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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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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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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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.

(more…)

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…)

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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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.

(more…)

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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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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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:

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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…)

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:

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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

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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…)

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…)

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?

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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…)

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…)

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…)

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…)

Like the Institute of Medicine’s (IOM) 2001 counterpart report, "Crossing the Quality Chasm," a new report from the National Research Council of the National Academies is complex, full of new ideas assembled from multiple disciplines, and is likely to have seminal importance in framing public policy from now on . "Computational Technology for Effective Health Care:  Immediate Steps and Strategic Directions " was released last Friday, January 9, 2009 in draft, but there is so much to comment on that I think it’s wise to begin with a quote from the committee that sums up the central conclusion:

In short, the nation faces a health care IT chasm that is analogous to the quality chasm highlighted by the IOM over the past decade. In the quality domain, various improvement efforts have failed to improve health care outcomes, and sometimes even done more harm than good. Similarly, based on an examination of the multiple sources of evidence described above and viewing them through the lens of the committee’s judgment, the committee believes that the nation faces the same risk with health care IT—that current efforts aimed at the nationwide deployment of health care IT will not be sufficient to achieve the vision of 21st century health care, and may even set back the cause if these efforts continue wholly without change from their present course. Success in this regard will require greater emphasis on the goal of improving health care by providing cognitive support for health care providers and even for patients and family caregivers on the part of computer science and health/biomedical informatics researchers. Vendors, health care organizations, and government, too, will also have to pay greater attention to cognitive support. This point is the central conclusion articulated in this report.  (emphasis added)

It would be difficult to find a more sober indictment of US health care IT policy and implementation over the past decade than what is contained here. The report is the result of many meetings and site visits beginning in April 2007. It was written by a committee chaired by William W. Stead, MD, Director of the prestigious Informatics Center at Vanderbilt University Medical Center, and includes not only some of the nation’s top academic computer scientists and health IT engineers, but representatives from the private sector (Google and Intel) as well. (more…)

It seems likely that the Obama administration and Congress will spend a significant amount on health IT by attaching it as a first-order priority to the fiscal stimulus package. We take the President-elect at his word when he recently said:

"…we must also ensure that our hospitals are connected to each other through the Internet. That is why the economic recovery plan I’m proposing will help modernize our health care system – and that won’t just save jobs, it will save lives. We will make sure that every doctor’s office and hospital in this country is using cutting edge technology and electronic medical records so that we can cut red tape, prevent medical mistakes, and help save billions of dollars each year." (December, 6, 2008)

Whether the health IT money is well spent will depend on how it is distributed and what it buys. Most observers suppose that federal health IT investment dollars will be used to help doctors’ offices and hospitals acquire and implement electronic health record systems (EHRs or EMRs). These are commercial software suites for entering, storing and managing patient health data within a practice or health organization.

We agree that some of the federal health IT money should go to purchase EHRs, especially to doctors and hospitals in rural and under-served areas, which otherwise could not afford them.

The Easy, Wrong Solution

The easy solution would be to spend most of the health IT funds on EHRs. The EHR industry has made it easy by establishing a mechanism to "certify" EHR products if they incorporate certain features and functions.

But the easy solution would not be the right one. (more…)

Mark E. Miller, Ph.D., Executive Director, Medicare Payment Advisory Commission testified recently in front of the U.S. Senate Committee on Finance. He opened his remarks by stating:

The health care delivery system we see today is not a true system: care coordination is rare, specialist care is favored over primary care, quality of care is often poor, and costs are high and increasing at an unsustainable rate.

About a quarter of Mr. Miller’s testimony focused on an issue that hasn’t received much attention: avoidable hospital readmissions . Here are some key excerpts:

(more…)

…that’s my key takeaway from attending the Robert Wood Johnson Foundation (RWJF) Project Health Design (PHD) conference in Washington D.C. on September 17. The conference was entitled  A ‘Report Out’ from Project HealthDesign and Forum on Next-Generation PHRs .

A PHD Fact Sheet capsulizes the evolution from PHRs to PHRSs: (more…)

"Re: UHG. Was at the Healthcare Quality Conference yesterday in Boston. Got to talking to a United Health exec who informed me that they have signed an agreement with Google Health and have a pending agreement with HealthVault. This backs up UHG’s previous statement that member records would be made portable. Individual made mention that the Google Health relationship extends beyond just claims records transfer and includes a technology partnership regarding UHG’s OMX."

