Certification Programs NPRM (Notice of Proposed Rulemaking)

Health IT, U. S. Department of Health and Human Services; March 2, 2010

Certification NPRM

Facts-At-A-Glance

FAQ

Bookmarked version of Certification NPRM (much easier to navigate)

U. S. Department of Health and Human Services; March 2, 2010

Via OCCAM Practice Management blog, March 3, 2010

Commentary and Analysis

Proposed EHR Certification Rule Changes Game

HDM Breaking News; March 2, 2010

“The rule mentions the Certification Commission for Health Information Technology, but does not grant it any grandfather status…. So, while CCHIT appears to be able to continue its operations under the proposed temporary certification program, its future isn’t clear in the proposed permanent program.”

Certification NPRM: A Statement from Alisa Ray, Executive Director, Certification Commission for Health Information Technology (CCHIT)

EHR Decisions; March 3, 2010

“…we feel confident about our prospects of becoming accredited…. We feel confident about the future, and we look forward to the opportunity to continue playing a role in accelerating the adoption of health IT.

 Why Rush Vendor Certification of EHR Technologies?

The Health Care Blog; March 08, 2010

“David Blumenthal and his staff have unveiled two separate plans to test and certify EHR technology products and services. We don’t think this is a good idea…this recently-announced two-stage EHR technology certification plan bears all the marks of a hastily drawn up blueprint that, if rushed into production, could easily collapse of its own bureaucratic weight.”

HIT Leaders React to Proposed EHR Testing and Compliance Rule

HealthLeaders Media; March 4, 2010

• “They got it exactly right.” Simeon Schwartz, MD, president and CEO of WestMed Medical Group.
• “It’s going to be interesting to see how much the vendors got out ahead of this and how much they’ve hedged their bets” Eric Saff, CIO of John Muir Health
• “…no matter where you are in the chain of this market, you can in fact certify those modules as opposed to waiting until you meet complete meaningful use to be certified. So I think that’s great. I think that’s really considerate of the ONC.” Luigi Leblanc of Solink

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However…I can’t help but comment on John’s misleading story “CCD Standard Gaining Traction, CCR Fading” in The Health Care Blog. He writes:

In a number of interviews with leading HIE [Health Information Exchange] vendors, it is becoming clear that the clinical standard, Continuity of Care Document (CCD) will be the dominant standard in the future.  The leading competing standard, Continuity of Care Record (CCR) appears to be fading with one vendor stating that virtually no client is asking for CCR today.

I have four beefs with John’s essay:

1. It’s no news that HIEs prefer CCD.
2. HIEs are not representative of the broader health IT market.
3. The narrow findings don’t justify the broad conclusion.
4. The CCD and CCR standards are more complementary than competitive

Let’s look at these one at a time.

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“If the needs for health care are to be met, the health care system must be organized to employ its resources with more wisdom and effectiveness. The two areas which appear to offer the greatest potential for improvement are (1) reducing unnecessary (or unnecessarily expensive) medical care and (2) increasing efficiency in the provision of hospital care.”

It will not be easy to carry out this recommendation.

Who said this? …and when? (more…)

I’d describe the app as Garmin-like but running on the iPhone. You type in the address at which you’re going to start your drive and then you type in the address of the location where you want to drive to. The iPhone displays a map and step-by-step directions. Want to zoom in on a section of the map? …just put your fingers on the screen, spread them, and instantly you see the map in greater detail. The app uses the GPS built into the iPhone to display your current location and progress on the map.

A few years ago you would have had to purchase a separate Garmin or Garmin-like appliance to get this type of functionality. Is this iPhone app as good as the Garmin? For many people, the answer might well be “No”, but that’s not the point.  For many people the iPhone app WILL be good enough — and having that choice is what creates a vibrant marketplace.

So what does this have to do with health care? A lot.

To date, health care has not had an iPhone like platform on which to run multiple high value applications. If you wanted specific functionality, you had to buy an independent appliance. For more on the appliance vs. platform distinction, start reading at Chapter 2 of Harvard Law Prof. Jonathan Zittrain’s excellent (and freely available) book, The Future of the Internet and How to Avoid It.

If you rethink health care, just about ANY technology or service can be reconceptualized as an app that COULD run on a common platform. Mull this over for a while…

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Thank you for being a loyal user of the Revolution Health Personal Health Record. Unfortunately we will be discontinuing this service as of the end of February 2010 and removing all records, information, and data from the Revolution Health Web site.

So that you don’t lose the information you’ve entered into the system, we strongly suggest that you download your personal records as a PDF to print and save for future reference. To do this, simply follow these instructions:

1. Log in to your Personal Health Record.
2. From any page of your record, click on the “printable version” link on the top right corner of any page. When you see a pop-up box asking you to “Select the following sections to include in your print out,” simply make sure that the sections you want to print and save are checked and then click the “Submit” button.
3. Once the PDF is created (this only takes a moment), you can print directly from it and/or save it to your computer. To print the PDF, click on the printer icon at the top left of the page. To save it, click on the disk icon to the right of the printer icon.

If you encounter a problem printing or saving your records, please e-mail our customer service department at CustomerCare@revolutionhealth.com for assistance. Even after the Personal Health Record is no longer available, Revolution Health and our partner sites will continue to offer you the same great health information and community pages as always. We hope you continue to visit Revolution Health often to take advantage of our offerings.

Thank you,
The Revolution Health Team

What happened here????  what’s the lesson?

“So Mom, are you learning to talk like a pirate? …like ‘aye, matey’”?

“I baby?” she asked.

“No, aye matey’”

“I-80?”

“…er, never mind Mom…how’s Benji?”

Vince’s mom (sans eyepatch) and Benji

Descriptive Summaries and Documents

 *Dissecting the Meaningful Use Proposed Rule PowerPoint

eHealth Initiative Policy Webinar; January 8, 2010

*What You Need to Know About the Meaningful Use Proposed Rule, Standards and Implementation Specification, and Interim Final Rule Certification Criteria PowerPoint

HIMSS Webinar; January 6, 2010

*Meaningful Use, Certification Criteria and Standards, and HHS Certification Process

HIMSS, frequently updated material, some members-only

Source Documents (Bookmarked)

Notice of Proposed Rulemaking (NPRM), Medicare and Medicaid Programs; Electronic Health Record Incentive Program; December 30, 2009

Warning: 536 pages of barely intelligible gobbledygook; stay away from this unless you are a lawyer, accountant, actuary, consultant, geek or wanna-be thereof 

Interim Federal Rule (IFR), HIT: Initial Set of Standards, Implementation Specifications, and Certification Criteria For EHR Technology; December 30, 2009

NPRM and IFR Tables in Spreadsheet Format

Healthcare Standards; January 9, 2009

Centers for Medicare & Medicaid Services (CMS) Website, Fact Sheets, Links

Updates on Meaningful Use, Certified EHR Technology and the Stimulus Bill

Software Advice; January 10, 2010

Analyses

*Urgently Needed: Useful Meaning of Meaningful Use

The Health Care Blog; January 9, 2009

*Now Reading: Proposed CMS Rule for EHR Incentives (from a patient access perspective)

Ted Eytan MD; January 10, 2010

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Gawande retorts: “Is that a bad thing?”

…and he answers his own question by describing the value of pilot programs contained in both the Senate and House versions of health reform legislation.

Is Gawande correct?  Yes and no….

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by Alexandra Drane and the Engage With Grace team

Last Thanksgiving weekend, many of us bloggers participated in the first documented blog rally to promote Engage With Grace — a movement aimed at having all of us understand and communicate our end-of-life wishes. It was a great success, with over 100 bloggers in the healthcare space and beyond participating and spreading the word. Plus, it was timed to coincide with a weekend when most of us are with the very people with whom we should be having these tough conversations our closest friends and family. Our original mission to get more and more people talking about their end of life wishes hasn’t changed. But it’s been quite a year so we thought this holiday, we’d try something different.

