Of course, the problem with sending this information in an email is that email is not secure. Email encryption hasn’t taken hold fast enough to make it encrypted. Is a user’s email box really a secure location where they want their health information? I personally don’t have a problem with it, but I would expect that many people wouldn’t want their health information in their email any more than their regular mailbox. Either way, without the encryption it wouldn’t be difficult for someone to sniff out what’s being sent in an Email containing for example a patient’s discharge. It would be going across the internet in basically plain text.

This situation actually happened in Austrailia a little while back in an article I read called “Unsecured email sparks dispute.” I know I wouldn’t be happy if a clinic just decided to send these unsecured emails. Not so much because I was personally worried about my information being lost. I personally have nothing to hide (yet anyway). However, I would feel uncomfortable patronizing an organization that would deal so flippantly with my information.

I’m sure that someone will chime in that this is the whole purpose of a Patient Portal or EHR interface that allows people a secure method to receive and send protected health information. This is all well and good, but from what I’ve seen this usually requires the doctor’s EMR company to support this type of interaction. Plus, even more serious of an issue is that you’re giving your patients one more login and password that they’ll need to remember. Certainly not a deal breaker, but one more inconvenience for our users and the staff that have to support our users when they forget their password. Unfortunately, I think that this is the future of secured messaging, but I can always hope that there’s something better that we’re just missing.

We should also realize that this isn’t going to get any easier. In fact, I think we can reasonably say that this is going to get harder and harder. Don’t be surprised if soon some patient would like their health information somehow incorporated into some site like Facebook. It’s really only a matter of time until some developer creates a health interface into Facebook.

It might not make sense to most people, but the next generation of patients are going to grow up living and breathing their online life in some sort of social network (Facebook is just one example of these). They are very comfortable with transparency and will be interested in being able to track and compare health information with other people. Not to mention interact in a social network with other people who have similar conditions. It seems like this isn’t a question of if, but when this type of interaction will happen.

Even if you think that health information on a social network like Facebook is far fetched, we are already seeing health information propagating to the web in Microsoft’s HealthVault and Google Health. Is this going to be ok? Will it become as synonymous as online banking has become to the banking world? It’s not that far of a stretch to think that Google Health could easily be tied into Google’s OpenSocial platform which would allow a patient’s health information to do all sorts of cool things.

The convergence of Health Care and IT is going to be really interesting. It’s taken health care a while to get going with IT, but I think almost everyone agrees that IT could do amazing things to better the health care a person receives.

Since it’s not a panel, then I’d love to hear any feedback from people on things I should include in my presentation about “Lessons Learned from EMR Implementation.” I have a ton of things already planned about EMR implementation, but I’m sure there are some important things that I’ve missed. Time has a way of doing that to you.

Either way, I’ll be happy if one person in my session on EMR goes away saying they were better prepared to implement an EMR system, then I’ll be happy.

Of course, that would make me happy, because I’m certain that EMR’s and EHR’s are the future of healthcare and competition is great for the consumer.

Well, here’s some other things I’ve found about Microsoft’s HealthVault. Most interesting is going to be watching the Microsoft HealthVault blog. Maybe that’s because I’m a crazy blog lover, but I love the idea of being in contact with the people that make it happen. Open communication is the best.

Also, here’s an interview with Peter Neupert talking about the significance of his group’s acquisitions of Azyxii and MedStory for clinicians and consumers and of course HealthVault.

Setting the legal items aside, the technology of a digital signature is not rocket science by any means. In fact, it’s the legal questions that are harder mostly because there just hasn’t been much case law that has dealt with it. Just as a thought, I would highly suggest that whoever reads about this talks with a good legal team before implementing it.

Of course, reading the comments from my previous post made me realize that what we’re doing is really quite innovative. I’m not just talking about digital signatures. For more than two years now we’ve been collecting patients health history form in our Health Center and intake questionnaire in our counseling center electronically. These forms don’t require the patient or client to leave a signature. It’s basically just capturing information. I think most people can see why it’s valuable to have a health history form captured electronically. In our case it makes all of the necessary clinical information available in one place without dealing with the time consuming and inaccurate scanning. Even more significant for us as a state institution was the ability to do aggregate reporting on the type of patients we were seeing. How many other people can find out things like 20% of your patients have a family history of heart disease (not our actual number)?

