The Role of MD/DOs in BIOLOGICAL and CHEMICAL Attacks

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Is there REALLY a Role … at all?

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By Dr. David Edward Marcinko MBA 

Title X of the USA PATRIOT Act contains several calls for strengthening the public health system. Section 1013(a)(4) calls for “enhanced resources for public health officials to respond to potential bioterrorism attacks.” Section 1013(a)(6) calls for “greater resources to increase the capacity of hospitals and local healthcare workers to respond to public health threats.”

PRE 9/11

Prior to September 11, 2001, the capacity of healthcare entities to respond to biological and chemical attacks by terrorists was quite limited. Strictly speaking, however, healthcare organizational preparedness plans are not as directly encumbered by the USA PATRIOT ACT, or by the Department of Homeland Security’s (DHS’s) Chemicals of Concern [COC] List, or the various steps of its Section 550 Program as some other industries. Nevertheless, healthcare organizations may have their sources of contaminants, such as: Mercury, Dioxin: DEHP (2-ethylhexyl), Volatile Organic Compounds and Glutaraldehyde, etc.

For some time now, the Joint Commission (formerly the Joint Commission on Accreditation of Healthcare Organizations) has also required hospitals to have a disaster preparedness plan mimicking the USA PATRIOT Act [personal communication, Kenneth A. Powers, Media Relations Manager, TJC].

Post 9/11

After September 11, 2001, “disaster preparedness” evolved into something that could more accurately be described as “emergency preparedness.” Experience in New York and Virginia has shown that there will be spillover outside the immediate geographic areas affected by a terrorist attack, which will affect suburban and rural hospitals.

Thus, the emphasis in emergency preparedness is on the coordination and integration of organizations throughout the local system. Hospitals and healthcare entities therefore need to revise existing plans for disaster preparedness to reflect the realities of potential terrorist threats. Mitigation against risk is essential to safeguard the financial position of an entity. Medical practices and healthcare entities can mitigate risks by developing an emergency preparedness plan.

The entity should start by identifying possible disaster situations, such as earthquakes and biological or chemical attacks that could affect the facility. Next, the entity should identify the potential damages that could occur to structures, utilities, computer technology, and supplies. After that, the entity should use resources currently available to safeguard assets, and then budget to acquire any additional materials or alterations required to secure the facility.

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Practices can take several steps to mitigate even in the absence of significant funding:

  • First, establish links with ‘first responders’ such as local law enforcement, fire departments, state and local government, other healthcare organizations, emergency medical services, and local public health departments.
  • Second, establish training programs to educate staff on how to deal with chemical and biological threats.
  • Third, make changes in their information technology to facilitate disease surveillance that might give warning that an attack has occurred. Information technology may be useful in identifying the occurrence syndromes such as headache or fevers that might not be noticed individually but in the aggregate would signal that a biological or chemical agent had been released.
  • Fourth, acquire access to staff and equipment to respond to biological and chemical attack through resource sharing arrangements in lieu of outright purchases.”

In addition to preparedness for an attack within its catchment area, a healthcare organization must be prepared for an attack on its own facility or office. They should assess the vulnerability of the heating, ventilation, and air conditioning (HVAC) systems to biological or chemical attack. The positioning of the air intake vents is especially important because intakes on roofs are fairly secure as compared to intakes on ground level.

One way to increase security is to restrict access to the facility. Some facilities are using biometric screening to restrict access to their facilities. Biometric screening identifies people based on measurements of some body part such as a fingerprint, handprint, or retina. The advantage of this approach is that there are no problems with forgotten badges, and biometric features cannot be shared or lost like cards with personal identification numbers (PINs).

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Assessment

In preparing for a possible attack, healthcare entities should also examine the federal, state, and local laws that might affect their response to a biological or chemical attack.

And so, is there really a roll; at all?

Unfortunately, there is no central source of legislation, and an extensive search of many sources might be required to determine the legal constraints.

Conclusion

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Inviting Debate with eDR Stakeholders

An ME-P Exclusive – Almost

By D. Kellus Pruitt DDS

I really, really love being provocative in my neighborhood that I know so well. It just doesn’t seem fair. In fact, for five years, I’ve watched the electronic dental record [eDR] market very closely, and I tell you, something big is moving under the radar. If you recall, in the last couple of weeks I brought your attention to unexplained interest blips appearing on the Medical Executive-Post www.MedicalExecutivePost.com concerning eDRs. I suggested that Internet interest in the topic following years of silence from even the ADA, could be a sign that important news about electronic health records in dentistry may be breaking soon.

CCHIT Seeking Comments 

Just a couple of hours ago, Andis Robeznieks posted “CCHIT seeks comments on specialized EHRs” on ModernHealthcare.com.

http://www.modernhealthcare.com/article/20101119/NEWS/311199996/#

Robeznieks writes: “The Certification Commission for Health Information Technology has opened a public comment period for its proposed oncology and women’s-health electronic health-record certification criteria and test scripts. The comment period will end December 10th at 5 pm CT.”