A bit of levity.

At the heart of Engage With Grace are five questions designed to get the conversation started. We?ve included them at the end of this post. They’re not easy questions, but they are important. To help ease us into these tough questions, and in the spirit of the season, we thought we’d start with five parallel questions that ARE pretty easy to answer:  (more…)

Medicare announced today that it is extending its Personal Health Record (PHR) pilot project for residents of Utah and Arizona.

This is a waste of time and taxpayer dollars. Those of you who read my blog know that I’m a big fan of PHRs, but you have to know when you’re backing the wrong approach.

What’s wrong with this pilot project? A lot:

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• Keep it simple; think big, but start small; recommend standards as minimal as possible to support the business goal and then build as you go
• Don’t let “perfect” be the enemy of “good enough”; go for the 80% that everyone can agree on; get everyone to send the basics (medications, problem list, allergies, labs) before focusing on the more obscure
• Keep the implementation cost as low as possible; eliminate any royalties or other expenses associated with the use of standards
• Design for the little guy so that all participants can adopt the standard and not just the best resourced
• Do not try to create a one size fits all standard, it will be too heavy for the simple use cases
• Separate content standards from transmission standards; i.e., if CCD is the html, what is the https?
• Create publicly available controlled vocabularies & code sets that are easily accessible / downloadable
• Leverage the web for transport whenever possible to decrease complexity & the implementers’ learning curve (“health internet”)
• Position quality measures so that they will encourage adoption of standards
• Create Implementation Guides that are human readable, have working examples, and include testing tools

Commentary:  These new guidelines are the right answer…let’s hope they are Dr. Halamka’s “final” answer.

Feedback from the community has been mixed:

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In that post I touched briefly on the potential for MAPCI to create effective networks at multiple levels — contracting networks, health IT networks, social and collaborative care networks.  I’d like to expand a bit today…

So, why is Medicare’s participation in MAPCI  and other regional collaboratives such a big deal? Here’s my hypothesis:

Medicare’s non-participation (to-date) in regional payer/provider collaboratives has been a rate limiting factor in the potential to achieve high levels of network effects that drive adoption.

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Dear Dr. Blumenthal,

I was honored to receive a personal email from you today. However, after reading it, I conclude that you must have intended to send this email to Judith Faulkner, CEO of Epic Systems.

I really liked what you said about working toward interoperability:

The HITECH Act calls for the “development of a nationwide health information technology infrastructure that allows for the electronic use and exchange of information and that…promotes a more effective marketplace, greater competition…[and] increased consumer choice” among other goals.  (Section 3001(b))  This means we cannot support arrangements that restrict the secure, private exchange of information required for patient care across provider or network boundaries.  Some of these arrangements may improve care for those inside their walls.  But ultimately, they have the potential to carve the nation up into disconnected silos of information, and thus, to undermine the vision of a secure, interoperable, nationwide health information infrastructure, which the law requires us to establish.  Consumers, patients and their caretakers should never feel locked into a single health system or exchange arrangement because it does not permit or encourage the sharing of information.

So you will probably just need to resend your email…

Vince

Why aren’t primary care physicians expressing similar laments about  the shelving of the MMHD (Medicare Medical Home Demonstration) in favor of the MAPCI (Multi-Payer Advanced Primary Care Initiative).

My colleague Jaan Sidorov, MD and I pick up on no signs of discontent.  Read our essay “Three Years of Medical Home Demonstration Preparation Down the Drain?” on Dr. Sidorov’s blog.

Dr. John Halamka — Vice Chair of the HIT Standards Committee of the ONC and one of the most vocal and influential figures in health IT — writes a blog post this morning entitled “The Genius of AND”. Halamka reasonably summarizes the essence of the debate about standards and interoperability as being between “the healthcare informatics crowd” (cats) and the “Internet crowd” (dogs):

He notes that the debate shouldn’t be about one or the other POV prevailing (“either/or”), but about integrating both points of view (“and”):

..we need to embrace both approaches – the right tool for the right job depending on what you want to achieve.

For provider to provider communication which requires the exchange of documents with non-repudiation as the medico-legal record for direct clinical care, the CDA/CCD has great metadata and the ability to support structured data as well as free text discharge summaries/operative notes/history&physicals.

For a summary record that represents a snapshot in time of problems, medications, and labs for transmission between EHRs and PHRs, the CCR and other formats such as Google’s CCRg or PDF can do the job.

I’m absolutely stunned…and speechless.

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Today’s blog post will tackle:

• Medicare’s biggest change in 40 years?
• The rise of MAPCI
• The fall of MMHD
• Implications/discussion

Medicare’s Biggest Change in 40 Years?

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Tinker Ready hosts the Halloween edition of Health Wonk Review at Boston Health News.

Read about the “the undead public option” or as Jon Stewart said, “It’s alive!”

10/26/2009 – In Washington, the efforts to reform health care and health insurance include proposed legislative language that would have an impact on the Medicare Medical Home Demonstration as described in section 204 of the Tax Relief and Health Care Act of 2006 and amended by section 133 of the Medicare Improvements for Patients and Providers Act of 2008. Specifically, section 1302 of House Bill 3200 contains a provision to repeal this demonstration and replace it with an independent practitioner-based medical home pilot described further in the bill. In addition, the House bill includes a second medical home pilot to evaluate community-based medical home models.

At this time, CMS believes it would be impractical to pursue clearance of the Medicare Medical Home Demonstration, which has been under review at the Office of Management and Budget, given the pending legislation that would repeal it and replace it with a similar pilot. CMS is moving forward with an Administration-initiated demonstration announced by Secretary Sebelius on September 16, 2009, whereby Medicare would partner with existing multi-payer medical home pilots to improve the delivery of care. This demonstration, titled the Multi-Payer Advanced Primary Care Practice Demonstration, would be implemented in 2010.

What does this mean? As one who has followed the MMHD closely, here are some of my top-of-mind reactions:

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The letter is directed at 10 EMR (electronic medical record) vendors, and asks very pointed questions about whether the vendors have been negligent in not addressing patient safety issues in their technologies.

Senator Grassley, you have the scent and you’re on the trail.  There are several other questions you should be asking these vendors: (more…)

Compare the proportions that “users pay” for desktop Internet services vs. mobile Internet services (the area inside the red lines — click on the graphics to see larger versions).

What do these slides tell us?

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BrightTALK is sponsoring a complimentary Electronic Health Record Summit this Tuesday, October 20, 2009.

David C. Kibbe MD, MBA and I will be presenting “Introduction to Clinical Groupware and the Clinical Groupware Collaborative”

Clinical groupware is a new and evolving model for the development and deployment of health information technology (HIT) platforms and applications having the following characteristics:

• Use of the Internet and the web for EHR technology.
• Explicit design for information sharing and online communication among providers and patients/consumers.
• A modular or component architecture upon which applications can be aggregated to meet specific clinical and workflow tasks.
• Patient/consumer engagement tools that facilitate ongoing health management and care coordination.
• Interface and data exchange standards for information sharing that emerge in a market-driven manner.

The Clinical Groupware Collaborative is in a formative stage organization. To date, representatives from over 50 companies have expressed interest. We are working to be formally incorporated in November 2009.

To register, attend live, or view afterward on-demand, click the following link:  http://www.brighttalk.com/webcasts/6114/attend  

Here’s a full listing of the other Electronic Health Record Summit presentations:   

Kaiser Permanente’s Journey and Ultimate Success with Health IT, Andrew M. Wiesenthal, The Permanente Federation

Prescribing the Best Security for Your EHR System, Andrew Klein, Product Management at SonicWALL

Business Associates Now and Then: HIPAA, EHRs and the HITECH Act, Susan Miller, Security & Privacy Workgroup Chair, WEDI

Fraud & Abuse in the EHR, Jean Bishop, J Bishop Consulting

New HIPAA Rules and EHRs: ARRA & Breach Notification, Raj Goel, Brainlink International; Jim Sheldon-Dean, Lewis Creek Systems

Three Forcing Factors of Electronic Healthcare Records, Kim Singletary, McAfee

How Great EHRs Empower Participatory Medicine, e-Patient Dave deBronkart, Society for Participatory Medicine co-chair

How big a network will the Health Internet (aka National Health Information Network) be?

