Anyone that is part of the healthcare IT and EMR world has to realize that we’re in a really incredible time for healthcare IT and EMR. There’s has never been more energy, excitement and actual investment in the Healthcare IT world than there is now. If you don’t believe me, buy your ticket to Las Vegas and attend HIMSS 2012 and I’m sure you’ll see what I mean. I have a feeling that HIMSS Las Vegas is going to be bigger than ever with more money flowing as well.

Just to provide a few examples of what’s happening, the prominent IT investor Esther Dyson has invested in 20 Health IT investments. That’s a whole lot of investment in healthcare IT. She obviously sees some real opportunities available at this time in health IT.

Another recent announcement was the recent batch of 15 Rock Health Startup companies. This is just one of at least 3 or 4 health focused incubators out there. Plus, the latest batch of health IT startup companies from Rock Health even has Neil Versel singing their praises after a previous not so glowing review of the health startup incubator (or health accelerator if you prefer).

One other thing that is easy to underestimate is the value that the US government is putting on supporting healthcare innovation through entrepreneurship. Normally I’m as skeptical as anyone in putting any sort of faith in government to produce results. I still think they have their hands tied in a lot of things, but I give a lot of credit to Aneesh Chopra, Todd Park and Farzad Mostashari for doing their very best to kick against the challenges of big government while enabling health entrepreneurs to be successful.

Priya Ramachandran wrote about an example of one initiative the government is putting forward to help entrepreneurs: Access to Public Health Data. Every time I hear someone talk about the data that’s available from these public repositories of health data, the entrepreneur inside of me kicks in with ideas on how to use that data for good.

It is a really tremendous time to be an entrepreneur in healthcare. I do think we still need a better platform for health IT startups to launch their products and get funding. I have a few ideas I’m working on in this regard. More on this in the future.

The following is part of an email interaction I had with an EHR vendor about the future of CCD. Of course, I can never let strong opinions go unpublished. So I asked if I could put this on my site. I have a feeling there will be many people who have a different view of CCD and how these standards will play out. I’d certainly be happy to publish an opposing view as well. My contact page is here. I’m interested to hear other view points on the subject.

Stage 1 MU allowed either CCR or CCD. Stage 2, and the short term efforts will require CCD. The jury is still out on what Stage 3 of MU will focus upon. Many at the ONC can see that the CCD will never have the flexibility to deliver. These are largely the same people that facilitated the Direct Project initiatives.

I still predict that it is inevitable that the data will become uncoupled from unwieldy, anachronistic document structures. That will be the only means to get to true information portability that can deliver patient-centric use of the information. The CCD will still be around for a while to come, just as CD’s are still around for music sharing. For now, we have to have the CCD to preserve legacy, industry-centric control of the information.

John Halamka has a couple of recent posts that do a good job of explaining what is evolving…. http://geekdoctor.blogspot.com/2011/09/september-hit-standards-committee.html and http://geekdoctor.blogspot.com/2011/10/cool-technology-of-week.html . Both of these contain links to some very interesting information. When the ONC proceeded to issue an advanced notice of rulemaking, the industry power elites became enraged. http://www.ihealthbeat.org/articles/2011/9/22/groups-urge-onc-not-to-include-metadata-standards-in-stage-2.aspx

Technology delivering to patients will eventually win out just as the open-platform WWW won out over proprietary CompuServe. http://www.healthdatamanagement.com/news/onc-metadata-ehr-meaningful-use-43021-1.html Once we have a means to truly exchange the content without the overhead associated with the CCD/RIM crap, we will see a revolution in healthcare similar to the social networking phenomenon.

Again, the whole CCD/CDA will stick around to support legacy information needs, but it will eventually be largely eclipsed by more straight-forward solutions that don’t require a team of consultants and IT engineers to implement.

Today I thought I’d cover some feedback and comments that have recently been posted on some of my previous posts. Some are feedback for ONC on meaningful use. Another suggests that more of us get involved in the meaningful use rule making process. These comments and others that I’ve ready have me wondering if I and others of my readers should be playing a more active role in helping form the meaningful use criteria.

As is evidenced by the 60 Minutes interview with Jack Abramoff last night, there’s so much messed up about Washington and the legislative process. I guess I partially see that with meaningful use and the HITECH Act and I’m sure there’s plenty more happening in Washington DC that I don’t know about.