Commentary: Among health care incumbents, health plans are experiencing the greatest heartburn over the emerging Personal Health Information Network (PHIN).

On the one hand, existing health plan IT and business models have been proprietary and closed. Here’s how a typical health plan might state their POV:

(more…)

By Vince Kuraitis and David C. Kibbe, MD, MBA

Once upon a time, there was a little girl named Goldilocks. Like most Americans, Goldilocks had concerns about achieving just the right amount of data liquidity for her personal health information (PHI).

Until today Goldilocks felt between a rock and a hard place:

"I want my PHI to be appropriately liquid — just the right viscosity. My PHI should be viscous enough to flow to my trusted health care providers to use to improve my health and health care.

“Today my PHI is frozen and inaccessible — it’s too cold.

“But I’m worried about the other extreme — the risks of using a personal health record (PHR). The privacy/security advocates tell me that I should be concerned about my PHI being too hot — like steam that’s vaporized and disperses uncontrollably into the atmosphere.

“How do I get it just right? …not too cold, not too hot?"

What happened today to resolve Goldilocks dilemma? The Markle Foundation’ released its Common Framework for Personal Health Information (PHI).

Dossia, Google, Intuit, Microsoft, and WebMD today joined prominent health care providers, health insurers, and consumer and privacy groups in endorsing a set of practices for new internet services that help consumers track and improve their health. The framework defines a set of practices that can help protect personal information and enhance consumer participation in online personal health records.

The Markle Foundation’s accomplishments in advancing this collaborative framework are nothing short of miraculous!

Let’s revisit Goldilocks and the bears to see exactly how the Framework resolves the PHI too hot/too cold dilemma. (more…)

The purpose of this post is to help a non-technical audience untangle some of the confusion regarding health data exchange standards, and particularly come to a better understanding of the similarities and  differences between the Continuity of Care Record (CCR) standard and the CDA Continuity of Care Document (CCD). But what I’m most interested in is getting beyond the technical, political, or economic positions and interests of the proponents of any particular standard to arrive at some principles that demonstrate in plain language what we are trying to achieve by using such standards in the first place.

Frankly, I don’t give a hoot about what standardized XML format for capturing clinical data and information about a person becomes the norm in the health care industry over the next several years. I do care that the decision is made by the people, institutions, and companies who use the standards, and not made by a quasi-governmental panel or a group of “industry experts” whose economic or political interests are served by the outcome, and dominated by a particular standards development organization with whom they are very cozy. 

In other words, I do want free and open market forces to be able to operate freely and openly as health information exchange evolves, in part because I believe market forces will work in the direction of continuously improving health IT, whereas in my experience top-down efforts are often protective of established interests and discouraging to innovation.

Herein lies the problem, in my opinion, with the standards adoption process that the Office of the National Coordinator of HIT (ONC) and HITSP have overseen during the past four years.

(more…)

What’s so special about this conference?

First, the caliber of the people attending.  It’s a stimulating mix of high-level clinical, technical and business types.  The energy is flowing and many people have told me how much they like to go just for the networking.

Second, the caliber of the conference organizer.  I’ve worked with many conference planners, and Satish Kavirajan is not your ordinary conference organizer.

Satish really knows his stuff and he’s a pleasure to work with.  I’m impressed how from a year in advance of the first Healthcare Unbound in 2004 he delved into the substance of the topics.  He read every link and every report I sent him, he talked with experts in the field, he asked deep questions about how best to structure a session or find the right mix of people for a panel.  In addition to many years of conference experience, Satish has an MBA in finance from Columbia — not your typical conference organizer.

Finally, there’s the caliber of the faculty.  Here’s the list of session titles and keynoters for Day 1 of this year’s Healthcare Unbound Conference:

• The Personal Health Information Network (PHIN): Opportunities and Implications for Healthcare Unbound. Vince Kuraitis, Better Health Technologies and David C. Kibbe, The Kibbe Group; American Academy of Family Physicians
• Healthcare Everywhere – How the New Culture of Wellness Is Opening the Door for Healthcare Unbound. Liz Boehm, Forrester Research
• A Behavioral Economist, a Roboticist, and a Healthcare Unbound Advocate Walk Into a Bar: Meanings for the Rest of Us. Mike Barrett, Critical Mass Consulting
• Keynote (title pending). Jay Srini, University of Pittsburgh Medical Center
• From Mainframe to Personal Healthcare: A Progress Report on Addressing Technology, Policy, and Cultural Challenges. Eric Dishman, National Chair, CAST; Intel Corporation
• The Internet of Bodies. Don Jones, Qualcomm
• Google Health Overview. Jerry Lin, Google
• Continua Health Alliance:  The Next Generation of Personal Telehealth is Here! Dave Whitlinger, Continua Health Alliance; Intel Corporation
• Microsoft HealthVault Overview. David Cerino, Microsoft
• Disruptive Healthcare Innovation – Changing the Rules of Diabetes Management by Marrying Wireless and Clinical Innovation in the Healthcare Ecosystem. Anand Iyer, WellDoc; In-Building Wireless Alliance
• Improving Health Outcomes and Lowering Costs Using a Distributed Care Management Model. Larry Leisure, iMetrikus