My BOTE (back-of-the-envelope) calculation is that this network could consist of about 301 million nodes.  Here’s my math (pls. clarify or amplify):

• 300 million individuals in U.S.
• 700 K doctors
• 5 K hospitals
• 295 K — other B2B healthcare entities

Very rough…but I hope you get the point.

So let’s put into perspective press releases from Google or Microsoft announcing that they have developed new “partnerships” (i.e.nodes in the network) for Google Health or Microsoft HealthVault. As an example, today Google announced partnerships with APWU Health Plan and Harvard Pilgrim Health Plan.

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ACOs of various types are being proposed in national health reform legislation. For all you ever wanted to know about ACOs, read How to Create Accountable Care Organizations from the Center for Healthcare Quality and Payment Reform.   I spent an hour and a half poring over the details of this excellent report written by Harold Miller.

My mistaken impression has been to focus on the organizational form of ACOs, rather than their objectives.  Organizational form is relevant in understanding ACOs, but primarily as a means toward creating accountability, not the end in itself.  Thus, expect to see many varying types of ACOs emerging based on local needs and characteristics.

I initially approached reading the report with a number of top-of-mind tactical and programmatic questions about ACOs:

• What kinds of organizations can serve as ACOs?
• What do primary care practices need to do differently to become ACOs?
• What’s the difference between a medical home and an ACO?
• Can small primary care practices become an ACO?
• Should all physicians in a geographic area be included in a single ACO?
• What is the role of specialists in an ACO?
• Should hospitals be part of an ACO?
• Are integrated delivery systems the ideal model?
• How many payers need to support an ACO?
• Accountability for all or some costs?

The answers to these questions are important, but primarily because they go to how an ACO can achieve accountability…

… and the short answer to every one of these questions is “It depends”. 

Depends on what?

To the maximum extent possible, an organization’s ability to serve as an Accountable Care Organization should be determined by its success in improving outcomes – controlling costs, improving quality, and providing a good experience for patients – not on its organizational structure or even the specific care processes it uses. 

Let me try to explain the big idea of accountability from a couple of other angles.

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Here’s a copy of our PowerPoint slides…

and here’s DMAA’s writeup:

Helping physicians and hospitals meet the “meaningful use” criteria for federal support for health information technology under recently passed legislation represents a keen opportunity for the population health management industry, presenters at this session said yesterday.

Vince Kuraitis, JD, MBA, of Better Health Technologies, LLC, and Don Storey, MD, of RMD Networks, presented a look at the evolution of HIT and the electronic medical records systems from a strongly proprietary model with little interoperability to new model of integrated, modular applications from various vendors sharing common languages and platforms.

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The part that’s puzzling to me is the statement that LifeMasters owes $125 M to CMS.  That’s hard to figure…the company only participated in MHS for a few months, and to my knowledge MHS is the only Medicare demo that required guaranteed savings (i.e., payback if targets aren’t hit).  

I really have to stretch my imagination to compute how CMS ran the tab to such an astronomical number. It raises questions around CMS’ good faith as a business “partner”.

Let’s do the math.

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I’m writing to extend a warm personal invitation to learn more about the Clinical Groupware Collaborative (CGC).  To-date, purely through word-of-mouth over 40 companies have expressed interest in the CGC, and we expect that you’ll be hearing a lot more about us over the coming months.

Our meeting will take place next Tuesday, September 22, 6 PM in conjunction with The Forum 09, the annual meeting of DMAA: The Care Continuum Alliance.  More details are provided at the bottom of this post.

I’ll address a few questions that might be on your mind.

Q. What is Clinical Groupware? 

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One bad deal can ruin your day.

Today, LifeMasters filed for Chapter 11 bankruptcy protection.  According to its press release:

“The Chapter 11 filing is the most efficient path for the company to restructure liabilities that are a result of Demonstration Projects previously performed under contracts with the Centers for Medicare and Medicaid Services (CMS), ” said George D. Pillari, President of LifeMasters. Mr. Pillari, named President of LifeMasters today, is a Managing Director of Alvarez & Marsal Healthcare Industry Group, LLC and had been working with the company and its board as a restructuring advisor prior to the filing.

During the last four years, LifeMasters participated in three CMS Demonstration Projects aimed at testing certain disease-management techniques in fee-for-service Medicare and Medicare/Medicaid dually eligible populations. Eight other disease management, health insurance and pharmaceutical companies also participated in these projects. LifeMasters’ involvement in the CMS projects ended earlier this year.

CMS contends that LifeMasters, like other participating organizations, was unable to demonstrate success based on CMS’ study design and measurement methodologies. Similar to its claims against other Demonstration Project contractors, CMS contends that LifeMasters is required to repay to CMS any fees earned in excess of savings generated during the multi-year projects. “Rather than endure a costly and time-consuming legal path to challenge CMS, we have chosen to restructure our CMS and other liabilities through the Chapter 11 process,” Mr. Pillari added.

LifeMasters expects no disruptions in its services to clients and believes it has ample cash on hand to emerge from Chapter 11 as a viable health improvement company.

A Modern Healthcare article contains a link to the bankruptcy filing:

• In one checkbox, the company estimates it has $10 to $50 million of assets
• In another checkbox, the company estimates it has $100 to $500 million of liabilities (to all creditors, not just CMS)
• It lists CMS as it’s largest creditor — $125 million

What happened? First let me acknowledge that I don’t have first-hand specifics of the current bankruptcy filing.  However, many bread crumbs have been dropped along the trail…

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Two issues have rightfully surfaced front and center in the public’s understanding of HITECH Act implementation:

• ” definition of “Meaningful Use” of EHRs, and
• ” definition of “certification” process for EHRs

…and we applaud the progress of the workgroups and the HIT Policy Committee in addressing these issues constructively.

However…a THIRD issue lurks – “Data harmonization at the expense of data liquidity“, or put another way – “misplaced pursuit of one (and only one) language at the expense of practical communication.”

On August 20, the HIT Standards Committee approved recommendations to bring forward to the HIT Policy Committee meeting later this September. 

In this post, we will:

1. Summarize aspects of the HIT Standards Committee’s recommendations that are problematic
2. Develop an analogy to illustrate how the recommendations will limit innovation and increase barriers to communication.  Our analogy:

The Standards Committee recommendations are like mandating that everyone in the U.S. be required to speak Latin by 2013.

Dr. Blumenthal has wisely anticipated that there could be a situation where in his role as national coordinator that he should not follow a Committee’s advice:

“This committee does provide advice to the national coordinator, but it does not make policy,” Blumenthal said, with a noticeable emphasis on “not.” [iHealth Beat; August 18, 2009]

Dr. Blumenthal, this is exactly the situation you have anticipated. (more…)

Many of us have enjoyed a few good minutes of fun having our fortunes told by soothsayers who claim they can predict our future based on patterns of tea leaves in a cup or the playing cards we’ve pulled from a deck.

We pay a few dollars for the entertainment and if the fortune teller is skilled, we are temporarily impressed by his “insight.” But once we leave the carnival, we come back to our senses. Fortune-tellers can’t predict the future.

With its latest announcement, the Certification Commission for Healthcare Information Technology (CCHIT) appears to have entered the fortune telling business.

And if information provided on blogs published by its founders is to be believed, some EHR vendors plan to have their fortunes told by the former EHR certification monopolist.