I know there are a number of EMR companies out there that have a whole patient portal where this kind of stuff is done, but I’ve never seen any that use a kiosk at the doctor’s office to collect this information. If you are an EMR vendor that has this feature, please leave a comment. I think we’d all love to know who else does it.

Looking at it now, capturing digital signatures for HIPAA privacy forms, consents, etc is just the next step in ridding ourselves of paper. In fact, this addition means that our patients can bypass the front desk completely. They check in on the computer, fill out their necessary forms and then are directed to have a seat. This notifies the nurse that they have arrived and they are ready to be seen. No face to face contact. Privacy at its best.

Well, I got a few questions and comments in my digital signature post that prompted this post. I’ll do my best to answer them here.

Chris Kozloski said, “I like the idea. A kiosk for registration that they could fill out the paperwork online and sign the blocks on the screen would be really neat.”

See my notes above. It’s not just an idea. We’ve been having them fill out the paperwork for two years now. We also have the technology to do the signatures. Just waiting for the other signature pads to arrive and we’ll be implementing it.

One thing I’m not sure most people think about is how the computer will know which forms need to be filled out by the patient. I think that’ll have to be the topic for my next post.

Craig Briars asked, “What software are you using to do this with?”

This is a good question. We are using Medicat EMR. It’s an EMR that is focused on the College Health community, but could be used in a general practice if needed. I’m not sure how it is in a general practice, but I know that they have a ton of features that make it a solid choice for College Health offices interested in EMR.

Medicat has integrated it’s software with topaz signature pads. Medicat uses the Topaz software to capture the signature. It’s actually quite neat how the signature is captured and stored in the database. We did find that the LCD signature pads with the back light were the best. The cheap $100 topaz signature pads just wouldn’t capture my signature if I did it quickly. Plus, if it isn’t LCD, then I don’t know which part of the signature it missed so that I can correct it.

The first method of digital signature is basically using your login to sign something. This is the most common digital signature in an EMR and many people don’t even realize that what they are doing is digitally signing their chart. Some EMR programs don’t even ask you to physically sign the chart. Instead, they leave the note open for a certain time period. After that time period, then the note will essentially be locked so that nothing can be changed. Why does this type of signature work? Basically it knows that you were the one that logged in and the EMR logs who enters what piece of data. Essentially, the program is leaving your virtual signature throughout the chart as you enter your information. Pretty neat as long as that EMR has a good audit program so you can see who entered what information on a patient.

The second method is similar to the first in that it uses your username. Often, it may use some of the same principles of the first method by keeping track of who entered what information. However, in this method each electronic note requires you to click a button to “digitally sign” the clinical note. This can also apply to lab or x-ray results. This is the type of digital signature that we use most in our clinic. Each note has a button that lets you sign the note electronically. After clicking the button it imprints your name, credentials and the date and the time of the signature. The date and time is especially useful on lab results so we can know when a doctor may have read the lab results.

The third method is what I call “electronic signature” because it literally takes your physical signature and captures is electronically. Everyone should be familiar with this if they have been to a grocery store or Walmart. Basically all of the major chains are accepting your credit card signature electronically now. I can’t say how much I appreciate the digital signature in stores when I’m holding a baby. Have you ever tried to sign a piece of paper while holding a baby in one arm. It’s nearly impossible, but I digress.

I honestly haven’t heard of many (if any) doctor’s offices that are using a signature pad like Walmart does. However, it really is something that is an essential feature of an EMR that wants to have patients fill our their information electronically. Ok, some larger practices can distribute logins to all their patients. However, even then you’d probably need a physical signature to give them the login. My clinic is currently implementing this technology. The signature pads aren’t cheap, but I think they are well worth the money. It basically allows us to make every patient form electronic. This was never possible before since so many required a signature. Capturing a digital signature is what we’re doing to capture this information.