Meaningful Dental Use 

Is it possible that following the establishment of “meaningful use” guidelines for these specialists, dentistry could be next in line? The nature of the approaching bolus of news concerning eDRs is pure speculation, but rest assured I’ll be right in the middle of it – which brings me to the next sign that eDR stakeholders are getting restless: An almost unheard of conversation about eDRs appeared today on the Internet. Since the only news about eDRs on the Internet are press releases from Dentrix – the largest vendor in the nation – conversations about value of electronic dental records only rarely break out. But, when they appear, I always try my best to be provocative – just to tease out new rationalizations I might have otherwise missed.

I think I found promising opportunity this morning following an article by “John” titled, “EMR Stimulus Q and A: EMR Stimulus Money and Dentists.” It was posted yesterday on the EMR and HIPAA blog.

http://www.emrandhipaa.com/emr-and-hipaa/2010/11/18/emr-stimulus-q-and-a-emr-stimulus-money-and-dentists/comment-page-1/#comment-126257

My Comments

I’ve looked into whether stimulus money will be available to dentists. Many in your audience won’t like it, but here’s your answer: 

Dentists will not receive any ARRA stimulus to help pay for electronic dental records – even if a practice is 30% Medicaid as required. For one thing, it’s already too late to collect on the biggest portion of our grandchildren’s money unless the practice can prove utilization of an ONC-certified eDR in a “meaningful” way by this time next year. And, that’s simply impossible because there are no ONC-certified eDRs, and meaningful use has still not been defined by HHS – with help from the ADA. Eventually, someone from the ADA will either have to promote computer busywork as meaningful use, or concede that meaningful use of eHRs in dentistry simply does not exist.

Example

For example, do you want to log on to a password-protected, HIPAA-compliant computer just to notify the lab that you have a pick-up? For dental practices, speed-dial on the telephone – or fax machine – is much more meaningful, and neither requires the dentist to be a HIPAA-covered entity. In addition, none of the conventional ways of communicating put patients’ identities at risk like digital records on a stolen or hacked computer. That’s Hippocratic meaningful.

Digital Drawbacks 

Here’s another drawback to digitalization: Even though electronic dental records are cutting-edge cool, they have yet to show a return on investment for dental practices, and data breaches will continue to make them more and more expensive. Without ROI, paperless is a hobby paid for by clueless patients in higher fees. Bet you haven’t heard that chunk of honesty very often. Honesty about hi-tech non-solutions is repressed even in the ADA because it is so politically incorrect to admit that our dental leaders who misled members were misled themselves by HIT stakeholders and Newt Gingrich. It’s really difficult for high officials inside and outside dentistry to stand up and say, “Oops! We were wrong.”

See: “Is ARRA Stimulus Money for Dentists?”

https://medicalexecutivepost.com/2010/11/16/is-arra-stimulus-money-for-dentists/

Assessment

I happened to post the article on the Medical Executive-Post two days before John’s article was posted here on the EMR and HIPAA forum. I invite you to read it, and tell me what you think. Other than here, nobody talks about these issues. That can’t be good for dental patients.

Conclusion

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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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More about Healthcare Organizations [Financial Management Strategies]

Our Print-Journal Preface

By Hope Rachel Hetico; RN, MHA, CMP™hetico1

As Managing Editor of a two volume – 1,200 pages – premium quarterly print journal, I am often asked about our Preface.

A Two-Volume Guide

As so, our hope is that Healthcare Organizations: [Financial Management Strategies] will shape the hospital management landscape by following three important principles.

What it is – How it works

1. First, we have assembled a world-class editorial advisory board and independent team of contributors and asked them to draw on their experience in economic thought leadership and managerial decision making in the healthcare industrial complex. Like many readers, each struggles mightily with the decreasing revenues, increasing costs, and high consumer expectations in today’s competitive healthcare marketplace. Yet, their practical experience and applied operating vision is a source of objective information, informed opinion, and crucial information for this manual and its quarterly updates.

2. Second, our writing style allows us to condense a great deal of information into each quarterly issue.  We integrate prose, applications and regulatory perspectives with real-world case models, as well as charts, tables, diagrams, sample contracts, and checklists.  The result is a comprehensive oeuvre of financial management and operation strategies, vital to all healthcare facility administrators, comptrollers, physician-executives, and consulting business advisors.

3. Third, as editors, we prefer engaged readers who demand compelling content. According to conventional wisdom, printed manuals like this one should be a relic of the past, from an era before instant messaging and high-speed connectivity. Our experience shows just the opposite.  Applied healthcare economics and management literature has grown exponentially in the past decade and the plethora of Internet information makes updates that sort through the clutter and provide strategic analysis all the more valuable. Oh, it should provide some personality and wit, too! Don’t forget, beneath the spreadsheets, profit and loss statements, and financial models are patients, colleagues and investors who depend on you.ho-journal9

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Assessment

Rest assured, Healthcare Organizations: [Financial Management Strategies] will become an important peer-reviewed vehicle for the advancement of working knowledge and the dissemination of research information and best practices in our field. In the years ahead, we trust these principles will enhance utility and add value to your subscription. Most importantly, we hope to increase your return on investment [ROI] in some small increment.

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Conclusion

And so, your thoughts and comments on this Medical Executive-Post, complimentary e-companion are appreciated. If you would like to contribute material or suggest topics for a future update, please contact me. Subscribers, have we attained our goals and objectives, as a work-in-progress in this preface statement?

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