Background

In June, ONC’s HIT Policy Committee released a Meaningful Use Matrix and proposed that it should serve as the basis for EHR certification as mandated by ARRA, the economic stimulus program signed into law last winter.

The Matrix consisted of five “Health Outcomes Policy Priorities” and associated Care Goals, Objectives and Measures. The Committee anticipated that the latter would be transformed into EHR certification criteria. (more…)

• Political reality dictates that the MMHD must save costs.
• As currently structured, the MMHD cannot achieve cost savings
  • In any given year, only a small percentage of patients account for the vast majority of costs
  • Lessons from previous Medicare disease/care management demonstrations has shown that effective care coordination interventions must be targeted at this population
  • Medicare has structured the MMHD so that any patient with one or more chronic condition is eligible; this includes 86% of all Medicare patients.
  • Physicians will be paid risk-adjusted care coordination fees for this entire population — the 86% of patients with one or more chronic condition.
    The MMHD cannot achieve cost savings. 

Dr. Randy Williams, MD — CEO of Pharos Innovations — has written Part II of this series: The Medicare Medical Home Demonstration: Crawling Out From Under the Rock. It’s insightful and provocative reading!

The Federation of American Hospitals (FAH) sent a letter to Dr. David Blumenthal (National Coordinator for Health IT) arguing that “Meaningful Use” funding should not be tied to achievement of quality measures.  The FAH is the trade association for for-profit hospitals; the letter is dated August 26 and a copy is available on the HealthHombre website, with a deserved hat tip.

First, let me concede that they make a reasonable point on p. 3 when they say “Under it’s framework, the Policy Committee has recommended that HHS should adopt a measure for 2013 requiring a 10 percent reduction in preventable admissions from 2012 to qualify as a meaningful EHR user.”  This measure deserves discussion.

Here’s the implicit threat of a lawsuit — the nuclear bomb: (more…)

This post is a foundational overview of characteristics of network industries.  Much of the terminology will deserve deeper discussion, but we have to start somewhere.

In his book The Economics of Network Industries, Professor Oz Shy lists four characteristics of network industries.

The main characteristics of these markets which distinguish them from the market for grain, dairy products, apples, and treasury bonds are:

1. Complementarity, compatibility and standards
2. Consumption externalities [network effects]
3. Switching costs and lock-in
4. Significant economies of scale in production

In this essay, I’ll quote from Dr. Shy in explaining each of these characteristics.  I’ll also offer a few thoughts as to how these characteristics apply to healthcare. More specifically, I’ll discuss physician adoption of EHRs (electronic health records) and patient adoption of PHRSs (personal health record systems).  

Why a PHRS instead of a plain old PHR?  Think of a PHRS as a PHR data repository platform bundled with multiple high-value applications. For a more detailed explanation, read here.   

Let’s look at the characteristics of network industries one at a time.

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There’s a double meaning to the title of this new series: Healthcare Crosses the Chasm to the Network Economy

At the level of technology, it’s a reference to Geoffrey Moore’s bestselling business/technology book — “Crossing the Chasm”. The Chasm here is the huge gap between early adopters of technology and mainstream users. The book describes the process of bringing specific technologies into mainstream usage.

At the level of clinical care, its a reference to the landmark 2001 report by the Institute of Medicine — “Crossing the Chasm”.  Here, the Chasm is a reference to the quality/safety gap existing in American healthcare, with major systemic recommendations for how to cross the chasm toward clinical improvement.

In this series, the “Crossing the Chasm” is a reference to both technology and clinical care — and to the interdependence between them. I believe we’re entering a new era in healthcare, marked by passage of the HITECH Act Federal stimulus legislation, but of which HITECH is only the beginning . While to a casual observer HITECH Act might seem focused on electronic health records (EHRs), it goes far beyond that.   

Over the past several years, I’ve had the privilege to work with many leading-edge clients who understand that health IT interoperability, networks, and platform/application technologies and business models will reshape health care over the coming years.  This has given me a chance to do a deep dive into understanding companies, business models and literature from outside health care, and then thinking through implications for health care companies (much blogging and book forthcoming).

This series will pull on concepts, terminology and lessons from two disciplines:

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Between the initial recommendations in July and the adopted recommendations in August, one critical word was added to the definition of “certification”.  That one word is “minimum” — and this one word expresses the correct approach and philosophy for the government’s role in the certification process for EHRs.

In this post I’ll address why a “minimum” approach toward certification makes sense: 

• Why “Minimum” Certification is Right: More Like UL
• Why Current CCHIT Certification Based on Functionality Risks Irrelevance or Lock-in to Outdated Technology

Why “Minimum” Certification is Right: More Like Underwriters Laboratories

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Over the past several years, many diverse initiatives have arisen offering partial solutions to systemic problems in the U.S. health care non-system. 

We see Meaningful Use Criteria recommended by the HIT Policy Committee as a unifying force for these previously disparate initiatives. These initiatives have included:

• Patient Centered Medical Homes (PCMHs)
• Regional Health Information Organizations (RHIOs)/Health Information Exchanges (HIEs)
• Payer Disease/Care Management Programs
• Personal Health Record Platforms — Google Health, Microsoft HealthVault, Dossia, health banks, more to come
• State/Regional Chronic Care Programs (e.g., Colorado, Pennsylvania, Improving Performance in Practice)
• Accountable Care Organizations — the newest model being proposed as part of national reform efforts

Today

While there are some commonalities and overlap, to-date these initiatives have mostly arisen in isolation and are highly fragmented — they’re all over the map. Here’s a graphic representation of the fragmentation that exists today:

Tomorrow

The HIT Policy Committee recently recommended highly detailed Meaningful Use criteria for certified EHRs.  Doctors and hospitals who hope to receive HITECH Act stimulus funds will have to demonstrate that they are meeting these criteria; the criteria are not yet finalized.

The Committee website describes the central role of the Meaningful Use criteria:

The focus on meaningful use is a recognition that better health care does not come solely from the adoption of technology itself, but through the exchange and use of health information to best inform clinical decisions at the point of care.

The HIT Policy Committee also is recognizing that there are multiple routes to achieving Meaningful Use beyond the traditional EMR 1.0, e.g., modular Clinical Groupware software.

While some might view the Meaningful Use criteria as limited to the world of health IT — something happening “over there” — we see much more going on. We believe the Meaningful Use criteria are becoming a powerful unifying force across the health system, with potential to converge previously disparate initiatives.  Here’s our conceptual representation:

(more…)

Over the past few days, several of my respected colleagues have written excellent blog posts essentially asking “Does Google Health have life?”

• Scott Shreeve — CLEAR! Shocking Google Health Back to Life
• John Moore — Is Google Health Irrelevant?
• Will Crawford — Future of Google Health

I share their observations and sentiments.  I see Microsoft HealthVault as a serious business strategy while Google Health is more like a hobby (one of probably hundreds at Google).

Are there reasons Google should stick around healthcare? Absolutely!  Off the top of my head, I can think of five:

1. Google brings unique competencies to health care information seeking.
2. Google Health is doing a good job on a shoestring budget.
3. Healthcare is ripe for disruptive innovation.
4. Microsoft needs competition.
5. Microsoft HealthVault and Google Health are more complementary than competitive.

Let’s take these one at a time. (more…)

Be sure to savor every word of Dr. Jaan Sidorov’s masterful witticisms!

Medical homes probably do save money in very controlled settings, where the entire team is literally or at least figuratively under one roof, such as Kaiser.  However, the belief that one can overlay a traditional medical home model across an entire state and save money in the process turns out to be total fiction.

The poster child for that fiction, North Carolina’s Community Care program, turns out to cost state taxpayers probably $400 million a year, rather than save them $300 million, as the state’s self-serving and blatantly incorrect analysis claimed.    A more extensive analysis is available for review, and any state is welcome to the backup data as well.

Here’s a press release with more details.

