the coffers of a medical practice, clinic or hospital; are we still confused about basic definitional terms?

And, does eMR linguistic obfuscation exacerbate our use ambivalence and encourage physician/dentist eMR avoidance?

Conclusion

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References:

[1]   See http://www.himss.org/content/files/PatientSafetyFinalReport8252003.pdf.

[2]   EHR (electronic health record) is often used interchangeably with EMR (electronic medical record).  In this discussion, EHR will be used consistently.

[3]   See http://www.iom.edu/.

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On HIT Continuity Planning

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Setting Up Your HIT Security System

Dr. MataBy Richard J. Mata, MD, CIS, CMP™ [Hon]

In order for a healthcare organization to thrive, it must be able to continue to function no matter what the circumstances are.

When disaster strikes, the organization must mobilize all the talent and resources needed to continue their operations and return to a normal state as soon as possible.

Time is money, and in today’s economy, an hour could be worth thousands of dollars.  Every department in an organization has responsibilities during a disaster.  Planning for a disaster and then dealing with it is a team effort by all parts of an organization.

Phases of Healthcare Business Continuity Planning

A system is required to realize this objective, and part of this system is healthcare entity business continuity planning (BCP).

Phase One: Set up a BCP Project

The first step is to set up a BCP project, which includes feedback from key members from all departments.  Appoint a project manager who has a solid background in the clinical and financial systems and functions that the organization deploys or services it provides.  The project manager can work with business and system analysts to document business flow and interactions with computerized systems that may go down, and how the organization will function on a manual system until service returns.

Phase Two: Review Emergencies and Assess Business Risk

The second phase involves reviewing the different types of emergencies that can arise and assessing the risks to the various business processes already documented.  This is accomplished following a system or service function.

Phase Three: Prepare for Emergencies

The third phase includes identifying of back-ups and recovery strategies to mitigate the effects of an emergency.  A storage area network (SAN) or redundant server could be used as back-ups.

Phase Four: Plan for Disaster Recovery

The fourth phase involves the development of procedures to be followed by a Disaster Recovery Team where human life may be at risk.  A disaster might be caused by weather, sabotage, or electrical power and be specific to the particular organization and its business and IT infrastructure.

Phase Five: Plan for Business Recovery

The fifth phase is critical, and involves developing detailed procedures for the recovery of the business.  Again, the BCP project manager could use each business or service procedure that was documented in phase two and detail which financial or clinical systems are involved, what would be done if the systems were down, and what the plan for recovering the system might be.

Phase Six: Test Business Recovery Procedures

The sixth phase involves simulating authentic emergencies and testing of the business recovery phase.  For example, how would business processes or services be affected by an electrical outage?  How fast can a power generator pick up the outage – and what might happen after a timely pause?  How would patients who were receiving mechanical support be affected?  What would happen to the clinical laboratory?

Phase Seven: Train the Staff

Phase seven covers the training of all employees in the procedures necessary to manage the business recovery process.  These are the procedures tested in phase six, which may require modification.

Phase Eight: Maintain the Currency of the Plan

Phase eight includes treating BCP as a dynamic project to be kept up to date to reflect all changes to business processes and employee structure.

Conclusion

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How eMR Vendors May Mislead You

Challenging Assertions

By Shahid N. Shah MS

As the physician executive of your medical practice, it’s your job to challenge any eMR vendors’ assertions about why you need an eMR, especially during the selection and production demonstration phase.

Information Availability [Anytime – Anywhere]

The most important reason for the digitization of medical records is to make patient information available when the physician needs that information to either care for the patient or supply information to another caregiver.

Electronic medical records are not about the technology but about whether or not information is more readily available at the point of need.

Reasons to Purchase?

In no particular order, the major reasons given for the business case of eMRs by vendors include:

• Increase in staff productivity
• Increase of practice revenue and profit
• Reduce costs outright or control cost increases
• Improve clinical decision making
• Enhance documentation
• Improve patient care
• Reduce medical errors

Assessment

So, doctors beware! Challenge vendor “authority.”

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Editor’s Note

Shahid N. Shah is an ME-P thought leader who is writing Chapter 13: “Interoperable e-MRs for the Small-Medium Sized Medical Practice” [On Being the CIO of your Own Office] for the third edition of the best selling book: Business of Medical Practice [Transformational Health 2.0 Skills for Doctors] to be released this fall by Springer Publishers, NY. He is also the CEO of Netspective Communications, LLC.

www.BusinessofMedicalPractice.com

Conclusion

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Is the Texas Dental Association too Authoritarian?

