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Will Meaningful Use Stage 3 Continue to Kill EHR Innovation?

Posted on July 7, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In my recent post on EMR and HIPAA titled “The Current EHR Reality,” L Parada, a product manager at an EHR vendor, offered this insightful and scary comment:

Looking at the 137 proposed certification requirements for MU3, I again see all innovation in 2016 slipping through the fingers of all specialty EHR companies. That stings.

I’ve occasionally mentioned that we’re finally at a more stable place with meaningful use that EHR vendors might be able to have some breathing room to innovate. Is that time frame for innovation going to be limited to 2015? Will meaningful use stage 3 ruin EHR innovation in 2016? I also don’t think that it just applies to specialty EHR companies either. That many government requirements is going to kill innovation at every EHR company of every size.

This would make me really sad. I’m tired of writing blog posts about the lack of EHR innovation. Can we just let the 300 EHR vendors get to work on listening to their customers and doing some creative solutions to really improve the efficiency of healthcare and improve doctors’ outcomes?

I think we all might feel different if we thought that the meaningful use stage 3 requirements were innovative and really pushing forward amazing initiatives that were going to transform healthcare. I don’t know anyone who really feels that way. At best they see it as a good step forward towards some noble goals. Should we kill innovation in the entire EHR industry for that?

With meaningful use stage 3 around the corner, it’s starting to feel a lot like meaningful use groundhog day. Does it feel that way to anyone else?

Meaningful Use Stage 3 to Come Out Before HIMSS15?

Posted on March 11, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Madelyn Kearns from Medical Practice Insider is reporting that we might see meaningful use stage 3 regulations before HIMSS. Here’s the exact quote from Robert Anthony, deputy director of CMS’ quality measurement and health assessment group:

“We will have two regulations that will come out in time to discuss meaningful use”

It’s hard to imagine that one of these 2 regulations will not be meaningful use stage 3. No doubt CMS and ONC will want to get some feedback from the HIMSS community on meaningful use stage 3. What better place than at the conference?

Madelyn aptly points out that Robert Anthony already has one session scheduled at HIMSS to discuss the meaningful use stage 3 requirements. I have a feeling that is going to be one of the really well attended sessions. Especially if the MU stage 3 rule does come out before HIMSS.

I realize that CMS is bound by laws on when they can announce the various rules and regulations, but I hope they’ve planned out the timeline better than they’ve done in the past. My colleague Neil Versel at Meaningful Health IT News has regularly pointed out how the rules always seem to go public on a Friday. He’s hypothesized that it was the case that they were trying to hide something. I think that’s true for many Washington news stories, but I think it was coincidence in meaningful use’s case.

Even worse than a Friday is the Friday before HIMSS. Talk about ruining the weekend before HIMSS. Although, if I remember right one time they announced the rule in the middle of HIMSS. I remember meeting with a number of EHR vendor’s government relations people who were grumbling about the late night reading of the meaningful use rule that they’d be consuming all night in the middle of the craziness of HIMSS.

Hopefully CMS has learned from past experience and has planned properly to be able to announce the meaningful use stage 3 rule well before HIMSS. Doing so will give people time to look over the rule so they can have a meaningful discussion of the rule at HIMSS as opposed to some frenetic review of what’s been proposed.

Either way, I’m very interested to see what meaningful use stage 3 will look like. My prediction is that it won’t be dramatically different from stage 2. It will be more of the same with maybe 1-2 additions. It’s too bad, because I’d still love to see them blow up meaningful use. Every doctor I know would love to see that as well. Instead I think we’ll be saying “more of the same.”

Meaningful Use Is Dead?

Posted on January 29, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Over on EMR and HIPAA, I got the following passionate response on my post titled Meaningful Use Created A Big Need for Certified MAs that I thought many readers on this site would enjoy.

In the EP world, MU is dead. There are some larger groups, especially primary care still struggling to overcome the huge hurdles of MU2, but most I know have given up and running for the hills. There is a ginormous gap between what ONC is peddling in terms of numbers and real MU use.