Highlights of the head-scratching implausibilities claimed would be as follows:

(more…)

• As a political matter, the MMHD must save money
• As currently structured, the MMHD cannot save money

Please read my guest post

The Medicare Medical Home Demonstration (MMHD): Between a Rock and a Hard Place

over at Pharos Innovations new blog: The Collaborative Forum.

Is there a way out from between the rock and the hard place?  In Part II of this series, Dr. Randy Williams will discuss options.

Disclosure: Pharos Innovations is a client of Better Health Technologies, LLC.

Economists call it “The Penguin Problem”  — No one moves unless everyone moves, so no one moves. 

The role of user expectations is crucial in getting penguins to move off of ice floes and in the successful adoption of new network technologies.  I’ll cover two main points in today’s essay:

• How “The Penguin Problem” Helps Explain Low EHR (electronic health record) Adoption To-Date
• How Recent Federal Actions Are Setting Higher Expectations for EHR Adoption

The Penguin Problem and Low EHR Adoption To-Date

While not the only factor, the role of user expectations is a crucial element in explaining the adoption of new network technologies. Harvard Business School Professor Tom Eisenmann explains:

(more…)

As demonstrated by e-CareManagement blog readership, there has been a lot of interest in LifeCOMM.  My first blog post on LifeCOMM in 2007 has been single the most commented on post and the second most widely read blog post.

It’s taken me a while to sift through my thoughts and feelings about saying “Goodbye” to LifeCOMM. At first I was deeply disappointed, but after further reflection think that LifeCOMM wasn’t the right type of platform for today’s consumer mobile health market.

Disappointment

My first reaction was one of disappointment. (more…)

…and the title of the eHealth Initiative’s Sixth Annual Survey of Health Information Exchange says it all:

Migrating Toward Meaningful Use

What’s happening here?

(more…)

Interoperability has multiple dimensions — and I’d bet that most of us have never thought of interoperabilty as involving “process” — people working together and collaborating; I know I hadn’t.

The Interoperability Work Group of HL7’s Electronic Health Record (EHR) Technical Committee was formed in April 2005 to attempt to define the concept of interoperability. The group examined 100+ definitions of interoperabilty. Their work is summarized in their report: Coming to Terms: Scoping Interoperability for Health Care, February 2007.

3 Types of Interoperability: Technical, Semantic, Process

Through work group consensus, three principal types of interoperability were identified: technical interoperability, semantic interoperability, and process interoperability. Here’s an overview:

Type 1: Technical Interoperability

The most basic, hardware-based form of interoperability. IEEE-90 defines interoperability as, “The ability of two different systems to exchange data so that it is useful”

The focus of technical interoperability is on the conveyance of data, not on its meaning. Were it not for the fact that computers tend to use written language, this would be similar to the level of interoperability provided by voice communications, e.g., via a telephone.

Type 2: Semantic Interoperability

the ability of information shared by systems to be understood… so that non-numeric data can be processed by the receiving system.

HL7 also defined a quality that is necessary for optimal semantic interoperability to exist. The quality-based rationale of the HL7 semantic interoperability messaging standard asserts that health information systems will communicate information in a form that will be understood in exactly the same way by both sender and recipient.

Type 3: Process Interoperability

Process interoperability is an emerging concept that has been identified as a requirement for successful system implementation into actual work settings. It was identified during the project by its inclusion in academic papers, mainly from Europe, and by its being highlighted by an Institute of Medicine (IOM) report issued in July 2005 which identified this social or workflow engineering as key to improving safety and quality in health care settings, and for improving benefits realization.8 It deals primarily with methods for the optimal integration of computer systems into actual work settings and includes the following:

• Explicit user role specification
• Useful, friendly, and efficient human-machine interface
• Data presentation/flow supports work setting
• Engineered work design
• Explicit user role specification
• Proven effectiveness in actual use

Here’s another helpful angle on the three types of interoperabilty: (more…)

There is no question,” says Sterling “that the selection and implementation of an EMR is a ‘bet-the-practice’ proposition. If you fail, you end up with more costs and greater frustration.…” (emphasis added)

The real question that Joe the Doctor is asking himself is “…’scuse me, but WHY am I being forced to bet-my-practice on an EMR in the first place?  I’m not a gambler.”

The problem here is not in health information technology (HIT) per se, but in conceptualizing EMR 1.0 as an all or nothing proposition…pass vs. fail, white vs. black, bet the practice and win vs. bet the practice and lose.

This is exactly why a modular and incremental approach to HIT — clinical groupware, EHR 2.0 — makes more sense than the monolithic bet-the-practice approach of EMR 1.0. Physicians shouldn’t have to bet-their-practice on EMR implementation success.

Click on the graphic to download a copy of today’s BrightTALK webcast.

Here’s a full listing of the six eHealth Summit topics (Eastern Time).  Click on the links to attend any or all of the webcasts.  The series will be recorded for future on-demand access. 

EHR 2.0: Federal HITECH Act Creates Opportunities Beyond EMRs

8 Jul 2009 11:00 am

Presenting Vince Kuraitis, Principal Better Health Technologies

Data Convergence in Life Sciences and Healthcare

8 Jul 2009 12:00 pm

Presenting Greg Nelson, President and CEO, ThotWave Technologies

Continua Health Alliance – Interoperable Telehealth Solutions 

8 Jul 2009 2:00 pm

Presenting Rick Cnossen, President & Chairman of Continua Health Alliance

The Future of Disease & Care Management for the Chronically Ill 

8 Jul 2009 3:00 pm

Presenting Jaan Sidorov, MD, The Disease Care Management Blog

(more…)

The last article in this series — Time for EHRs to Become Plug-and-Play — used words to describe a major industry shift underway in health IT.

Sometimes pictures help to make a point. Here are several diagrams that you can also download as PowerPoint slides.

 Computer Industry 1983 to 2002

  Source: Venkatraman, N. Winning in a Network Centric Era, 2006

Blueprint for Health IT Shift

From EMR 1.0 — 2008…

…to Clinical Groupware/EHR 2.0 — 2012 (more…)

by Scott Shreeve, MD

We are entering an unprecedented season of change for the United States health care system. Americans are united by their desire to fundamentally reform our current system into one that delivers on the promise of freedom, equity, and best outcomes for best value. In this season of reform, we will see all kinds of ideas presented from all across the political spectrum. Many of these ideas will be prescriptive, and don’t harness the power of innovation to create the dramatic breakthroughs required to create a next generation health system.

We believe there is a better way.

This belief is founded in the idea that aligned incentives can be a powerful way to spur innovation and seek breakthrough ideas from the most unlikely sources. Many of the reform ideas being put forward may not include some of the best thinking, the collective experience, and the most meaningful ways to truly implement change. To address this issue, the X PRIZE Foundation, along with WellPoint Inc and WellPoint Foundation as sponsor, has introduced a $10MM prize for health care innovators to implement a new model of health. The focus of the prize is to increase health care value by 50% in a 10,000 person community over a three year period.

The Healthcare X PRIZE team has released an Initial Prize Design and is actively seeking public comment. We are hoping, and encouraging everyone at every opportunity, to engage in this effort to help design a system of care that can produce dramatic breakthroughs at both an individual vitality and community health level.

Here is your opportunity to contribute: (more…)

The remarkable report, “Initial Lessons From the First National Demonstration Project on Practice Transformation to a Patient-Centered Medical Home,” published in the May/June issue of Annals of Family Medicine, the Nutting Report, makes this point about the state of primary care IT offerings:

Technology needed in a PCMH is not “plug and play.” The hodge-podge of information technology marketed to primary care practices resembles more a pile of jigsaw pieces than components of an integrated and interoperable system.

Surprise!  Well, actually, no surprise.  We all recognize that health IT implementation in family practices, even under the best conditions and with the best of planning, is difficult and can be an ongoing challenge.   