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About Employee Mary Kay Linn

[By Darrell Kellus Pruitt; DDS]

Texas Dental Association Executive-Director Mary Kay Linn seems to think that TDA members owe her respect for some reason. I don’t see it. You get what you give TDA employee Mary Kay Linn.

Link: TDA response to Pruitt

I’ve attached the partially answered, authoritarian response from the TDA. I think it speaks for itself. And, I posted the following Twitterpoem today.

Mary Kay Linn, the executive director of the TDA just doesn’t get it.

@theTDA, I received the responses to some of the 30+ questions that were invited by the TDA. Linn’s evasion is transparent and regrettable.

@theTDA, when a Judicial Committee member delivered the PDF, he said Linn told him to tell me that “This is it. No more questions.”

Assessment

He added that: “There will be no follow up responses and that the very busy TDA staff spent far too much time on my questions already.” 

TDA Executive Director Mary Kay Linn, this will not end well for you.

Assessment

How responsive was the TDA; just right, under or overwhelming when pushed? Or, was Dr. Pruitt over-the-top? Does he expect too much from his professional association? Does almost every DDS except him know that the “emperor has no clothes?” Or, is he one member with critical thinking skills instead of blind [misplaced] faith?

Finally, is there an analogy here for the AMA, ADA, APMA, ANA, AOA, etc? Are the aging command-control medical association monopolies crashing down in the era of internet connectivity and professional networking? Do we need new norms and etiquette models of communication? Please opine.

Conclusion

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What is M-Health for Physicians?

On “Smart Phones” and Mobiles Devices

By Shahid N. Shah MS

M-Health or “mobile health” is an industry term for collectively defining those tools and technologies that can be used on “smart phones” like iPhone, Blackberry, Android, or on traditional mobile phones from various vendors.

Unlike traditional computers, almost every patient that walks into your medical office, as well as all your own staff, have mobile devices already. If you can find mobile applications that can help your practice you can immediately put to use without large capital expenses, network configuration, and other technical tasks.

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The M-Health Initiative

According to the mHealth Initiative, there are 12 major “application clusters” in mobile health: patient communication, access to web-based resources, point of care documentation, disease management, education programs, professional communication, administrative applications, financial applications, emergency care, public health, clinical trials, and body area networks.

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The Applications

Almost all of these applications are focused around the patient but most of them will be directly useful to you and your staff as well. Here’s how:

  • Improving physician-patient communications. You can get your staff to send out text messages, e-mails, photos, and other information about your practice to the patient before their visit. You can remind them about appointments, tell them what to expect, ask them for their insurance and check-in information, or let them send you their personal health record link. During the visit you can send them patient education information directly to their phones instead of handing out paper. After the visit you can send medication reminders, additional educational resources, and update to their personal health record, or ask them to join a Health 2.0 social network. PumpOne, GenerationOne, Intouch Clinical, Life:Wire, and Jitterbug phones all have great patient user experiences and you should tell your patients about them.
  • Faster access to information for you and your patients. There are countless web-based resources that are now at your fingertips on a phone. Patients can lookup providers, labs, testing services, etc. that you can refer them to; you can help them join clinical trials, and manage their health records online. None of these require a computer either in your office or in their home, it can all be done on the phone. Check out companies like Healthagen and iSeek.
  • Real-time documentation of office or hospital visits. Most of the things you want to do in your EMR are possible on a smart phone today. You can get your patient profiles, document an encounter with basic order management and lab results review capabilities, and immediate storage into either your own EMR or your hospital’s information system.
  • Help those patients with the most time-consuming treatments. You already know that disease management is an important part of managing the health of chronic patients; diabetes and hypertension are two perfect examples. Help enroll your patients into Diabetes Connect, MediNet, HealthCentral, and similar applications that can help track compliance with your medical treatment guidance. If they use these applications they can simply give you printouts or login credentials so that you can track their progress without doing any data entry yourself. There are patient tools for most common diseases.

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Editor’s Note

Shahid N. Shah is an ME-P thought leader who is writing Chapter 13: “Interoperable e-MRs for the Small-Medium Sized Medical Practice” [On Being the CIO of your Own Office] for the third edition of the best selling book: Business of Medical Practice [Transformational Health 2.0 Skills for Doctors] to be released this fall by Springer Publishing, NY. He is also the CEO of Netspective Communications, LLC.