The problem I see is that the ones interested in being actively engaged in the rule making process are those that have the most financial benefit to gain. Certainly all of us have some reason to care how our government spends money and particularly the health of our healthcare system. Unfortunately, financial benefit seems to be a much stronger motivating force to participate than the greater good.

Look at it this way. If I’m an EHR vendor that’s going to have to comply with meaningful use and use it and EMR certification to sale my product, then I have a reason to pay for someone to fly to Washington DC and be involved in the process. I could even make some reasonable argument for me as an EHR and healthcare IT blogger to make the journey to Capitol Hill to talk about what’s happening. In fact, I’m going to be in DC in December, but I’m not going there to help improve meaningful use. The idea of getting ONC and CMS or other members in Washington DC to talk with me about meaningful use and the HITECH act sounds daunting and I’m not sure it’s worth the effort for a one time event.

Does that basically mean that ONC and CMS are listening mostly to those who have a vested financial interest in meaningful use and certified EHRs?

I like many others would likely be happy to share our voice in the meaningful use stage 2 creation process. It just feels so hard to participate and with little confidence that our voice will be heard above those who are paying a lot more to have their voice played over a proverbial loud speaker. I’m sure most doctors feel this same way. Although, Dr. Koriwchak over at Wired EMR Practice was in Washington DC this last week. I’ll be interested to hear more details on his visit, but I think his visit came as part of a larger health organization. Evan Steele of SRSsoft has a good post requesting other medical organizations become more involved in the meaningful use process. Could they be an independent voice for the physicians they represent?

Enough ranting about the challenge of working with the government to shape policy. Although, a comment from Anthony Subbiah was what prompted my reaction above. The following are Anthony’s comments from my Small EHR Vendor and Specialty EHR post suggesting that EHR vendors get more involved in the process:

As a vendor who works with ONC, and having gotten to know them better, they do have the greater good in mind; and some of these hurdles are un-intended and un-foreseen. The Phase II of the meaningful use requirements are in pilot and this is a good time for the EHR vendors to work with ONC and point out the flaws which ONC will graciously accept and review. It has been interesting working with ONC and understanding their thought process goes a long way in positioning and requesting exemptions. Key here is for the EHR vendors to spend the time and effort and work with ONC helping to meet their objectives.
On another note, while reducing the expenses is the goal, its more about the reduction of wastefull expenses which is being targeted to get the healthcare costs under control.
…
ONC maintains an extensive directory and blog of what they do at WIKI and any company interested can join. In order to realize value, the companies interested should be able to dedicate one or two senior resources towards this; there are many pilots that go on related to MU Phase II; the EMR companies can participate in the Pilots, provide their inputs and the ONC group is more than willing to listen. Actually, this is a great group of people to work with and they take the input and integrate that within the initiatives framework. We do not participate in all the Pilots – we are participating in two of them currently.
I believe its better to participate and shape the outcome as opposed to sitting on the sidelines and later on finding fault in such initiatives…………..

Here’s a link to the Wiki that Anthony mentions.

The other comment that prompted this post was a comment made by Julie Lundberg about the meaningful use smoking status requirement:

In an attempt to improve ‘Usability” we are trying to build a smoking status that will satisfy both the Core Measure (which requires CDC smoking status categories) and CQMs (which require SnoMed codes). There is no 1-1 relationship between the 2 lists. In fact, the CDC list makes no distinction between a “Light” cigarette smoker (1-9 cigs/day) and a “Very Heavy” cigarette smoker (40+ cigs/day). Both would be considered a “Current every day smoker”. We can obviously gain this granularity with SnoMed codes but this makes the task more onerous for the provider to capture (selecting from 2 lists of “descriptions”). Let’s give the Providers 1 smoking status to fit all requirements.

It’s an interesting question for which I don’t have the answer to which feels odd since I feel that I’m reasonably well versed with meaningful use and the creation of the meaningful use creation process. The only way to know the answer to this is to have been intimately involved in the creation process in Washington. Something no doctor that sees patients daily can really do.