I hope to see you at the 5th Annual Healthcare Unbound Conference! Please consider attending, sponsoring and/or exhibiting.

Google Wants to Index Your DNA, Too Business Week; April 18, 2008

A few years ago I remember reading a vivid description of how much information is contained in one person’s genetic code:  a stack of phone books high enough to reach the top of the Washington Monument.

Drs. Mandl and Kohane begin their recent article in NEJM with the statement that “large corporations are seeking an integral and transformative role in the management of health care information,” and then warn that this “will profoundly affect the biomedical research enterprise.”   

At issue for the authors is who controls the information about you and me, our health and healthcare data. Without coming right out and saying it directly, they worry that data in the hands of consumers and patients made possible through PCHR service providers like Google and Microsoft could be dangerous to the nation’s health because of  “commercial interests”.  

So, they are warning us, too.

But, let’s examine the presumption that your personal health information is safest in the hands of the medical establishment (incumbent service and health care provider organizations and the biomedical research enterprise). The real question that their article in NEJM begs is:

how good a job of stewarding our health data is the medical establishment doing? (more…)

I’ll take this a step further and ask “Could a linkage between HealthVault and Amalga become a centerpiece of Microsoft’s broader health care strategy?” (more…)

• What are companies like Google, Microsoft, and Dossia (sponsored by Intel, Wal-Mart, AT&T and others) hoping to accomplish in health care?
• What is the emerging Personal Health Information Network (PHIN) and why should you care?
• What’s the Continuity of Care Record (CCR) Standard, and how is it destined to become an initial focal point of data exchange initiatives?
• Why is the PHIN potentially disruptive to many business models? What types of companies or organizations could be affected the most?
• What are opportunities and threats to major health care players — hospitals, physicians, health plans, enterprise HIT vendors, ambulatory HIT vendors, and others?
• What specific actions can you take to be a leader in advancing the PHIN and positioning your company for success?

In a recent blog posting, David C. Kibbe, MD, MBA and I wrote an overview of our vision for the PHIN. 

Now, for the first time, we look forward to discussing our vision for the PHIN. This Healthcare Informatics webinar will be held:

Thursday, April 17, 1 PM Eastern, 10 AM Pacific.

Click here for details….read “Event Info” to see a more specific description of the webinar.  Get a 15% discount by using Promo Code VK15.

Here’s a diagram of the PHIN as we see it today:

(click on the picture for a larger version)

The Speakers

(more…)

Continua’s work-to-date is a necessary, but not yet sufficient effort to make RPM devices mainstream.

Knocking down the barrier of device-incompatibilty exposes the bigger barrier of lack of data interoperability among RPM technologies and between RPM devices and health care IT systems.  Jonathan Edwards, research VP and lead telemedicine analyst for Gartner, nails the issue:

(more…)

Older Americans 2008: Key Indicators of Well-Being, AgingStats.gov, Federal Agency Forum on Aging-Related Statistics

Healthy@Home, commissioned by AARP and the Blue Shield of California Foundation

State of Technology in Aging Services, Center for Aging Services Technology (CAST)

These reports are succinctly profiled with links to the full studies at Profiles of older health care consumers: living longer, longing for technology on Jane Sarasohn-Kahn’s Health Populi blog. A great read!

Who is the federal  government calling on to breathe life into the Nationwide Health Information Network (NHIN)? Google and Microsoft.

In our first article of this series describing the Personal Health Information Network (PHIN), we noted early entrants as Google Health, Microsoft HealthVault, and Dossia.  We also noted that the network could grow rapidly, and that others would want to join or link to the PHIN.

With Uncle Sam announcing plans to link to the PHIN, even we are surprised at the speed at which developments are occurring. 

Government Executive reports:

The federal office in charge of creating a national network of electronic health records plans to integrate the system with the health care databases that Google and Microsoft launched last year, on which individuals can store their health records, a top official with the Health and Human Services Department said….