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Conclusion

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On Hospital CPOE Systems [Part One]

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Computerized Physician Order Entry Systems

[By Brent Metfessel MD, MIS]

Since the late 1990s, there has been increasing pressure for hospitals to develop processes to ensure quality of care. The Institute of Medicine (IOM) has estimated the number of annual deaths from medical error to be 44,000 to 98,000.  Manual entry of orders, use of non-standard abbreviations, and poor legibility of orders and chart notes contribute to medical errors.  They also concluded that most errors are the result of system failures, not people failures.

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Other studies suggest that between 6.5% and 20% of hospitalized patients will experience an adverse drug event (ADE) during their stay. Both quality and cost of care suffer.  The cost for each ADE is estimated to be about $2,000 to $2,500, mainly resulting from longer lengths of stay. The National Committee on Vital and Health Statistics reported that about 23,000 hospital patients die annually from injuries linked specifically to the use of medications.

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The Joint Commission and the Leapfrog Group

In addition, the Joint Commission and the Leapfrog Group, a consortium of large employers, have pushed patient safety as a high priority and hospitals are following suit. The Leapfrog Group in particular highlighted CPOE systems as one of the changes that would most improve patient safety.  These patient safety initiatives have further advanced CPOE systems, since these systems have the reduction of medical errors as a prime function.  State and federal legislatures have also stepped up activity in this regard.

For example, back in July 2004, the federal government strongly advocated for electronic medical records, including the creation of the Office of the National Coordinator for Health Information Technology to develop a National Health Information Network. Consequently, regional health information organizations have been established in many states, and these are used for the purpose of expediting the sharing and exchange of healthcare data and information, although there still remain issues in terms of providing adequate funding to these programs.

In addition, consideration was given to the allocation of grants and low-interest loans to aid hospitals in implementing healthcare technology solutions.  In 2000, California first enacted legislation (Senate Bill 1875) stating that as a condition of licensure, acute care hospitals, with the exception of small and rural hospitals, submit plans to implement technological solutions (such as CPOE systems) to substantially reduce medication-related errors by January 1, 2002. Hospitals in California had until January 1, 2005, to actually implement their medication error-reduction plans and make them operational. Unfortunately, many are still not in compliance today.

Health plans also entered the patient safety stage. In 2002, one large health plan in the northeast provided a 4% bonus to hospitals implementing a CPOE system and staffing intensive care units (ICUs) with “intensivists.” Today, this goal is almost the norm, but not yet reality for all.

More than Data Retrieval 

Many hospitals have “data retrieval” systems where a provider on the wards can obtain lab results and other information. A CPOE system, however, allows entry of data from the wards and is usually coupled with a “decision support” module that does just that — supports the provider in making decisions that maximize care quality and/or cost effectiveness.

In this application of HIT, physicians and possibly other providers enter hospital orders directly into the computer. Many vendors of such systems make special efforts to create an intuitive and user-friendly interface, with a variable range of customization possibilities. The physicians can enter orders either on a workstation on the ward or in some cases at the bedside.

Features of a True CPOE System

Basic features of CPOE should include the following:

  • Medication analysis system — A medication analysis program usually accompanies the order entry system. In such cases, either after order entry or interactively, the system checks for potential problems such as drug-drug interactions, duplicate orders, drug allergies and hypersensitivities, and dosage miscalculations. More sophisticated systems may also check for drug interactions with co-morbidities (e.g., psychiatric drugs that may increase blood pressure in a depressed patient with hypertension), drug-lab interactions (e.g., labs pointing to renal impairment that may adversely affect drug levels), and suggestions to use drugs with the same therapeutic effect but lower cost. Naturally, physicians have the option to decline the alerts and continue with the order. In fact, if there are alerts that providers are frequently overriding, providers will often provide feedback that can lead to modification of the alert paradigms. Encouraging feedback increases the robustness of the CPOE system and facilitates continuous quality improvement.
  • Order clarity — Reading the handwriting of providers is a legendary problem. Although many providers do perfectly well with legibility, other providers have difficulty due to being rushed, stressed, or due to trait factors. Since the orders are accessible directly on the workstation screen or from the printer, time is saved on callbacks to decipher illegible orders as well as preventing possible errors in order translation. A study in 1986 by Georgetown University Hospital (Washington, D.C.) noted that 16% of all manual medical records are illegible. Clarifying these orders takes professional time, and resources are spent duplicating the data; thus, real cost savings can be realized through the elimination of these processes.
  • Increased work efficiency — Instantaneous electronic transmittal of orders to radiology, laboratory, pharmacy, consulting services, or other departments replaces corresponding manual tasks. This increase in efficiency from a CPOE system has significant returns. In one hospital in the southeast, the time taken between drug order submission and receipt by the pharmacy was shortened from 96 minutes (using paper) to 3 minutes. Such an increase in efficiency can save labor costs and lead to earlier discharge of patients. The same hospital noted a 72% reduction in medication error rates during a three-month period after the system was implemented. Alerting providers to duplicate lab orders further saves costs from more efficient work processes. And, in another instance, the time from writing admission orders to execution of the orders decreased from about six hours to 30 minutes, underscoring CPOE system utility in making work processes more efficient; thus positively affecting the bottom line.