This is good example of another hidden cost of trying to MU. We have some excellent MA’s, and I could not tell you which are and are not certified. Makes no difference. Sadly, CMS and ONC, do not realize that they are literally driving EPs from accepting Medicare patients, especially us specialists. And once we are gone, or severely limit new patients with Medicare, we are not coming back.

So the 17 times in 11 years fix for SGR, PQRS, VBM, MU, CPQ, ICD10, HIPAA, RAC audits, sequester cuts, etc. Its too much cost. clicking, paper work to take care of these patients. We actually had a serious discussion with our hospital about cutting back severely on doing Medicare total knees and hips next year due to all this. And the hospital initiated the conversation. So its not just us, even EHs are looking into this.

We all know that CMS and ONC want something, anything in terms of numbers to report anything to Congress, but this is the wrong way to do it. Again, everyone out there that is sitting in their cubicle Monday morning quarterbacking our care for these patients, will be very sad, very soon as we will just stop seeing them.

You can see by the numbers, if 250,000 EPs are taking the first MU hit this year, just wait until the rest give up. EPs can see that MU does not equate to better care, safer care, or more efficient care. We all may use an EHR, but could care less about attestations and audit risks and counting numerators/denominators forever. Again now that at least half the EPS are out, the rest will be right behind.

CMS and ONC need to realize that penalties NEVER work. Incentives like the heady days of MU1, got people to try EHR, but the costs are now piling up, big time. Everyone wants their piece of the pie. But as the incentives have gone away and the clerk like data entry has gone up, EPs have left the program. And are never, I mean never, coming back.

This provider makes an interesting assertion about meaningful use being dead. Do you think that MU is dead?

I thought this post’s timing was interesting given the announcement that CMS is changing the meaningful use stage 2 reporting period to 90 days. Correction…they intend to change it, but I think we all see that it’s going to happen. Just let the rule making process take it’s course.

Before this announcement, I would have largely agreed that meaningful use was pretty close to dead. I know some people have sifted through the meaningful use stage 2 attestations and have said it’s better than we thought, but I think those are the early birds and not the majority. With this announcement, I think the majority will take a much deeper look at taking on MU stage 2. If CMS can simplify some things, I could see many participating to get the incentive money, but to also avoid the penalties. Penalties aren’t the end all be all for doctors, but they represent a big chunk of money for many doctors.

I’d love to hear your thoughts. What are you seeing in the trenches?

Does Meaningful Use Inspire Innovative or Mediocre Systems?

Posted on December 12, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I was absolutely intrigued by Dr. Webster’s tweet about the impact of meaningful use (MU) and the types of systems it inspires. I think everyone would agree that MU has done nothing to inspire innovative EHR systems to be created and I think most would agree that it’s mostly fostered the creation of mediocre systems.

I’m not saying that meaningful use has no redeeming qualities. It definitely drove adoption of EHR software. Some of the meaningful use requirements like ePrescribing and CPOE were already moving forward for many organizations and meaningful use threw gas on those fires. I think those will turn out to be really beneficial components to meaningful use.

We could talk about the overall impact of MU (good or bad), but I’m not sure how productive of a conversation that would be. Meaningful Use is the reality of today. So, instead of focusing backwards on something we can’t change, I’m interested to think about what meaningful use could become. For all intents and purposes, that’s going to be called meaningful use stage 3 (unless ONC decides to spend time on a rebranding).

The key question: Could Meaningful Use inspire innovative EHRs and other innovative health IT?

While I’m skeptical of government regulation doing much for innovation, I think there’s a chance that this could happen. The key change will be that meaningful use needs to move away from its prescriptive approach and requirements. Innovation rarely comes from prescriptive approaches to anything.

Instead of being so prescriptive, meaningful use should focus on creating frameworks for which innovation can happen. My initial analysis of FHIR is that this is directionally right when it comes to inspiring innovation in healthcare IT. I need to dig into the details a bit more, but the concepts of creating an open framework for health IT companies to innovate on top of EHR data is what things like meaningful use should incentivize. Reimbursement should help to encourage this type of innovation. HIPAA should be clarified to support this type of innovation.