I hope for the signature pads to all to go live in the middle to end of August so look for more information on this coming soon. Is there anyone else using digital signatures with their EMR?

It seems like the logical method. It would definitely have to be secured and password protected. However, the ability to have it accessible by the entire clinic and to be editable by anyone is great. Plus, it is great because you can dynamically add new pages on the fly. In fact, I plan on using it for all of our documented policies and procedures.

I found a really good article detailing the various wikis. I think that I’m going to try out the one that powers Wikipedia, Media Wiki. Anyone else have thoughts on how to do this?

I brought in the director of the health center to take a look at the single sign on. I opened my EMR application and it pretty much goes straight into the application. The director of the health center pulled one of those “Ohhh!” because she was surprised at how quick it was.

I showed one of the front desk personnel and she said, “When do we get that?” As soon as possible was my answer.

I just can’t get over how smart it is. Continuous authentication is the best type of security you can have on your PC. Facial recognition constantly is looking for your face and making sure that you haven’t left. It’s the very best feature.

I only have one more thing I have to get working properly and we’ll be putting into our clinical environment. We have to still make it so that two people can use the computer. Too bad our application isn’t browser based because then it wouldn’t be an issue at all. Unfortunately, my application is in VB and so there’s a little more programming to get the facial recognition software to logoff the application if someone forgot to do that.

I’ll let you know once I have it in the clinic.

-Password enabled screen savers

-Disclosure Notice at Windows Login

-Logged off after 25 minutes

-Adware/Spyware

-Windows Update

-Updated virus software

· Weekly workstation scans of local hard drives;

· Daily checks for updates to their virus definition files.

Anyone have suggestions for things that I’m missing? I think there are a ton of other Windows options that I’d like to have done but aren’t necessarily HIPAA requirements. I just need some more time to do some more research into what you have to do to the workstation to make the Windows policies persist across users. In my counseling center I found the options for disabling the recycle bin and the automatic logoff also.

Also, does anyone have a good disclosure notice that they use when the computer starts up? Is it even necessary? They seem mostly useless, but all the HIPAA documents I’ve seen suggest it. Is it a legal requirement because they could argue you never told them not to use it?

Today they issued pricing on their FastAccess product that is very reasonable compared to other biometric devices. I’ve attached the release below and here’s a short review of the product with certainly more details to come as I continue to use it.

Setup
Setting up the FastAccess was a piece of cake. I got the box with only 15 minutes before I had to be somewhere. I unboxed the product, read the instructions(yes I always feel I must read the instructions on new products) and installed it on my computer. In 15 minutes I had it recognize my face and automatically log me in. The other nice part is that the set was really nothing but plug the camera in and run the CD install file. On restart it starts learning who you are when you log in. Couldn’t have been simpler. I repeated this process on my laptop so I could show my wife and had it set up in 5 minutes(booting my computer took longer than setup).

Facial Recognition/Training
Training facial recognition is much different than other biometrics. Fingerprint biometrics requires you to “train” it to know your fingerprint. Facial recognition(at least with FastAccess) is continually updating every time you login. In fact, it stores 90-100 different biometric “faces” that identify you. The biggest fault with this model is that initially the recognition is poorer than fingerprint recognition. However, with time I’ve seen that it actually is more reliable and recognizes you quicker than fingerprint. Not to mention it recognizes you just coming into view. No need to reach and hold your finger or eye to something. The lazy part of me loves that.

Active Directory Integration
FastAccess has very nice integration with active directory. The best part is that they have two methods of implementing active directory integration. First, they can extend the active directory schema. While this is a common practice, it is difficult to convince my system administrator to do since it can’t be rolled back if we decide we don’t want to do it anymore. Second, FastAccess can be implemented using existing active directory fields. This means that you can test the active directory implementation without extending the schema. I plan on doing this in the near future and you can expect a review of it soon.