I love that Julie was willing to offer her suggestion on my EMR blog. Plus, I know that a number of people from ONC read this site, so I’m hopeful that now that I’ve posted Julie’s comment it will get more traction from the people in Washington. However, I still feel there needs to be an easier way for those who can’t spend their days following the latest meaningful use happenings in Washington DC to have their voice heard in the process. Then, they wouldn’t have to resort to blogs like mine to provide comments.

I’m open to other suggestions on how regular people can get involved in the process. Maybe my personal fear of involvement is that I want to actually effect change on something I’m involved in. It seems like casual involvement in the process isn’t enough to be heard. I guess that’s the problem when you want what you said to be meaningful (ie. actually heard and used).

Today at MGMA, Fujitsu together with Osmosyz announced a new scanner that supports the relatively new CDA “Unstructured Document” HL7 standard at MGMA 2011. I must admit that the press release is a little intense. However, I find what they’re doing with a hardware product to support HIE is quite interesting.

I don’t want the title of this post to be misleading. While certainly HIE has generally become synonymous with some large health information exchange entity, in this case I’m describing a hardware device (a smart scanner if you will) that acts as a small health information exchange. Basically, it’s more along the lines of Direct Project as opposed to NHIN. Although, I imagine that it could send the documents to some larger health information exchange if someone wanted to do so.

The larger application I see of this technology is as a replacement for the fax machine. In some ways, it’s like a second generation fax machine. The major differentiation I see between a document sent using the CDA “Unstructured Document” HL7 standard and a fax is all the meta data that comes with the CDA document.

The fax or scanning workflow for most EHR software consists of receiving faxed documents or scanning documents into what amounts to basically a bucket of all the scanned documents. Then, it’s up to the user to go in and sort through all the various faxes that have been received or documents that have been scanned. At this point, the user can assign the document to a patient in the EHR. You can imagine the challenges that this can pose. I wonder how many documents scanned or faxed into an EHR have been assigned to the wrong patient accidentally.

That’s what makes this new Fujitsu scanner quite interesting. If it’s receiving the document from an outside source, it will come with the meta information for the document as part of the CDA standard. That can then be leveraged to more quickly assign that document to the patient. Not to mention, then all of that CDA information is available for other uses within the EHR.

For inside documents that are scanned in through the Fujitsu device you can actually assign the document to a patient on the scanner itself. That’s right, you can identify which patient a scanned document belongs to while you’re holding the document in your hand. A much better way to ensure that the document you scanned gets attached to the right patient in your EHR.

I’m just touching on a few of the features of what’s possible with this new Smart Scanner from Fujitsu and smart documents. You can do other things on the scanner like dividing document scans between multiple patients.

Meaningful Use Monday Angle
Of course, as most of you know, on Monday we usually do our regular Meaningful Use Monday series. Turns out that the CDA Clinical Document standard that I discuss above is being adopted by ONC as part of meaningful use. I’ll be interested to see how this plays out over time, but don’t be surprised if EHR software has to support this standard in the future.

What I find more intriguing is that the above scanner could be used by someone who doesn’t have an EHR, but wants to exchange patient information. I still think that the long term solution to interoperability of patient information has got to come from connections with EHR software. However, this does illustrate that technology solutions can and will be created to exchange health information. In fact, some combination of these solutions could be a way to meet some of the meaningful use requirements around exchange of health information. You still can’t get the EHR stimulus money without an EHR, but technologies like this could help you achieve meaningful use.

I’ll keep an eye on how this technology progresses. I wonder how many EHR vendors will integrate with this type of technology. Whether we like it or not, documents are going to be a major part of healthcare for the foreseeable future. We’ll see if smart documents and smart scanners are an intermediate step to the health information exchange nirvana (whatever that might be).

LinuxMedNews just posted the announcement that OpenEMR is now a certified EHR. Here’s the quote from their announcement:

It’s official! OpenEMR has passed all ONC certification tests as a fully qualified emr that can be used to attest for incentive moneys. The official posting: http://onc-chpl.force.com/ehrcert/EHRProductDetail?id=a0X30000003mNwTEAU&retURL= appeared on the website 2011/08/19. Congratulations to all involved! OpenEMR 4.1 should be ready for download in a few weeks.

This is a really big announcement for the open source ambulatory EHR community. A number of other open source EHR are certified, but they’re mostly for the hospital EHR space. So, it’s a great thing for OpenEMR to provide an open source EHR to the ambulatory space.