RHIR is just one example and I’m sure there are many others. It’s an open approach which encourages the right things while not damaging those for which it doesn’t make any sense. To me that’s the major difference between a prescriptive requirements list versus a framework oriented approach.

Do we really care that doctors game the system to be able to meet the 5% patient engagement requirement of meaningful use? What value does that provide the healthcare system if they’re not truly engaging? That’s too prescriptive. I’m all for patient engagement. Doctors are too. However, these prescriptive MU requirements just cause doctors to game the system as opposed to truly engage.

What do you think could be done with MU so that it inspires innovative EHRs instead of mediocre systems?

Meaningful Use Audits and the Inconsistent Appeals Process

Posted on November 6, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

If you haven’t had the pleasure of a meaningful use audit yet, consider yourself lucky. They are not pretty, but I’ve never met anyone who actually enjoys an audit. Turns out that meaningful use appeals are even worse than most audits. It’s likely because the meaningful use appeals process are so new and they haven’t figured out their processes. However, if you’re a clinic on the wrong side of a new process, that’s not much consolation.

Meaningful Use expert, Jim Tate, has a fascinating look into the inconsistency of meaningful use appeals. Here’s one story he shares that will kind of blow your mind (or at least annoy and scare you).

“Two Set of Rules”: You are not going to believe this one, but it is true. I was contacted last week by a large practice. Two of their physicians had failed audits. Both appealed and won with the statement from CMS: “This is the final determination notice regarding your recent appeal….Based on our review of your Appeal Filing Request, supporting documentation and the Program policies, we have accepted the documentation your provided to support your appeal. Therefore, CMS upholds your appeal.” Sounds great, doesn’t it? However, two months later they received this from CMS: “CMS has reopened the review of your appeal and supporting documentation along with others from your practice. The documentation provided….is unsufficient to support the appeal and CMS is reversing….the decision to uphold your appeal. As a result, the final CMS decision denies your appeal and upholds the adverse audit finding. This decision is not subject to further appeal.” Is it just me or it this a little bit on the crazy side? They received from CMS a “final determination” that their appeal was upheld and then two months were told the “final determination” was being undone, the appeal would now be denied and “this decision is not subject to further appeal.” Both of the letters were signed by the same CMS official. Is it just me or do we need a little sunlight on the inner workings of this process?

Jim is right that there should be a clear process for meaningful use audits and appeals. It’s interesting that Jim tried to go to DC to visit with CMS about the process. Unfortunately, his request was denied. There’s nothing worse than hitting a dead end and people aren’t willing to listen.

Hopefully CMS will hear this story and act. It’s not fair to any organization to get stuck in a bad process.

Karen DeSalvo Remains as National Coordinator of ONC Along with New Position

Posted on October 31, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In case you missed it, last week it was announced that Karen DeSalvo had been appointed Assistant Secretary of Health focused on Ebola by HHS Secretary Burwell. In that same announcement Jacob Reider also announced his departure from ONC.

While the news was true that DeSalvo was taking on a new role at HHS as Assistant Secretary of Health, ONC also published a blog post that DeSalvo would stay on as National Coordinator of Health IT as well:

Dr. DeSalvo will serve as Acting ASH while maintaining her leadership of ONC. Importantly, she will continue to work on high level policy issues at ONC, and ONC will follow the policy direction that she has set. She will remain the chair of the Health IT Policy Committee; she will continue to lead on the development and finalization of the Interoperability Roadmap; and she will remain involved in meaningful use policymaking. She will also continue to co-chair the HHS cross-departmental work on delivery system reform.

Lisa Lewis will provide day to day leadership at ONC. Lewis served as Acting Principal Deputy National Coordinator before Dr. DeSalvo joined ONC, so she has had experience with all parts of our work. She will lead our extremely talented and very strong team during Dr. DeSalvo’s deployment to the Office of the Assistant Secretary for Health.

But most importantly, the team that is ONC is far more than one or two leaders. The team of ONC is personified in each and every individual – all part of a steady ship and a strong and important part of HHS’ path toward delivery system reform and overall health improvement.