What is surprising to us, however, is that Dr. Nutting and co-authors make this comment in their recommendations section:

…[I]t is possible and sometimes preferable to implement e-prescribing, local hospital system connections, evidence at the point of care, disease registries, and interactive patient Web portals without an EMR. (more…)

What if the health care payer were re-imagined as a service to the primary care doctor – supplying the tools, information and funding primary care physicians needed to meet the call to reform health delivery?

The structure of physician payment is considered one of the most problematic aspects of our health care system.  Driven by volume instead of coordinated, proactive care and favoring procedures over cognitive work, the payment system has driven primary care into decline and stifled improvements in quality and efficiency.  Indeed, primary care physicians are overstressed and demoralized by demands, coming from every direction, that drive them only to see more patients, as quickly as possible.   In this state, primary care cannot attract new physicians at a time when an expansion of the primary care workforce is desperately needed.  Without new primary care doctors, how will medicine meet the future volume demands of the aging “baby boomers”, much less deliver the kind of comprehensive approach to patient health needed to correct the defects in today’s care?  Despite these growing concerns, little in the way of innovation is arising from payers.

So, what if the payer model was re-imagined?  What would such a payer look like?  At ESSENCE Healthcare, we have developed the Collaborative Payer Model (CPM), which takes the first steps at answering these questions. 

The CPM brings a new approach to address what is missing in much of health care reform, including: (more…)

The forthcoming definition of the “meaningful use” of health information technology will set the direction of the Obama administration’s strategy for health IT adoption, said David Blumenthal, the new national coordinator for health IT. Government HealthIT, April 28, 2009

…but not everyone sees eye-to-eye on the definitions of “meaningful use” and “certification”.  [See the first post in this series for a refresher on the dog (disruptive innovator) and cat (incumbent EHR vendor) points of view.]

Markle Foundation –  Best Articulation of the Dog (Disruptive Innovator) POV 

Achieving the Health IT Objectives of the American Recovery and Reinvestment Act
A Framework for ‘Meaningful Use’ and ‘Certified or Qualified’ EHR
Markle Foundation; April 30, 2009

HIMSS and EHRA — Best Articulation of the Cat (Incumbent EHR Vendor) POV 

HIMSS Publishes Its Definitions of ‘Meaningful Use’
HIMSS News; April 27, 2009

HIMSS Electronic Health Record Association Executives Testify at NCVHS Hearings on ‘Meaningful Use’ Criteria
RedOrbit; April 28, 2009

Many Others Weigh In…. (more…)

For those of you who have not seen earlier posts in this series, please understand that the reference to “goes to the dogs” is a great compliment.

In a joint press release, the American Medical Association and Covisint unveiled an agreement yesterday:

Compuware Corporation (NASDAQ: CPWR) announced today that its Covisint subsidiary signed an agreement with the American Medical Association (AMA) to deploy an innovative health information exchange solution delivering value to its 240,000 member physicians and the physician population at large….

Covisint will enable AMA physicians to have access to a variety of health information technologies via an AMA-branded, web-based solution.  The AMA said it will use the Covisint platform to deliver to physicians a variety of products, services and resources aimed at increasing medical practice efficiency and facilitating the adoption of health information technology (HIT), including help with implementing electronic health records (EHRs). Current product categories that the AMA is exploring include: practice management tools, resources for professional development and clinical management services. The new platform will provide personalized content, search capabilities and learning and networking opportunities, among other valuable offerings

The features of Covisint’s offering are described on its website.

This deal is a  slap in the face to incumbent EMR vendors who have been attempting to develop the electronic plumbing in physicians’ offices for the past decade. You could interpret it as a vote of no-confidence in EMR vendor abilities to develop these web-based collaboration and care coordination tools.  It’s at least a strong expression of “we’re not going to wait around to see whether you can extend your existing EMRs with these types of capabilities”.

…and it’s a strong validation for the technologies and business models of emerging, innovative companies enabling EHR 2.0 capabilities, e.g., RMD Networks, Shared Health.

What are some other possible implications?

(more…)

by Deven McGraw JD, MPH, Center for Democracy & Technology

Introduction

There has been considerable discussion lately about whether or not the stimulus legislation (ARRA) extends HIPAA coverage to commercial vendors of personal health records (PHRs) any time they contract with entities already covered by HIPAA like hospitals, health plans or physicians groups.  (For those of you who don’t know, HIPAA is the Health Insurance Portability and Accountability Act of 1996.  The HIPAA privacy and security regulations form our national health privacy and security rules.)

The provision in question (Section 13408) states that “each vendor that contracts with a covered entity to allow that covered entity to offer a personal health record to patients as part of its electronic health record” is required to enter into a business associate agreement with the covered entity.   Under ARRA, business associates must comply with key provisions of the HIPAA privacy and security regulations. 

In this post, I argue that PHR vendors should be covered under HIPAA only under certain circumstances.  PHRs should be governed by a comprehensive framework of privacy and security protections, but HIPAA would provide inadequate privacy protection for people using these tools (at least as the HIPAA rules are currently structured).  As a result, I argue that this provision in ARRA should not be read to require the automatic application of HIPAA to PHR vendors any time they contract with covered entities to offer a PHR.   Instead, I suggest that HIPAA should cover a PHR vendor’s activities when the nature of the relationship between the vendor and the covered entity (hospital, health plan, physician office) primarily concerns the vendor performing a service for the covered entity. 

However, where the contractual relationship is primarily about improving the value of the PHR to the consumer, HIPAA should not apply.  (I know, not an easy line to draw – but I do suggest some factors that should influence the decision.) 

Finally, I urge the prompt adoption of separate, targeted privacy provisions to protect consumers using PHRs so that the choice is not HIPAA or limited protections under other federal laws. 

Why Not HIPAA – Isn’t it Better Than Nothing? (more…)

Modifications to HIPAA Privacy Laws: Impact on Microsoft HealthVault, Google Health, and other PHRs. 

We’ll explore how recent changes in privacy provisions of  ARRA/HITECH Federal stimulus legislation affect personal health information (PHI) platform companies (e.g., HealthVault, Google Health,  Dossia) and personal health record (PHR) companies.

Health IT expert and journalist Neil Versel described the issue in the April 7 issue of BNET Healthcare:

Although Google and Microsoft have gotten plenty of attention for their Web-based personal health records, both companies have long maintained that they’re not bound by the privacy protections of a 1996 federal law known as HIPAA. And despite a recent HIPAA change — one intended to extend its privacy provisions to services like Google Health and Microsoft’s HealthVault — both companies still insist they’re not bound by the law.

…“Our understanding is that HITECH, which is the jargon for [the health IT] part of the legislation, did not change the definition for a covered entity or a business associate, so our service is offered directly to the consumer,” Google Health Product Manager Roni Zeiger told Modern Healthcare last month. “[O]ur understanding is that we are neither a covered entity nor a business associate,” he continued. “We’re providing a service directly to the consumer or a patient.”

Microsoft offered a similar assessment at the annual Healthcare Information and Management Systems Society conference in Chicago. “We’re still outside [of HIPAA],” said David Cerino, general manager of Microsoft’s Health Solutions Group.

Not everybody agrees with Microsoft and Google. Versel commented in his own blog:

Excuse me? I’ve been struck since Day 1 with the arrogance Google seems to be exhibiting with its entry into healthcare …  it seems to me Zeiger is intimating that the law doesn’t apply to Google.

In the BNET article, Versel also quotes David Brailer, the first head of the Office of the National Coordinator for Health Information Technology at HHS: (more…)

What a difference in attitude! Compare two press announcements from April 5:

1) CCHIT:  Interoperability Isn’t Doable With Today’s Technology .