Strong Audit Controls
Looking over the audit logs they are pretty standard for what you would need to satisfy HIPAA. Having active directory manage this type of audit control would be key to me.

Continuous Security
The biggest advantage to facial recognition is that it is continuously verifying your access. My biggest problem with fingerprint biometrics had to do with not having a way to easily lock the workstation. Facial recognition biometrics is constantly monitoring to see you are the authorized person. If you leave then it locks the computer. This really changes the way you deal with authentication since it can create a true single sign on.

Security Screen Capture
This idea is inegnious. Since you have a camera you might as well capture a picture of the person that was signed on to a machine. Imagine them saying they didn’t log in and you can show them the picture taken when they did log in. Fantastic!! There is also talk of using this technology as a digital signature. I’d love that with my EMR.

Pictures and Twins
I tried to see what I could do to fool the camera and nothing really worked. I imagine this is theoretically possible, but it would have to be a picture in the exact same place as the biometric match. FastAccess tells me that they add in environmental variables(such as light) which makes it much more difficult to fool. So far so good. The idea of twins is addressed in the documentation. I’ll be testing it on my wife and her twin sister to see how that goes. Sometimes it freaks me out how much they look alike.

Accuracy
In an EMR or healthcare environment FastAccess has designed it properly. Sometimes it didn’t recognize me and so it required me to enter my password and then after logging in, it stores another biometric image. While this could be annoying to some doctors, I see this as an essential key to proper authentication.

Instant Desktop Switching
This seems like it is a somewhat new module being developed by Sensible Vision. The idea is that multiple people can log in to the same account and have a different desktop. This currently works espescially well with Internet Explorer and a few other selected applications. I imagine this list will grow over time. They offered to make it work for my favorite apps. One interesting note is that they have it working for Cerner’s EMR. I’ll be having them develop it for Medicat EMR(my EMR)

Random Points
Since FastAccess is constantly checking for facial recognition, when you answer the phone that changes what your face looks like. This isn’t really a problem since they store 90-100 different biometric “prints”. You just have to “train” it to know what you look like with a phone in hand.

One nice feature is that you can turn off continuous facial recognition when you have a presentation. It lets you disable the recognition for a specified period of time. It also recognizes any keyboard or mouse input and disables locking when it sees either.

Here’s the Press Release:
Sensible Vision Innovates Biometric Facial Recognition for Continuous Computer Access Control and Authentication

FastAccess Virtually Eliminates Passwords, Makes Computer Easier to Use and Ensures Privacy Compliance and Identity Management

Introductory Pricing of $99 per Desktop License

Covert, Michigan, April 3, 2006 – Sensible Vision, an innovator of continuous authentication solutions, today revolutionized computer access control and authentication by replacing a user’s password with their face. Sensible Vision’s FastAccess™ is a powerful yet simple solution that uses patent-pending biometric facial recognition to automatically and continuously authenticate user log-in and instantly secure the computer when the user leaves. This virtually eliminates login passwords, makes the computer significantly more secure and easier to use, and strengthens access control auditing for privacy and identity management policies.

“Because a person’s face is unique and always with them, it is ultimately the ideal password and the best way of continuously ensuring who is accessing the computer,” said George Brostoff, CEO of Sensible Vision. “This is a new paradigm for secure and simplified computer access that goes well beyond initial log-in and inactivity timers. FastAccess identifies and authenticates users in less time than it takes to enter a password and knows the second they leave their computers. These breakthroughs make it a simple, secure and low-cost approach for securing the computer and network.”