Plus, I have to admit that it’s pretty great that an open source community can pull together the funds to actually be certified. The programming and development time is one thing, but getting the $20-30k to be certified is a big deal that I’m sure took a lot of effort. I actually wish I knew more about the process they used to achieve the EHR certification.

Now, OpenEMR users better start digging into resources like Meaningful Use Mondays. EHR Certification is the first step, but showing meaningful use of that certified EHR is the next one.

Big thanks to an avid follower of OpenEMR – Jojo the HITMAN who informed me of the news.

You’ve undoubtedly heard the argument before: EHR certification is about assuring that systems meet minimum requirements for functionality and interoperability, but the certification process falls way short in terms of usability, privacy and security. But have you heard the argument from one of the ONC-authorized certification bodies?

This is an excerpt from an e-mail I received today:

Meaningful Use criteria have become a massive EHR certification driver for healthcare organizations. Hospitals and other providers rely on the criteria to ensure that their health IT systems meet minimum government-specified functionality and interoperability requirements to support Stage 1 of Meaningful Use.  Achieving Meaningful Use also ensures a health care organization qualifies for reimbursement under the American Recovery and Reinvestment Act as a way to incent adoption of e-health processes among health organizations. The ultimate goal is to improve our nation’s healthcare system by leveraging technology to allow greater access to important health information and empower patients to securely access their own health information.

However, as one of only five organizations authorized to test both complete and modular EHRs by the Office of the National Coordinator (ONC) for Health IT, ICSA Labs questions whether EHR certifications are enough as the criteria represents only minimum requirements. Amit Trivedi, healthcare program manager at ICSA Labs, believes providers should take further steps to heighten the security and privacy of their health IT systems. He also suggests vendors should look beyond the current regulations to address and improve usability, data portability, and information exchange in their products.

That’s right, ICSA Labs, one of five organizations currently authorized to test and certify complete EHRs on behalf of the Office of the National Coordinator for Health Information Technology, seems to think that the standards it tests EHRs against are inadequate, which is something that critics of certification—particularly critics of the Certification Commission for Healthcare Information Technology—have been saying for years. Critics of many of the larger vendors have been saying that, too. But it’s shockingly refreshing to hear this from an actual certification body.

In fact, the publicist for ICSA, a unit of Verizon Business, has offered interviews with executives of two lesser-known vendors,  Health System Technology and Design Clinicals, to talk about how they are going beyond the minimum certification requirements. Deadlines beckon, so I didn’t really have time to wait for the publicist to try to find me an schedule opening for one of the executives, but here’s a statement from a March 30 ICSA press release that is somewhat telling:

“This year we are expanding our certification programs into health IT, a much-needed area of focus to help modernize today’s health care system,” said George Japak, managing director for ICSA Labs. “With our new focus on safeguarding patient information within electronic health records, we are committed to helping accelerate the adoption of health IT.”

We don’t hear too much about security in the context of certification from too many other camps, so it’s nice to hear that at least one certification organization is critical of the rules it is under contract to follow. Perhaps we’ll see tougher usability, privacy and security standards in the permanent certification program ONC needs to have in place by the beginning of 2012 to support the forthcoming Stage 2 “meaningful use” requirements from CMS.

Wishful thinking?

Probably unintentionally, it seems like various HHS branches are playing good cop-bad cop right now.

I’m in Ojai, Calif., right now (please don’t hate me because of it) for the annual Association of Medical Directors of Information Systems (AMDIS) Physician-Computer Connection meeting, a gathering of chief medical information officers and others in the field of what AMDIS likes to call applied medical informatics. That contrasts with the American Medical Informatics Association (AMIA), which tends to draw more from the academic side.

The Office of the National Coordinator for Health Information Technology (ONC) apparently is the good cop. National health IT coordinator Dr. Farzad Mostashari was unable to make it out here from Washington, but he addressed the gathering by telephone. Unfortunately, he called into a cell phone hooked up to the PA system in a room already suffering from poor cellular coverage, so some of his words were clipped. But a few things were clear.

Mostashari indicated that he was in favor of delaying the start of Stage 2 of “meaningful use” to 2014, even for those who meet Stage 1 requirements this year. That’s the recommendation that the Health IT Policy Committee made to him a couple of weeks ago. Furthermore, if CMS approves the delay—CMS is producing and administering the EMR incentive program—Mostashari said that providers will be able to earn three years of Medicare and/or Medicaid bonus payments, not just two years’ worth, prior to the start of Stage 2.

