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    Dr. David E. Marcinko is past Editor-in-Chief of the prestigious “Journal of Health Care Finance”, and a former Certified Financial Planner® who was named “Health Economist of the Year” in 2010. He is a Federal and State court approved expert witness featured in hundreds of peer reviewed medical, business, economics trade journals and publications [AMA, ADA, APMA, AAOS, Physicians Practice, Investment Advisor, Physician’s Money Digest and MD News] etc.

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    As a state licensed life, P&C and health insurance agent; and dual SEC registered investment advisor and representative, Marcinko was Founding Dean of the fiduciary and niche focused CERTIFIED MEDICAL PLANNER® chartered professional designation education program; as well as Chief Editor of the three print format HEALTH DICTIONARY SERIES® and online Wiki Project.

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Clarifying Some NPI Number Mis-Understandings

The NPI Number: What is is – How it works?

By Carol S. Miller RN, MBA

The National Provider Identifier (NPI) is a HIPAA Administrative Simplification Standard that provides a unique identification for covered health care providers, all health plans and health care clearinghouses.  The NPI must be used in administrative and financial transactions adopted under HIPAA and with one identifying number will simplify security and allow greater protection or encryption of the provider number.  The NPI can be used to identify the health care provider on prescriptions, COB between health care plans, inpatient medical record systems, program integrity files, and other areas.

Dependent on his/her medical practice, the provider can obtain an individual or group NPI; however, there are situations where an individual NPI number is required such as with the submission of pharmacy and lab claims.  The NPI remains with the provider regardless of job or location change.  NPI will eventually be the standard identifier for all e-prescribing under Medicare Part D.

A Ten Digit Number

The NPI is a ten digit, intelligence-free numeric identifier with a check digit in the last position to help detect keying errors.  If there is a security breach, the number in itself cannot identify the protected health organization.  The use of one identifier with a check digit simplifies encryption of this number when transmitted electronically and thereby enhances security.

On HIPPA

HIPAA also requires that employers have standard national numbers that identify them on standard transactions.  The Employer Identification Number (EIN), issued by the Internal Revenue Service (IRS) was selected as the identifier for employers.  This number is used as a Federal tax identification number for the means of identifying any business entity and for the purpose of reporting employment taxes.  The EIN number should be protected as a social security number is.

ITL and NIST

Both the Information Technology Laboratory (ITL) and the National Institute of Standards and Technology (NIST) are involved in the development of technical, physical, administrative, and management standards and guidelines for cost-effective security and privacy of sensitive unclassified information in federal computer systems.  These standards and guidelines can be applied to the management of medical IT.

Assessment

Additional reference material for NPI can be found at: www.cms.gov/nationalprovidentstand.

Conclusion

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“Meaningful Use” for Ambulatory Care Medical Practices

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EHR Objectives and Measures

By Shahid N. Shah MS  

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.

Fear and Promises

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 an up-to-date problem list of current and active diagnoses 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 with an electronic copy of their discharge instructions at time of discharge, upon request.
  13. Capability to exchange key clinical information among providers of care and patient-authorized entities electronically.
  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 or 9). Drug-formulary checks.

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

Government Agencies and Participants Involved in MU

As you can see in the Figure, 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.

Figure Link: Figure 

* 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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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

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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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.

Conclusion

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.

Speaker: If you need a moderator or speaker for an upcoming event, Dr. David E. Marcinko; MBA – Publisher-in-Chief of the Medical Executive-Post – is available for seminar or speaking engagements. Contact: MarcinkoAdvisors@msn.com

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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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