(The HHS official) provided few details on how the office would incorporate personal health records….

Federal interfaces to the health network will be through an entity called NHIN Connect.

Here’s a simplified diagram of our current understanding of how NHIN Connect will link to the Personal Health Information Network (click on the diagram for a larger version):

Commentary (more…)

Two companies — Aetna and Microsoft — have come up with 180 degree different answers.

In this post, I will:

• Describe how Aetna’s and Microsoft’s approaches differ
• Speculate on why their approaches make strategic sense for the respective companies
• Explore how technology and expectations about using PHI for search are likely to change over time

Aetna’s SmartSource and Microsoft HealthVault 

Aetna has adopted a more aggressive strategy of using your PHI to improve search results. Microsoft HealthVault is employing a much more cautious strategy and (for now) has pledged NOT to use personalized health information to target health search.

Aetna is a health insurance plan with an existing member base of 17 million members.  Aetna’s recent press release announced a partnership with Healthline introducing

Aetna SmartSource, the first-ever personalized search engine that mines information from Aetna’s vast data resources to deliver meaningful, personalized health and health benefits information to Aetna members. 

Based on existing medical claims data that Aetna already has about members, your search term will be matched against your own medical history to provide the most relevant results.

Microsoft HealthVault search is different.  From the Microsoft HealthVault Fact Sheet:

Microsoft does not link users’ personal information with HealthVault search queries.

Why the Difference? (more…)

I’ll describe 4 factors behind my thinking:

• Lack of Trust
• Lack of Access to Clinical Data
• Lack of Permission
• Lack of Convenience in Consumer Workflow (more…)

The Internet and digital technologies have transformed many aspects of our lives over the past twenty years.  We can get cash at ATMs all over the world; we can book our own airline reservations; we can shop and get best prices over the Internet.

Why hasn’t this happened in health care?  Something is missing.

Recently, major global information and communication companies have announced their intention to bring their technologies and business models to health care.  While the creation of Google Health (GH), Microsoft HealthVault (HV), and Dossia (sponsors include Intel, Wal-Mart, AT&T) are important news items by themselves, what’s more important is what they represent collectively — a new Personal Health Information Network (PHIN). The PHIN and applications developed around the PHIN will fill in many missing pieces and bring health care into the Information Age.

For example, suppose you just found out you have high blood pressure – that’s not uncommon.  Suppose you could easily submit information about your condition using the Google Health platform to receive a service that does the following:

• informs you whether there are clues in your medical history that point to a cause for your high blood pressure
• explains why being overweight can be a contributing factor
• tells you in easy-to understand language what the top number and the bottom number mean (”140 over 90″)
• explains which laboratory tests are necessary
• alerts you to the possibility that one of your prescription or over the counter  drugs could be making your high blood pressure worse
• advises you about the usefulness of using non-drug approaches to treatment
• tells you which treatment drugs have the greatest efficacy and safety for your specific circumstances
• tells you if any of those generics high blood pressure drugs are available at Walgreens for $4 a month
• offers to provide you a map with several Walgreens stores in your city that carry those $4 a month medications

…and many more possibilities we have not yet begun to imagine!

This essay:

• Is the first in a series of articles we’ll be writing to describe the PHIN and why it’s important — expect about a dozen follow-up posts.
• Is an overview of the basic idea — think executive summary or long abstract
• Introduces some new concepts, which we’ll try to simplify and define.  We understand that some of this is not easy reading. ….so we suggest you refill your cup of coffee and settle in. (more…)

A High Level Comparison

Google Health and Microsoft HealthVault Personal Health Information (PHI) Platforms

There’s still not much information available about the specifics of GH, although they did release sketchy information on the Official Google Blog.  I’ll comment on a few of the particulars. (more…)

A report released this week raises strong doubts. The study — Creating Sustainable Local Health Information Exchanges: Can Barriers to Stakeholder Participation be Overcome? — was  funded by the U.S. Agency for Healthcare Research and Quality (AHRQ) and conducted by the Center for Studying Health System Change (CSHSC). The term HIE is often used interchangeably with RHIO (Regional Health Information Exchange).

What’s different about this study? The CSHSC report goes a step further than other recent reports documenting minimal progress by most HIEs and questioning whether HIEs have a business model. Through interviews with HIE participants — hospitals, physicians, health plans, employers — it brings evidence from the horse’s mouth suggesting

1. the rationale TO share data is WEAK, and
2. the rationale NOT TO share data and to preserve the status quo is STRONG. 