Certification Commission for Health Information Technology (CCHIT), Interoperability: Supplying the Building Blocks for a Patient-centered EHR , April 5, 2009

This report…(is)  also an attempt to inject a dose of reality into the discussion of interoperability – from practical expectations for the near term and future years to the challenges of developing software architecture and implementation guides that can execute new interoperability criteria uniformly and successfully.

2) New York Presbyterian/Microsoft: We’re Creating Patient Data Liquidity Today!

New York-Presbyterian Hospital Pioneers New Personal Health Record, Press Release; April 6, 2009

Patients can reference their actual, up-to-date health records, which are organized and stored through Microsoft’s Amalga and HealthVault technologies and stored by the patient in a personal account following visits to their hospital, doctors and health care providers.

(more…)

One of the potential dangers of limiting $17 B HITECH federal stimulus funds to electronic health records (EHRs) is the risk of locking-in outdated technologies. Let’s consider what this might mean.

If you think of today’s EHR technology as EHR 1.0, what might EHR 2.0 look like? This post presents a number of innovative ways to conceptualize EHR 2.0:

• EHR as Platform + Applications
• EHR as Clinical Groupware
• EHR Integrated with PHR
• EHR as Software-as-a-Service (SaaS)
• EHR as a “Publish-Discover” Search Engine
• EHR + Disease Management Services = Care Coordination
• DRT-Enabled EHR

My point here is not to provide an exhausting listing of what’s possible, but simply to get you to begin to think about what’s outside the existing EHR box. These concepts are not mutually exclusive and you’ll see there’s overlap.

Let’s look at each of these innovative approaches. (more…)

On March 24, Stand for Quality — a new group representing 165 diverse health care organizations — called for a new era of quality in health care. Their white paper is titled Building a Foundation for High Quality, Affordable Health Care: Linking Performance Measurement to Health Reform .

The perspectives of Stand for Quality are a remarkable break from the past and have significant implications for future investment in health information technology. The Stand for Quality document unequivocally supports the dog  (disruptive innovator) POV — that providers should be paid for improvements in quality and outcomes. It rejects the cat (incumbent EHR vendors and supporters) POV — that providers should be reimbursed for simply acquiring health IT , with the expectation that quality will naturally follow.  (For a refresher on definitions of the dog/cat POV, see the first post of this series .)

Stand for Quality is a who’s who list that includes substantial representation from the physician, hospital, and health plan communities, as well as many others.  A listing of initial supporters is provided at the bottom of this posting.

The key recommendations of the white paper are:

• We must improve quality in health care and make it more affordable.
• Performance measurement is a core building block to provide high quality affordable care
• Public investments are needed to support the performance measurement, reporting and improvement enterprise.
• We should build upon the existing public-private performance measurement, reporting and improvement enterprise.
• Investment in health information technology should be linked to improving care (emphasis added).
• Performance measurement must be dramatically expanded, but measurement alone is not enough.

From having barely been on the radar screen six months ago, is the dog (disruptive innovator) POV rapidly becoming the majority perspective? Here’s the text from the 5^th recommendation:

(more…)

Even though I am a self-admitted dog person, Hoover is my buddy.

Hoover got a new shoebox as a Christmas present.  While most cats are very tied to their existing surroundings and don’t like things to change, Hoover is not your average cat.

The following photos were taken over about a two week period. Hoover hopes you enjoy them! (more…)

Sometimes laws are passed and the statute itself represents 95% of the work — there aren’t many details to figure out or loose ends to tidy up.

That isn’t the case with HITECH. The HITECH statute is just the beginning.

Whether you’re a cat or a dog, you’ll have hopes and fears about aspects of HITECH that are unclear or yet to-be-determined (TBD).

These include:

(more…)

What do cats (incumbent EHR vendors and their supporters) have to smile about over HITECH?

A lot.

…and it’s not very complicated.  HITECH directs $17 B to the cat community, and leaves scraps for the dogs.

(As a refresher, the cat POV is that HITECH stimulus funds should simply pay directly for electronic health record (EHR) technology — that providers will figure out how to use the technology to improve quality and outcomes; the dog POV is that HITECH should pay for improved quality and outcomes — change incentives and IT will naturally follow. See the first post in this series for more detailed explanations.)

There are three aspects of HITECH that are particularly favorable to cats: (more…)

Download a copy here .  Excerpts from the Executive Summary:

Effective Interventions

Three types of interventions have been demonstrated to be effective in reducing hospitalizations for Medicare beneficiaries with multiple chronic conditions who in general are not cognitively impaired:

• Transitional care interventions in which patients are first engaged while in the hospital and then followed intensively over the 4 – 6 weeks after discharge
• Self-management education interventions that engage patients for 4 -7 weeks in community-based programs designed to “activate” them in the management of their chronic conditions
• Coordinated care interventions that identify patients with chronic conditions at high risk of hospitalization in the coming year, conduct initial assessments and care planning, and provide ongoing monitoring of patients’ symptoms and self-care working with the patient, primary care physician, and caregivers to improve the exchange of information. …In-depth analysis of program details has revealed that six
  key components distinguished the successful…programs from the ineffective ones:

(more…)

In the first post of this series, I suggested that HITECH favors cats by about 60/40 and noted that the single most cat-like feature of HITECH is providing incentives for physicians and hospitals to acquire and implement EHRs  — but only EHRs. Reader “Mark” commented:

“How does this work out to 60/40? Looks to me like 100% cats.”

Let’s look a bit deeper to see how HITECH creates opportunities for disruptive innovation . (As a refresher, the cat POV is that HITECH stimulus funds should simply pay directly for EHR technology — that providers will figure out how to use the technology to improve quality and outcomes; the dog POV is that HITECH should pay for improved quality and outcomes — change incentives and IT will naturally follow. See the first post for more detailed explanations.)

The next three posts in this series will examine various aspects of HITECH from differing points-of-view:

• What’s dog-like (innovative)?  — today’s post.
• What’s cat-like (protecting incumbents)?
• What’s yet to-be-determined (TBD) or unclear?

The Need for Innovation

Lack of innovation is the heart of the problem in today’s health IT marketplace. Writing specifically about the market for hospital EHRs, my colleague David Kibbe and I have previously characterized the prevalent HIT business model:

• Proprietary, non-interoperable software
• Low volume, high margin sales (there are only about 5,000 hospitals in the country)
• Customers (hospitals) have high needs for installation support and customization. Customization for individual customers further challenges opportunities for creating interfaces and achieving interoperability.
• High costs of purchase and installation result in high switching costs and customer lock-in.

We questioned whether interoperability was in the economic interests of current health IT vendors:

• Interoperability will tend to commoditize data and reduce opportunities for high margin pricing
• Interoperability will reduce customer needs for software customization
• Interoperability will reduce switching costs and potential for lock-in
• Although it might seem contradictory…hospital customers aren’t asking for it

The market for physician EHRs is very similar.

What’s needed are technology and business models that will create disruptive innovation  in today’s HIT marketplace.

How Does HITECH Create Potential for Disruptive Innovation?

Here are five aspects of HITECH that lay groundwork for future innovation in health care: (more…)

It’s a mixed bag — HITECH legislation  is both dog-like (innovative) and catlike (protecting incumbents).  I’ll refresh your memory below on more specific definitions of cats and dogs.

Among many other reasons, HITECH is dog-like primarily because it has ended the question of WHETHER the U.S. is really serious about health IT reform.  HITECH spells out clear policy goals working toward interoperable health IT and dedicates an initial $19B in federal stimulus funds to begin the work. HITECH begins to create an environment for innovation in health care reform.

There are many open questions as to HOW best to go about this — how to spend the federal stimulus funds in ways that encourage innovation.

HOWEVER,

On balance, HITECH favors cats by about 60/40.

Why?

(more…)

Study breaks new ground in calculating the "normal impairment factor."