That, not surprisingly, elicited some smiles and nodding from attendees. Mostashari, himself a medical informatics veteran with a primary care and public-health slant, played to the crowd by pointing out how health IT is accelerating real reform of American healthcare—not just an expansion of insurance coverage that to me is just throwing more money at a broken system. “We’re moving away from the fee-for-service model comfortably faster than we had anticipated,” he said.

Meanwhile, CMS came off looking like the bad guy, at least in contrast to ONC.

The agency already is taking a lot of heat from many parts of the healthcare world, which has heaped tons of criticism on the proposed Accountable Care Organizations rule. Just after Mostashari’s session, Ethan Moore, a health IT and HITECH Act specialist at CMS, hosted an update on the Medicare and Medicaid agency’s efforts in health IT, which included two other CMS technical specialists calling in on the phone.

One of the callers delivered a disheartening message to the 200 or so informaticists present: the Oct. 1, 2013, deadline to convert to ICD-10 coding is “firm.” That may not have surprised anyone, but it certainly seemed disappointing, given that there’s probably going to be more time available to achieve later stages of meaningful use.

Moore also showed slides that walked through the online application for attesting to meaningful use. Moore was an engaging speaker, albeit not as enthusiastic as Mostashari, but a lot of eyes still glazed over. Blame it either on the relatively early hour if you want, but I think it had more to do with the bureaucratic nature of the process. I suppose there isn’t much anyone can do about that. If there is, I’d love to know exactly what.

This is the second in a series of EMR and EHR interviews that will be done on EMR and HIPAA and EMR and EHR. The full EMR interview with Dr. Muir can be found on the new EHR and EMR interviews website. The following is a summary of that interview written by Kathy Bongiovi.

If you’re a doctor, nurse, practice manager, EHR consultant, CEO or executive of an EHR vendor, etc with EMR experience that’s interested in being interviewed, let us know on our http://www.emrandehr.com/contact-us/“>Contact Us page.

Dr. Peter Muir of Springfield Center for Family Medicine was interviewed recently concerning his acquisition of the maximum Medicare Incentive for showing Meaningful Use of a Certified EHR. The Ohio based primary care practice has been using NextGen Ambulatory since 2003 and NextGen Management since 2006.

Dr. Muir stated that their practice chose NextGen EHR because the company focused on clinical offices. Dr. Muir and NextGen EHR share the philosophy of always searching for ways to improve the product. Dr. Muir not only believes in this philosophy but also attended a development think tank along these lines at NextGen’s headquarters. He was also drawn to NextGen because he wanted the capability of customizing his templates.

Having demographics, scheduling, clinical and billing information all on one database has had a huge impact on Muir’s practice. He feels that having a centralized database “makes reporting much easier and more comprehensive than those EHRs with separate databases or separate vendors”. The doctor admitted the conversion from paper charts to EHR was stressful for the first year but well worth it in the long run.

Since Muir’s office has been using EHRs (since 2003), there have been relatively few changes needed for Meaningful Use and any required upgrades to the system came as part of the standard NextGen maintenance fees. There was data that had to be added which was not normally collected by his practice as it had little relevance to his patients but from the patients’ perspective, there was no change in the attention patients received from Springfield Center.

The family practitioner Muir credits the CMS web site and NextGen Healthcare for not only the upgrades to their EHR software but also for their pathway documents and webinars which helped them show meaningful use. He also credits GBS of Youngstown, Ohio (his NextGen vendor for hardware, software) who also helped them implement security upgrades in 2010 in anticipation of the process.

Additionally, being a part of the ONC Meaningful Use Vanguard Program was a benefit to Dr. Muir because “it provides recognition which may allow a greater input in system design and operation.” Muir is concerned, though, that the Program’s flow of information may be difficult if multiple database silos remain in service and a lack of standardization isn’t addressed.

Especially with respect to Meaningful Use Stages 2 and 3, the doctor believes it is critical to have professional health providers utilizing some form of regional system – versus individual systems – in order to have a seamless flow of information. Muir has begun such a system within his own state of Ohio.