The next question becomes “Is it time to get off the dead horse?” Does it make sense to put more time and energy into a flawed model model and further delay national efforts to create interoperable electronic health records?  Are HIEs doing more damage than good?

Here are some of the key conclusions:

(more…)

I’m pleased to share a copy of the PowerPoint presentation with you, and I hope you find it useful and provocative.  You can view and/or download a copy here (6MB).  This version contains 77 slides, which would be about the length I’d use for a 3 hour workshop; you’d see a more compact version for a conference keynote, Board summary, or management strategy session.

fyi, the DM Megatrends are:

MAGNITUDE: We are just scratching the surface of chronic disease challenges.
INTEGRATION:  The 50 year tide is shifting toward integration, away from specialization.
MEDICARE: While Medicare has endorsed the need for chronic disease management, disappointing results from recent demo projects make future direction unclear.
PROVIDERS: Care providers have woken up to DM opportunities and threats; they are promoting the medical home and the Chronic Care Model.
MAKE, ASSEMBLE, BUY? Fewer are buying as health management becomes increasingly strategic.
TECHNOLOGY:  DM in your home and your pocket.
BEHAVIOR CHANGE: DM is moving from a medical to a social model; behavior change has become the Holy Grail.
CLINICAL AND ECONOMIC ROI:  Round one is over, DM wins; Round 2 has just begun.
WILDCARDS! (employers, P4P, retail clinics, CDHPs, elections)

Comments are always appreciated.

Last week was a podcast of DM Megatrends…next week — the movie.  Brad has signed, Angelina is waffling.

The OptumHealth and UnitedHealthcare units of Minneapolis-based UnitedHealth Group have made their personal health records service accessible for life.

That means an individual covered by UHC insurance or OptumHealth’s outsourced health and wellness services will be able to access their PHR–and continue to enter data into it–if they change jobs or insurance coverage.

Prediction:  over time, the market will force all employers, payers, and providers to provide interoperable and transportable PHRs; proprietary PHRs will not survive in the marketplace.

Why?

(more…)

More typically, DM Megatrends is 45–90 minute presentation with accompanying PowerPoint slides.

As part of the Web Summit, the good folks at MCOL asked me to do a short podcast on highlights of this presentation. They’re allowing me to share it with you… click here to save or listen to the podcast.

fyi, the DM Megatrends are:

MAGNITUDE: We are just scratching the surface of chronic disease challenges.
INTEGRATION:  The 50 year tide is shifting toward integration,  away from specialization.
MEDICARE: While Medicare has endorsed the need for chronic disease management, disappointing results from recent demo projects make future direction unclear.
PROVIDERS: Care providers have woken up to DM opportunities and threats; they are promoting the medical home and the Chronic Care Model.
MAKE, ASSEMBLE, BUY? Fewer are buying as health management becomes increasingly strategic.
TECHNOLOGY:  DM in your home and your pocket.
BEHAVIOR CHANGE: DM is moving from a medical to a social model; behavior change has become the Holy Grail.
CLINICAL AND ECONOMIC ROI:  Round one is over, DM wins; Round 2 has just begun.
WILDCARDS! (employers, PHRs, P4P, CDHPs)

The aha of “hospital as mainframe” came from reading Eric Dishman’s epilogue in Dr. Mike Magee’s excellent recent book, Home-Centered Health Care:

As with mainframe computers only a couple of decades ago, today we have to make a pilgrimage to that hospital mainframe to wait ever so patiently as we time-share those miraculous modern medical capabilties that have been gathered there.  In the midst of already ballooning healthcare costs, growing ranks or un-and under-insured, and epidemics of age-related illnesses and injuries, this mainframe model cannot scale to meet the needs of ouj aging population where neither the dollars nor the doctors will exist to deliver healthcare business as usual.

Just as we moved from mainframe to persional computers that are now part of our everyday lives at home, work, and play, so, too, we must redistribute healthcare expertise and equipment from  mainframe megaplexes to our homes and to our personal lives. Eric Dishman is General Manager, Health Research & Innovation Group, Intel Corporation. Disclosure: Intel has been a client of Better Health Technologies.

OK, sounds good…and just HOW is all this going to happen?

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What Will Microsoft’s HealthVault Mean to the Telehealth Community?

Our bottom line:  HealthVault overall is a positive for telehealth industry growth and scale, even though it will speed the inevitable commoditization of remote patient monitoring (RPM) devices.