We know that poor health accounts for a considerable amount of productivity loss-anywhere from 1 ½ to 3 times direct medical costs.  The potential for disease prevention and disease management programs to reduce productivity loss has, for obvious reasons, caught the attention of healthcare purchasers.  But let’s be careful about making big claims to "recapture" productivity loss.  People find it tough to change health behaviors.  And, even if someone is perfectly healthy, they aren’t 100% productive 100% of the time!  (Possibly with the exception of the current reader.)

Although the association between poor health and reduced productivity is reportedly quite high, employers don’t know how much productivity loss can realistically be recaptured .  There is a need to quantify the portion of productivity loss that can be regained through health management strategies.

Without knowing that amount of impairment, employers and their population health management providers can’t set realistic objectives for their health and productivity strategies.  A recently published article in the Journal of Occupational and Environmental Medicine (Riedel et al with StayWell Health Management) sheds some light on this issue.

(more…)

They all relate to care coordination.  As shown in the diagram below from the Kansas Health Policy Authority (KHPA), there’s a lot of overlap.

A larger copy of the slide is available in this March 2 PowerPoint presentation by Marcia Neilsen , Executive Director, KHPA.

What are some of the implications?

(more…)

Part Medical Home 101,  part strategy session to rescue primary care, part revival meeting — the National Medical Home Summit held earlier this week in Philadelphia was an amazing event.

The optimism, energy, and dogged persistence of attendees and presenters was pervasive. The event was standing room only with another 200 people tuning in to a live Internet video cast.

Dr. Joseph Scherger captured the mood of the day when he proclaimed:

The Medical Home “model” has become the Medical Home Movement !

For those of you unable to attend, here are some key links and publicly available PowerPoint presentations:

(more…)

Here’s a recap:  On a Saturday evening Dorothy took her 86 year old aunt to a hospital in Montgomery, Alabama. Frustrated after an overnight stay in the ER which she said yielded “little treatment”, she requested a copy of her aunt’s medical records before leaving. When she was told that it was hospital policy to request records “in writing”, Dorothy escalated her requests for the records. Refusing to leave without the records, she was brought to the floor by security guards and arrested on charges of  criminal trespassing.

The Chicago Tribune reports that Dorothy has been VINDICATED! (more…)

Warrantee

War`ran*tee"\, noun. A written assurance that some product or service will be provided or will meet certain specifications.

Today when we buy practically any consumer item we expect a warrantee.

What’s the “warrantee” after you are discharged from a hospital?

Last September I wrote a post posing the question “What’s the Best Way to Get Hospitals Involved in Care Coordination? ” The short answer was:  Pay them to do it, take money away when they don’t — make hospitals accountable for their role in avoiding unnecessary readmissions.

President Obama’s FY 2010 Budget begins to project savings from avoiding unnecessary hospital readmissions. “Jumpstarting the Economy and Investing for the Future ”  lays the groundwork for hospitals being required to “warrantee” their services:

Improving Care after Hospitalizations and Reduce Hospital Readmission Rates. Nearly 18 percent of hospitalization of Medicare beneficiaries resulted in the readmission of patients who had been discharged in the hospital within the last 30 days. Sometimes the readmission could not have been prevented, but many of these readmissions are avoidable. To improve this situation, hospitals will receive bundled payments that cover not just the hospitalization, but care from certain post-acute providers the 30 days after the hospitalization, and hospitals with high rates of readmission will be paid less if patients are re-admitted to the hospital within the same 30-day period. This combination of incentives and penalties should lead to better care after a hospital stay and result in fewer readmissions—saving roughly $26 billion of wasted money over 10 years. The money saved will also be contributed to the reserve fund for health care reform. [p.28]

Will this be politically challenging? Not likely…this is a continuation of reforms started under President Bush.

The changes will be profound. (more…)

We have learned that coordinating care of patients — particular care of Medicare patients — is complex and time consuming for physicians.

A breakthrough study quantifies just how complex and challenging care coordination really is.  The study is reported in the February 17 issue of Annals of Internal Medicine and is entitled Primary Care Physicians’ Links to Other Physicians Through Medicare Patients: The Scope of Care Coordination :

We found that in a single year for just fee-for-service Medicare patients, the typical primary care physician needs to coordinate care with 229 other physicians working in 117 different practices…. The number of peers was greater for physicians treating patients with higher chronic illness burden, who may benefit the most from coordination.

My mental visualization of these networks is a series of spider webs.

The authors write that “Coordination involves complex activities that require conscious interactions between providers and between providers and patients, including timely transfer of accurate clinical information, effective communication between the involved parties, and shared decision making.”

The estimate of 229 physicians in 117 different practices is conservative: (more…)

What would you call health care software that:

• Is Web-based and networkable, therefore highly scalable and inexpensive to purchase and use;
• Provides a ‘unified view’ of a patient from multiple sources of data and information;
• Is designed to be used interactively – by providers and patients alike – to coordinate care and create continuity;
• Offers evidence-based guidance and coaching, personalized by access to a person’s health data as it changes;
• Collects, for analysis and reporting, quality and performance measures as the routine by-product of its normal daily use;
• Aims to provide patients and their providers with a collaborative workflow platform for decision support; and
• Creates a care plan for each individual and then monitors the progress of each patient and provider in meeting the goals of that plan?

I call this Clinical Groupware.  The term captures the basic notion that the primary purpose for using these IT systems is to improve clinical care through communications and coordination involving a team of people, the patient included.  And in a manner that fosters accountability in terms of quality and cost.

Clinical Groupware is a departure from the client-server and physician-centric EHR technology of the past 25 years, a fixed database technology that never really became popular.  It is a substantially new and disruptive technology that offers lower price of purchase and use, greater convenience, and is capable of being used by less skilled customers across a broader range of settings than the technology it replaces.

As the name indicates, Clinical Groupware is intended for use by groups of people and not just independent practitioners or individuals.  It is not the same thing as an electronic health record, but may share a number of features in common with EHRs, such as e-Prescribing, decision support, and charting of individual visits or encounters, both face-to-face and virtual.  Neither is Clinical Groupware bloated with extra features and functions that most providers and patients don’t need and, with good reason, don’t want to pay for.

Some Clinical Groupware may look and feel like a web-based "EHR lite." But Clinical Groupware aims to create a unified view of the patient, assembling health data and information that may be stored in many different places and in several different organizations – including HealthVault or Google Health — which most EHRs cannot do.   Clinical Groupware is an evolutionary approach to a shifting health economy in which doing more is not always equated with better care, and the physician or provider role is transforming from autonomous expert to advisor, partner, and guide.   It is also an organic response to the reality that most health care data in electronic format is dispersed across numerous organizations and companies – e.g. hospitals, labs, pharmacies, and devices – and provides a means of accommodating patient demands for a more participatory practice of medicine.

Let me give a couple of examples of this new and emerging class of health software. (more…)

“Where’s the single best place to get up to speed on how the Feds should  spend $20 billion to advance health information technology (HIT)?”

A colleague asked me this question a couple of days ago, and at first I hesitated.  Then it struck me — Matthew Holt’s The Health Care Blog has become the focal point for discussion of this critical topic.

Matthew’s very recent article — Cats & dogs: Can we find unity on health care IT change? — summarizes the two schools of thought that have emerged over the past two months.

His article is important and notable for a number of reasons:

• He crystallizes the two emerging schools of thought — the dog vs. cat POV (see below)
• He summarizes and links to many other key writings on the HIT spending topic
• He suggests that the dog and cat POV can be reconciled — that there’s a middle road
• He suggests several initial options to reconcile the differing schools of thought.  This discussion should continue.

If you’re interested in disease/care management, this is a topic you should be following closely. While the first decade of DM focused on a services based, call center model — the handwriting is on the wall that the next decade will focus much more on a technology based model.

Companies and organizations involved in disease/care management should be positioning themselves to take direct and indirect advantage of the Federal injection of funds.

Here’s Matthew Holt’s summary of the dog vs. cat perspectives: (more…)