Automatic Authentication and Continuous Access Control

Sensible Vision has innovated biometric facial recognition to provide a convenient and fast way to securely submit a user’s account credentials to Windows and applications. Users simply approach the computer equipped with a standard web camera, and FastAccess biometrically authenticates them and logs them on. Once they step away, the computer automatically secures. When they return, FastAccess automatically unlocks the computer and their desktop is returned as they left it. Advantages include:

* No More Passwords, Better User Productivity: Users focus on their jobs rather than time-consuming and frustrating processes of constantly entering passwords 20, 50 or 70 times a day.
* No More Unsecured, Unattended Computers: Computers instantly secure when users leave.
* Improved Access Control and Auditing: Provides an accurate audit of computer access for privacy and compliance – a true audit log of who’s been at the computer and when.
* Simple Setup and Administration: Unlike other security and biometric solutions, no special enrollment procedures or ad ministration is required to distribute and manage ongoing support for lost or damaged tokens. Administrators can configure FastAccess locally or remotely through Microsoft’s Active Directory or Novell eDirectory.
* Support for Shared Computers: FastAccess features Instant Desktop Switching for multiple users who need quick access to shared workstations, such as in healthcare and manufacturing environments. Access is granted to each user almost instantly, without the usual delay logging into the network account.

Optimizing Productivity and Security

“It’s imperative for security solutions to complement user workflows and mitigate interruptions while simultaneously meeting the most stringent tests for identity, privacy and regulatory compliance,” said Rob Alger, director of IT strategy at Kaiser Permanente and Sensible Vision Technical Advisory Board member. “By guarding computer access from log-in until users walk away , Sensible Vision is addressing a critical hurdle in persistent data protection and access control that optimizes user workflow and productivity.”

FastAccess has innovated facial recognition with its patent pending Continuous Adaptive Sensing™ (CAS) technology to provide fast and accurate recognition to a computer. CAS takes a dramatically different approach to facial recognition than traditional solutions targeted at homeland security. FastAccess sets a much higher standard for accuracy. While most existing facial recognition technologies have false acceptance rates of several in 100 matches, CAS typically achieves a false acceptance rate of several in 1,000,000 matches. FastAccess accuracy is superior to existing security solutions where passwords are written down, shared or easily guessed.

“Minimizing disruptive computer login procedures continues to be a pain point for organizations,” said Cyrus Azar, CTO of Sensible Vision. “Passwords are difficult to enforce and ineffective in practice. Tokens can be shared or lost while previous biometrics have proven expensive, inconvenient to use or unreliable. Most importantly, none of these approaches offers continuous security: they simply authenticate the user at initial login. Not only does FastAccess simplify user access, but, finally IT staff can spend less time on administering security processes and focus on other critical business tasks.”

Introductory Pricing & System Requirements

FastAccess is comprised of client software installed on the PC, a standard web camera, and a management application installed on a domain controller. The client software can be part of an organization’s standard image and can be automatically distributed to remote PCs via existing software management tools.

Sensible Vision announced today special introductory pricing for FastAccess of $99 per desktop license through June 30, 2006. FastAccess may also be purchased under a service-based model with a two-year subscription price of $49/year for each license. Web cameras are also available for $25.00.

About Sensible Vision

Headquartered in Covert, Michigan, Sensible Vision Inc. (www.sensiblevision.com) is an emerging provider of continuous access control solutions for securing computers using facial recognition. Sensible Vision’s flagship product, FastAccess™, is an insider firewall that provides quick and continuous authentication and access control for computers and workstations. Using patent-pending biometric facial recognition, it speeds and simplifies access to the computer in a way that is economical and easy to deploy.

One other really nice feature with biometrics security is that you can choose to restrict people from using a password to get into certain programs. While this could be scary if something happens to the biometrics device it is an interesting concept. Since it is all managed by group policy in active directory I could train my end users on just using their fingerprints and never having them know their password(see below for password change policy). I would of course want to be able to use a password or biometrics, but there might be a few cases where you could literally restrict access to EMR to a fingerprint. Now that’s security!

Password Change Policy
One other impressive feature that I had never considered is how does biometrics handle the wonderful password change policies required by HIPAA? It’s not like your fingerprint can be changed. The units I’m testing can take care of this for you as part of the templates you create for each application. In fact, if you don’t want to have users know the password at all you can even have the biometrics software generate a password. I think this might be a little scary since then if the biometric device breaks or some other problem then you have no way of getting into your EMR program(or other application as desired).