Assessment

In today’s environment of high expectations for care quality and pay-for-performance initiatives, enhanced quality of care can translate into financial gain. Although there is a significant up-front allocation of funds for CPOE systems, given present trends the time may arrive where there is no longer a choice but to implement such a system.

Conclusion

Although a Computerized Physician Order Entry system alone will reap significant benefits if intelligently implemented, in order to realize the greatest benefit a CPOE system should be rolled up into a fully functioning EMR system where feasible.

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Some Dental Consultants Say the Most Incredible Things

Are Dentists like … Rodney Dangerfield? 

By Darrell Kellus Pruitt; DDS

“Let’s face it — in our world dentists do not get the respect they deserve. They are not perceived to be ‘real’ doctors … Perhaps the lack of sex appeal in dentistry is part of why dental coverage for everyone is an afterthought in the national health care conversation.”

Gary Kadi DDS, DentistryiQ

http://www.dentaleconomics.com/index/display/article-display/4196579430/articles/dental-economics/volume-100/issue-5/features/the-cavity_in_the.html

Even if Dr. Kadi is correct, and the barrier between a 12 year old and his toothbrush is a world-wide lack of respect of dentistry, that hardly means that electronic dental records (eDR) are going to make the kid brush any better. Experience tells me that if mom’s nagging won’t motivate the stinker, the computer won’t either.

eDR Rationalization?

For those who read the article, did you notice how Dr. Kadi, a dental practice consultant, attempts to subtly insert a fat rationalization for adopting eDRs into the middle of a comment lamenting dentistry’s lack of respect? Tricks like Kadi’s make stakeholders look silly at times, and it bothers me that hardly anyone notices and appreciates the humor that these pros bring to marketplace conversation. That’s why I like to point out mistakes like Kadi’s when I come across them. It’s getting harder to find these kinds of articles about eDRs. My pleasure!

Working Both Sides of the Consulting Fence

As far as I can tell, all but a few dental consultants work both sides of the fence in order to please vendors who give them good deals, as well as dentists who pay for unbiased help. Sponsorship by vendors is the bottom level of a consultant career if one chooses to make a living at selling advice. In this way, the dental consultant business is a lot like the financial advice business. Some advisors push their favorite investments that serve them well no matter what happens to their clients’ money. If a client wants advice, but prefers not to pay full price, interested vendors can be counted on to quietly chip in on an advisor’s bill. And that is why the customer must always be cynical. What’s more, it is arguably one’s community obligation to publicly challenge such artists by luring them out into the open to explain further what they meant to say to naïve people. Dr. Kadi begins:

“The national health-care debate cannot be complete unless we include dental care as part of the discourse.”

He then presents oft-repeated, convincing findings which support the widely held conclusion that one’s overall health is dependent on one’s oral health. Even though this chunk of common sense has recently been supported with well-respected research, the news isn’t a revelation. Other stakeholders have proclaimed the findings as an example of ultra-modern “Evidence-Based Dentistry,” and proof of the need for thousands of their dental products. However, let’s not kid ourselves. A healthy mouth has less to do with computerization than the proper application of a low-tech toothbrush. 10,000 years ago, even buzzards recognized that bad breath from advanced gum disease smells like imminent death from a long way off if the wind is right. The results Dr. Kadi leans his reasons against only confirm traditional Evidence-Based Superstition.

eDR Lobbying 

By half-way through the article Dr. Kadi turned “The cavity in the health-care debate” into a PR piece for eDRs. He’s in so deep that he cannot recognize that his misplaced concerns about image have nothing to do with dental patients’ oral health. Image is only cosmetic.