Seems like an awkward arrangement if you ask me. DeSalvo will be providing high level leadership on policy direction, but Lisa Lewis will handle the day to day leadership. That job description for DeSalvo sounds like something an Assistant Secretary of Health might do and Lisa Lewis’ job sounds like something the National Coordinator would do.

I’m sure there’s more to this story. Maybe moving DeSalvo to Assistant Secretary was a way for ONC to save money and keep DeSalvo on board working on healthcare IT. If ONC’s budget gets cut, then HHS still has a way to pay for DeSalvo. Maybe that’s why Lisa Lewis can’t be promoted to full National Coordinator. Then again, maybe it’s like I mentioned when we first heard the DeSalvo news, DeSalvo is more of a public health person than she is a healthcare IT person.

The fact that DeSalvo is remaining as National Coordinator is interesting. However, I just came back from CHIME (healthcare CIO conference) where DeSalvo was scheduled as one of the plenary session speakers. However, she didn’t show and so the whole session was cancelled. I guess you could make the case that she’s got Ebola to deal with right now, but it also illustrates how health IT will be playing second fiddle for her going forward. Likely says something about the future of ONC.

Meaningful Use #HITsm Twitter Chat

Posted on October 17, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I had the honor today to host the #HITsm Twitter chat. For those not familiar with the #HITsm chat, you just join every Friday at Noon ET and watch the tweets that are sent using the #HITsm hashtag. There are usually 4-5 questions that are discussed over the hour chat. Since I was the host, I created the questions this week. I chose to focus the chat on the latest happenings with meaningful use. The transcript of the chat is found here.

I just took a look at the stats for the chat on Symplur and saw that the chat had 68 participants that sent out 474 tweets which had 3,196,079 impressions. You have to be a little careful looking at impressions since that’s potential impressions, but it’s still interesting to consider the possible reach of a chat.

There were some really interesting tweets during the chat, so here are the questions and a few (ok, more than a few since I got carried away) of my favorite tweets: Read more..

Purpose of EHR Incentive Program According to CMS

Posted on September 9, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

When I was reading through the EHR Certification flexibility final rule, I found a really interesting part of the rule (pg.49-50) that describes what CMS sees as the purpose of the HITECH act and all the money their spending on EHR software:

The entire overarching purpose of the EHR Incentive Program is to move providers towards advanced use of health IT to support reductions in cost, increased access, and improved outcomes for patients.

It’s been one of my pet peeves lately. People always come on this site or on social media and say “that goes against the purpose of the HITECH act.” I often would reply, “what is the purpose of the HITECH act?”

My problem with people’s comments about the purpose of all this spending on EHR software is that purpose changes depending on perspective. I’ve written before about the misalignment between “incentives” and “purpose.”

While I think the purpose for something changes based on whose perspective you’re talking about, I think it’s really important to know where CMS is coming from when it comes to the EHR incentive money and meaningful use. Now we know. They made it quite clear in the final rule.

How do you think the EHR incentive money is doing at achieving CMS’ purpose?

One Physician’s Experience Seeing an Ophthamalogist Pre and Post EHR

Posted on August 27, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I always love to hear doctor’s perspectives on EHR and how they’re impacting their day. You can be certain that they’ll lead with a long list of complaints. Many of the initial complaints are minor things that can be easily resolved with workflow or by a small enhancement by the EHR vendor. Once you get past the initial complaints, then you get to the heart of what they really think about the EHR software. I’ve had this experience hundreds of times and it’s always insightful.