The health care and technology worlds are still trying to figure out what Microsoft’s HealthVault (HV) is all about.  We believe that there are a number of misconceptions out there about what HV is and isn’t:

Misconception #1: HealthVault is a personal health record (PHR).

Misconception #2: People don’t trust Microsoft, so they won’t sign up for and use HV.

Misconception #3: Patients don’t understand PHRs, don’t want them, and don’t know what they’d do with them.  This is a rate limiting step to market growth for HV and its partners.

Misconception #4: By launching HealthVault first, Microsoft beats Google to the punch.

Let’s take these one at a time.

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Initial confusion put aside, I think HealthVault is strategically brilliant.  While I’d give Microsoft a C- for explaining HealthVault (HV), I’ll give them an A for laying the strategy and foundation for what can become an extremely powerful platform for the appropriate, free flow of interoperable and transportable personal health information (I’ve chosen my words carefully here).

Here are four initial impressions about HealthVault — please comment as I’m still trying to figure out myself exactly what HV is and isn’t.

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Dear Colleagues:

Thursday I attended a wonderful one day conference, entitled “Health 2.0 — User Generated Health Care.” One of the most interesting events of 2007. Held in San Francisco. I had a chance to talk with Adam Bosworth and Missy Krasner of Google, with Peter Neuport of Microsoft, and with David Brailer, among many others. It was particularly good to see Drs. Walter Lim and Rick Chan, with the Ministry of Health in Singapore, who came all the way from Singapore for the event. I was on the final reactor panel with Esther Dyson, Lee Shapiro of Allscripts, and Jay Silverstein of Revolution Health, representing the American Academy of Family Physicians (AAFP).

How to describe this event? (more…)

A Bluetooth heart monitor could text your local hospital if you are about to have a heart attack, according to research published in Inderscience’s International Journal of Electronic Healthcare. The device measures electrical signals from the heart, analyses them to produce an electrocardiogram (ECG) and sends an alert together with the ECG by cell phone text message. Portable heart monitor sends emergency alerts and ECG as text message, Virtual Medical Worlds, August 2007

Original article: Design of wearable cardiac telemedicine system, International Journal of Electronic Healthcare 2007 – Vol. 3, No.3  pp. 303 – 316

PowerPoint from Opening Keynote

Here’s a copy of the PowerPoint for my opening keynote presentation. My colleague and fellow blogger Tim Gee did a great job summarizing key points on his blog.  THANKS, Tim.

In a nutshell, my main theme is that the adoption of Healthcare Unbound technologies is becoming increasingly dependent upon adoption of broader health information technology (HIT) standards for interoperability and transportability of personal health information.  We should view the Healthcare Unbound ecosystem as highly interdependent — a crew team rowing in harmony rather than a bunch of kayakers in sleek craft that are independently powered and steered.

Major Takeaways from the Conference

Here are some of my key take away points from the conference:

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Thanks for your interest and feedback on my recent posting Connecting the Dots…Google Health Promises to Create AND Dominate Next Generation PHRs.

Despite being over 3,500 words long, this essay has quickly become the #1 most widely read posting on my blog.  It continues to generate several hundred views per day and has been linked to by over a dozen other bloggers and news sources.

Reader comments center around two primary themes:

1) Should I trust Google Health’s (GH’s) next generation personal health record (PHR) with my personal health information (PHI)?

2) Can GH really get health care players to adopt and share electronic PHI?  Why would/should others share their data with Google?

Today’s blog posting will tackle the trust issue.  Reader Paul summarized the concerns here when he wrote:

“…personally i find it bizarre to think patients will entrust Google.”

Please consider 5 points about the trust issue.

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While Google has not “officially” announced the details of GH, they’ve left a lot of clues. In this essay I’m going to play a combination of detective and tea leaf reader — deciphering existing clues and making some educated guesses about where GH is headed….it’s very exciting.

I get truly inspired when I see a business model that 1) is exceptionally powerful, and 2) offers dramatic benefits to humanity. Google Health is just such an animal.

Let me be clear. I am not speaking for Google; I don’t work for Google. This posting is my collection of inferences drawn from the clues provided about GH and from my general knowledge of health care and business. So when I write “GH will ______”, recognize that this is me putting together clues and applying my best judgment.

Here’s an overview:

• The Current Market Structure for Personal Health Information (PHI)
• GH’s Anticipated Technology Model
• Three Leverage Points
• GH Will Be Disruptive
• Concluding Thoughts

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