The doctor was intricately involved in starting CCHIE (Collaborating Communities Health Information Exchange) in Springfield, Ohio. CCHIE chose HealthBridge as their data engine and together they have partnered with other healthcare providers to provide electronic access to patients’ lab and radiology results as well as to admissions, discharges and transfer information. They have added regions in Southern Indiana and two regions in Northern Kentucky.

Dr. Muir’s advice to fellow doctors is that unless they are planning to retire within the next couple of years they should not delay in the implementation of an EHR. The longer they wait, the more difficult and time consuming the transition will be because, with time, the activities of daily practice will be much broader and more demanding. Additionally, he suggests providers select a system that does not just meet Meaningful Use requirements. His advice is to “select a system that assists you in providing better medical care”.

Read the full transcript of Dr. Muir’s interview.

As much as I’d like to visit DC (I’ve never been), I wasn’t able to make it out there to attend the NIST workshop on EHR usability. However, Carl Bergman from EHR Selector did make it to the event and sent the following notes on EHR usability according to NIST.  Most of the speakers name link to their slides in PDF format.

National Institute of Standard and Technology’s Workshop on EHR Usability

This week I went to a NIST workshop examining the state of EHR usability. The workshop was at its administrative headquarters, a large 60s building on its sprawling Gaithersburg, MD campus about 20 miles outside Washington.

You might wonder what NIST is doing in the EHR business? I certainly did. NIST’s mission is to promote commerce and technical innovation including methods to determine, independently, the safety and security of a broad range of technologies including software. (It’s part of the Department of Commerce.) Since WW II, this has involved looking at the human factors involved in operation of every thing from nuclear plants to robotics. Interestingly, it’s not a regulatory agency, such as, the FDA or FCC. NIST’s standards work is through consensus building among manufacturers, consumers, regulators, etc.

The workshop, attended by about 200 persons, had two parts:

•      A review of the state of EHR usability studies by academics, practioners and system administrators and,

•      Introduction of NIST’s draft for a usability standard.

Part I. EHR Usability Today. There were many speakers, here’re the ones that had the most new information for me:

•      Mat Quinn of NIST covered its approach and work with ONC on the issue. Notably, NIST has published several documents in the area such as, NIST Guide to the Processes Approach for Improving the Usability of Electronic Health Records, (NISTIR 7741) which promotes a user centric approach to design and development.

•      I was really taken by Muhammad Walji’s study using a unified framework for EHR testing. The study compared user experience with the VA’s Vista program and a prototype system. It looked at:

o   What percent of an operation was substantive and what was overhead?

o   How long it took users to reach various performance levels.

o   How much memorization tasks took.

o   How many steps tasks required.

o   Error and recovery occurrence.

o   Time to complete defined tasks.

The study then applied its findings to rework the EHRs’ structure and workflow showing potential time and effort savings.

•      Anjum Chagpar of Toronto’s University Health Network. A human factors manager for this large healthcare network, she discussed the problems of integrating various vendor products into their system and their approach to usability and user satisfaction.

•      Buckminster Fuller famously declared, “I am a verb.” Dr. Lyle Berkowitz may not be a verb, but he is at least a gerund. His presentation swiftly covered several topics from HIMSS’ EHR Usability Task Force to usability definitions to stakeholder roles, and applying metrics to see how much of the problem was the system and how much the user.

•      The VA’s Dr. Jorge Ferrer provided several key references on usability studies.

Part II. NIST’s Proposed Protocol. If the first part took a broad and free ranging approach to usability, NIST’s staff approach was more focused. After an outline of the study’s setting and approach, the study director, Lana Lowery, outlined the protocol’s goal: prevention of unacceptable medical errors. These include errors of both omission and commission, for example:

•      Writing an order for the wrong patient.

•      Prescribing the wrong dosage.

•      Omitted information causing an error.

•      Critical delays in delivery due to system design errors.

•      Errors due to incorrect sequencing of actions.

Next, came examples of EHRs allowing errors. Unfortunately, several of the examples weren’t well thought out. For example, a patient ID error showed two patient records on the screen. One had the first patient’s x-ray, but the second patient’s name. Most likely, this would be a database problem or an x-ray production error not an EHR problem.