However, this time a doctor shared something even more interesting. This was a doctor visiting another doctor as a patient. Rather than put words in his mouth, I’ll just share with you what he shared with me (EHR vendor name excluded since this could apply to many different EHR vendors):

I was in my ophthalmologist today. He is a really nice, busy doctor. He is in group practice and used to run his wing with one long time nurse with no hassles. He could previously see a patient in 10 min finish refraction, move from room to room and breeze through cases jotting what he needed to write down on one clean ophthalmology SOAP note. Since 2011 they have had EHR Vendor A. (because a consultant sold them on it and promised rewards from CMS)

Today, It took them a total of 1.5 hours to get my refraction, eye exam done. The workflow seemed to be in a complete disarray (remember this is an installed cloud based software since 2011, supposed to the be cream of the crap for Ophthalmology). What shocked me the most was that he now has 4 ladies doing inane things with EMR, trying to help him. I can also see why errors can creep in because he was reading out numbers for the assistant/ Nurse to enter into EHR Vendor A. Distraction fatigue, EMR ennui can cause errors of entry. So the cost of running crappy software far exceeds the physical costs / monthly service costs of the product. It amplifies personnel costs. It took the lady 20 minutes to take totally pointless history and do ROS!

I did not tell her I was a physician and she was clicking away to glory. I counted more than 50 clicks before anything of substance was even gathered. Based on the EMR prompts she made me do finger counting and asking me if I can see her face etc..>! I had clearly indicated to her that I just wanted a retinal exam and prescription for glasses because I wanted to buy new lenses and that I had not required change of prescription for glasses in 10 years!

Then I walk out with mydriatic in my eyes…and saw a hazy illusion of one of my ex-patients, a severe schizophrenic waiting for his turn to be checked in. He was talking about meeting Jesus and asked if I have had a “meeting Jesus moment” in my life.. I assured him I just did…

In those 1 hr and 45 min, the good doctor had seen just 4 patients and 6 more were still waiting impatiently on one arse looking irate, checking their iphones and smart watches …spreading anxiety.

I’m always torn on sharing these type of stories. I know that this doesn’t have to be the case since I know many EHR users who don’t have these issues. However, far too many of them do that it’s worth keeping this perspective in mind. Plus, regardless of how efficiently someone has incorporated the MU requirements, it’s had a huge impact on everyone that’s participating.

I guess it’s fair to say that the above ophthamologist doesn’t agree that meaningful use saves a doctor time.

Could Clinicians Create Better HIE Tools?

Posted on August 13, 2014 I Written By

The following is a guest blog post by Andy Oram.His post reminds me of when I asked “Is Full Healthcare Interoperability a Pipe Dream?

A tense and flustered discussion took place on Monday, August 11 during a routine meeting of the HIT Standards Committee Implementation Workgroup, a subcommittee set up by the Office of the National Coordinator (ONC), which takes responsibility for U.S. government efforts to support new IT initiatives in the health care field. The subject of their uncomfortable phone call was the interoperability of electronic health records (EHRs), the leading issue of health IT. A number of “user experience” reports from the field revealed that the situation is not good.

We have to look at the depth of the problem before hoping to shed light on a solution.

An interoperability showcase literally takes the center of the major health IT conference each year, HIMSS. When I have attended, they physically arranged their sessions around a large pavilion filled with booths and computer screens. But the material on display at the showcase is not the whiz-bang features and glossy displays found at most IT coventions (those appear on the exhibition floor at HIMSS), but just demonstrations of document exchange among EHR vendors.

The hoopla over interoperability at HIMSS suggests its importance to the health care industry. The ability to share coordination of care documents is the focus of current government incentives (Meaningful Use), anchoring Stage 2 and destined to be even more important (if Meaningful Use lasts) in Stage 3.

And for good reason: every time we see a specialist, or our parent moves from a hospital to a rehab facility, or our doctor even moves to another practice (an event that recently threw my wife’s medical records into exasperating limbo), we need record exchange. If we ever expect to track epidemics better or run analytics that can lower health case costs, interoperability will matter even more.

But take a look at extensive testing done by a team for the Journal of the American Medical Informatics Association, recently summarized in a posting by health IT expert Brian Ahier. When they dug into the documents being exchanged, researchers found that many vendors inserted the wrong codes for diagnoses or drugs, placed results in the wrong fields (leaving them inaccessible to recipients), and failed to include relevant data. You don’t have to be an XML programmer or standards expert to get the gist from a list of sample errors included with the study.

And that list covers only the problems found in the 19 organizations who showed enough politeness and concern for the public interest to submit samples–what about the many who ignored the researchers’ request?