“A validation [of bringing “sex appeal” to the profession] is the inclusion of dentistry in the recently mandated National Healthcare Information Infrastructure (NHII). The purpose of the NHII is to create an information network to facilitate the creation of an electric health record [eHR] for all aspects of health care. The primary impetus is to achieve interoperability of health information technologies used in the mainstream delivery of health care.”

Note: Dr. Kadi admits that the goal is HIT, and sharing health information is the tool – not the other way around. As anyone can see, that kind of nonsense will never work out well in the US. Why that would be as foolish as stuffing a certifying commission for eHRs with industry, government and academic leaders rather than providers – and then tossing billions of dollars that could otherwise be used for treating disease out in the street for the biggest and fastest stakeholders who grab the most. That would be simply ridiculous.

Dr. Kadi bravely continues: “This will enable an individual’s health care information to be shared by all the necessary health care parties in a secure manner, including dentistry. It will improve patient care and reduce the number of patients, currently 100,000 plus, who die each year due to a lack of accurate, complete, or timely information. The federal government estimates a cost savings of $85 billion to $100 billion per year with electronic health records [eHR].”

Is HIT – Or any IT – Really Secure? 

In a secure manner – really? There are so many other misleading statements in this paragraph as well. First of all, how can an eDR improve a dentist’s chance of successfully extracting a molar in one piece? It can’t. Secondly, how many of the alleged 100,000 victims died because of lack of electronic DENTAL records? Third, how many patients will die because of faulty information in interoperable records that would not have occurred if the records were paper? Fourth, to insinuate that patient information can only be shared over the Internet is plain silly. Telephone, fax and the US mail have been sufficient for dentistry for decades, and none involve HIPAA. Finally, the $85 to $100 billion in savings Dr. Kadi casually throws out is based on a five year old Rand study that’s been widely trashed for being biased in favor of the stakeholders who funded the research. That happens. It just amazes me that anyone in the healthcare industry who knows anything about HIT is foolish enough to still shop discarded garbage. And once again, regardless of the success of electronic medical records, how will eDRs save even $10 in dentistry? It’s impossible without re-defining “savings.”

Cost Savings

“Dentists and hygienists will play a vital role in this cost savings because people who go for regular cleanings will have their medical history updated in the shared system during each visit. In some cases, dental cleanings may be the only medical attention a person receives yearly.”

“Cost savings”? Where have I heard that term? And why didn’t Dr. Kadi simply say “savings”?

Now I remember. It was Dr. Robert Ahlstrom, the ADA’s eDR expert, who coined the handy buzzword in his testimony describing the benefits of paperless dental practices for the US Department of Health and Human Services in July of 2007. “Cost savings to providers and plans will translate in less costly health care for consumers. Premiums and charges will be lowered.” That would be the seventh of his 11 reasons that are each one so lame that other than Dr. Kadi, stakeholders never borrow them. Although it is undeniable that electronic records benefit insurers and the government more than the patient, if Ahlstrom hadn’t been coy, and had clearly stated that eDRs will save money in dentistry, his testimony would have been false. By calling it a “cost savings,” Ahlstrom technically concedes that using eDRs will indeed require an increase in cost of overhead – which dental patients will ultimately have to pay to obtain dental care. The saving part comes from “what could have been.” Whatever that could possibly mean, HHS Secretary Michael Leavitt bought it.

The PennWell Article

Because of a situation beyond my control, I am unable to provide a link, but to find more of my opinion of Ahlstrom’s testimony that is still used by lawmakers to establish national policy, simply google “Dr. Robert Ahlstrom.” My PennWell article from a year ago or so, “Dr. Robert H. Ahlstrom’s controversial HIPAA testimony,” is probably still his first hit. It could be on his first page the rest of his life.

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Assessment

If necessary, I’ll make a few more examples of insensitive HIT stakeholders who know better than to offer such crap to the nation’s lawmakers as well as providers who are too busy to pay attention to the welfare of their profession. The ADA should reassure the nation that there are cheap, effective low-tech ways dental patients can stay healthy that don’t risk their identities and won’t bankrupt a dental practice because of a stolen computer. But; they won’t do it.

Conclusion

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