Robert Schumacher of User Centric, outlined how the protocol would be tested. For example, review and update of a problem list or replacement of one medication with another. The plan included testing several of ONC’s meaningful use functions that had usability factors.

Part III. Workshop Reactions. The workshop finally broke into two discussion groups: one for the draft protocol and the other on consensus building. In both cases, the discussion quickly went off script. Participants were quick to criticize the staff’s error oriented protocol as too narrow. Why, for example, did the protocol focus on internal EHR processes to the exclusion of workflow generated errors?

I understand NIST has a high interest in eliminating catastrophic errors, but I think there is not enough solid evidence on the kind and extent of the problem. No one discounts the need to prevent catastrophic errors, however, much of the EHR error focus is due to anecdotal reports of computer prescribing errors. From what I read, many of these reports are both old and recycled. Does anyone know the actual extent of major errors?

The FDA has developed several systems for dealing with medical device errors. These now include the software that the devices use. Even if the FDA does not regulate EHRs, it may step up its efforts to record important errors. I’d sure like to know FDA’s findings before I started an effort to shape EHRs.

This is not to say that safety is not important in EHRs, obviously the types of errors that are outlined by the staff are major. However, I think there are three points that are missing in the NIST approach:

•      Design for Success. You can’t design for failure. You have to design for success. The object of EHRs, as with any system, must be to accomplish certain ends. If you loose sight of that, you may not make mistakes, but you also will fail your objective.

•      Risk Analysis. Risk analysis measures the impact on a given population of an action, its potential and costs broadly defined. It also specifies mitigation efforts. I’d be far more comfortable about the protocol if there were a risk analysis behind it.

•      Error Handling. There should be more thought to error handling. For example, when the stall warning alarm goes off on a plane, it doesn’t grab the stick and take control. It’s a warning, just that. Physicians should be warned if they are about to prescribe beyond the recommended dose, but they may have good clinical reason to do it.

NIST put on a worthwhile workshop. My guess is that the draft protocol is not going to survive without modifications that take into account a broader range of usability issues and approaches.

Yesterday on EMR News, we posted about the first case I’ve seen where someone has collected EHR stimulus money after attesting to meaningful use.

It’s the day many have been waiting for. The first checks arrive for those showing meaningful use of a certified EHR (Medicaid had sent some EHR Stimulus checks previously). Yes, the government really is going to pay out the money. Yes, people really are getting paid. In fact, it seems that they’ve pretty much stuck to their schedule for meaningful use stage 1 and paying out the first EHR stimulus checks. Props to the people at CMS and ONC for being able to stick to that schedule (even if meaningful use stage 2 might be delayed).

I do have to say that an electronic bank transfer isn’t nearly as exciting as a check in the mail. Plus, a picture of someone checking their online banking isn’t as compelling as a picture of someone with a check. So, technology has hurt the visible image that would illustrate this occasion. However, the “shovel ready” ARRA stimulus money has started to flow (sorry I had to point out the irony of “shovel ready” or lack therof).

Since seeing the news, I’ve wondered whether the cash flowing will have the impact on doctors that one would expect. Will doctors start saying, “I want to get my EMR stimulus check!”? Certainly the cash has just started flowing and so we can’t fully assess the impact of these first checks. However, I personally think that the cash flowing will provide little momentum to EHR adoption.

First, from those I interact with, there aren’t that many fence sitters. Most have already decided to do EMR or not to do EMR. The flow of money would be great to get the fence sitters off the fence, but I don’t believe it’s strong enough to get those against EMR to finally go for it.

Second, the lack of certainty around meaningful use stage 2 and 3 is a major concern. Most people aren’t and shouldn’t be concerned with the payments for meaningful use stage 1 (unlike PQRI incentives). Why should they be? After all, it’s a self attestation process for meaningful use stage 1. Check the right check boxes and give them the right numbers and you get paid. However, the same certainty isn’t available around MU stage 2 and 3. We don’t know how it will be measured nor what it will include.

Third, it takes real time for the word of mouth discussions between doctors to disperse in the medical community. Will the message of stimulus money get out quickly enough for it to matter to most doctors who are mostly against an EHR?

It’s great to see the EHR stimulus money flowing. We’re still in a wonderful EHR and healthcare IT bubble that will continue for at least another couple years. However, EHR incentive money flowing isn’t going to contribute much to that bubble.