A slightly different list of complaints came up at the HIT Standards Committee Implementation Workgroup meeting, although along similar lines. The participants in the call were concerned with errors, but also pointed out the woeful inadequacy of the EHR implementations in representing the complexities and variety of patient care. Some called for changes I find of questionable ethics (such as the ability to exclude certain information from the data exchange while leaving it in the doctor’s records) and complained that the documents exchanged were not easy for patients to read, a goal that was not part of the original requirements.

However, it’s worth pointing out that documents exchange would fall far short of true coordinated care, even if everything worked as the standards called for. Continuity of care documents, the most common format in current health information exchange, have only a superficial sliver of diagnoses, treatments, and other immediate concerns, but do not have space for patient histories. Data that patients can now collect, either through fitness devices or self-reporting, has no place to be recorded. This is why many health reformers call for adopting an entire new standard, FHIR, a suggestion recognized by the ONC as valid but postponed indefinitely because it’s such a big change. The failure to adopt current formats seems to become the justification for keeping on the same path.

Let’s take a step back. After all those standards, all those certifications, all those interoperability showcases, why does document exchange still fail?

The JAMIA article indicated that failure can be widely spread around. There are rarely villains in health care, only people pursuing business as usual when that is insufficient. Thus:

  • The Consolidated CDA standard itself could have been more precisely defined, indicating what to do for instance when values are missing from the record.

  • Certification tests can look deeper into documents, testing for instance that codes are recorded correctly. Although I don’t know why the interoperability showcase results don’t translate into real-world success, I would find it quite believable that vendors might focus on superficial goals (such as using the Direct protocols to exchange data) without determining whether that data is actually usable.

  • Meaningful Use requirements (already hundreds of pages long) could specify more details. One caller in the HIT Standards Committee session mentioned medication reconciliation as one such area.

The HIT Standards Committee agonized over whether to pursue broad goals, necessarily at a slow pace, or to seek a few achievable improvements in the process right away. In either case, what we have to look forward to is more meetings of committees, longer and more mind-numbing documents, heavier and heavier tests–infrastructure galore.

Meanwhile, the structure facilitating all this bureaucracy is crumbling. Many criticisms of Meaningful Use Stage 2 have been publicly aired–some during the HIT Standards Committee call–and Stage 3 now looks like a faint hope. Some journalists predict a doctor’s revolt. Instead of continuing on a path hated by everybody, including the people laying it out, maybe we need a new approach.

Software developers over the past couple decades have adopted a range of ways to involve the users of software in its design. Sometimes called agile or lean methodologies, these strategies roll out prototypes and even production systems for realistic testing. The strategies call for a whole retooling of the software development process, a change that would not come easily to slow-moving proprietary companies such as those dominating the EHR industry. But how would agile programming look in health care?

Instead of bringing a doctor in from time to time to explain what a clinical workflow looks like or to approve the screens put up by a product, clinicians would be actively designing the screens and the transitions between them as they work. They would discover what needs to be in front of a resident’s eyes as she enters the intensive care ward and what needs to be conveyed to the nurses’ station when an alarm goes off sixty feet away.

Clinicians can ensure that the information transferred is complete and holds value. They would not tolerate, as the products tested by the JAMIA team do, a document that reports a medication without including its dose, timing, and route of administration.

Not being software experts (for the most part), doctors can’t be expected to anticipate all problems, such as changes of data versions. They still need to work closely with standards experts and programmers.

It also should be mentioned that agile methods include rigorous testing, sometimes to the extent that programmers write tests before writing the code they are testing. So the process is by no means lax about programming errors and patient safety.

Finally, modern software teams maintain databases–often open to the users and even the general public–of reported errors. The health care field needs this kind of transparency. Clinicians need to be warned of possible problems with a software module.

What we’re talking about here is a design that creates a product intimately congruent with each site’s needs and workflow. The software is not imported into a clinical environment–much less imposed on one–but grows organically from it, as early developers of the VistA software at the Veterans Administration claimed to have done. Problems with document exchange would be caught immediately during such a process, and the programmers would work out a common format cooperatively–because that’s what the clinicians want them to do.