Free EMR Newsletter Want to receive the latest news on EMR, Meaningful Use, ARRA and Healthcare IT sent straight to your email? Join thousands of healthcare pros who subscribe to EMR and EHR for FREE!

Epic Tries To Open New Market By Offering Cloud Hosting

Posted on November 26, 2014 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

When you think of Epic, you hardly imagine a company which is running out of customers to exploit. But according to Frost & Sullivan’s connected health analyst, Shruthi Parakkal, Epic has reached the point where its target market is almost completely saturated.

Sure, Epic may have only (!) 15% to 20% market share in both hospital and ambulatory enterprise EMR sector, it can’t go much further operating as-is.  After all, there’s only so many large hospital systems and academic medical centers out there that can afford its extremely pricey product.

That’s almost certainly why Epic has just announced  that it was launching a cloud-based offering, after refusing to go there for quite some time.  If it makes a cloud offering available, note analysts like Parakkal, Epic suddenly becomes an option for smaller hospitals with less than 200 beds. Also, offering cloud services may also net Epic a few large hospitals that want to create a hybrid cloud model with some of its application infrastructure on site and some in the cloud.

But unlike in its core market, where Epic has enjoyed incredible success, it’s not a lock that the EMR giant will lead the pack just for showing up. For one thing, it’s late to the party, with cloud competitors including Cerner, Allscripts, MEDITECH, CPSI, and many more already well established in the smaller hospital space. Moreover, these are well-funded competitors, not tiny startups it can brush away with a flyswatter.

Another issue is price. While Epic’s cloud offering may be far less expensive than its on-site option, my guess is that it will be more expensive than other comparable offerings. (Of course, one could get into an argument over what “comparable” really means, but that’s another story.)

And then there’s the problem of trust. I’d hate to have to depend completely on a powerful company that generally gets what it wants to have access to such a mission-critical application. Trust is always an issue when relying on a SaaS-based vendor, of course, but it’s a particularly significant issue here.

Why? Realistically, the smaller hospitals that are likely to consider an Epic cloud product are just dots on the map to a company Epic’s size. Such hospitals don’t have much practical leverage if things don’t go their way.

And while I’m not suggesting that Epic would deliberately target smaller hospitals for indifferent service, giant institutions are likely to be its bread and butter for quite some time. It’s inevitable that when push comes to shove, Epic will have to prioritize companies that have spent hundreds of millions of dollars on its on-site product. Any vendor would.

All that being said, smaller hospitals are likely to overlook some of these problems if they can get their hands on such a popular EMR.  Also, as rockstar CIO John Halamka, MD of Beth Israel Deaconess Medical Center notes, Epic seems to be able to provide a product that gets clinicians to buy in. That alone will be worth the price of admission for many.

Certainly, vendors like MEDITECH and Cerner aren’t going to cede this market gracefully. But even as a Johnny-come-lately, I expect Epic’s cloud product do well in 2015.

Ebola and EHR Workflow

Posted on November 20, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

Earlier this month, the EHR Workflow fanatic addict expert, Charles Webster, MD, put together a webinar on EHR workflow (imagine that). However, he decided to piggyback the Ebola headline and talk about EHR workflow and a bit about how it applied to the Ebola incident. I love the marketing behind it.

EHR workflow is a topic of interest to me and so this summer I had Charles Webster, MD do an EHR workflow series over on EMR and HIPAA. Turns out, he covers a number of the same EHR workflow topics in the webinar embedded below:
-What it workflow?
-What is workflow technology?
-What is a workflow engine?
-What is a workflow editor?
-What is workflow visibility?

If you have an interest in EHR workflow, here’s Chuck’s webinar:

EHR Requires You to Reconsider Your Workflow

Posted on November 19, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

Despite many EHR vendors best efforts to tell you otherwise, an EHR requires every organization to reconsider their workflow. Sure, many of them can be customized to match your unique clinical needs, but the reality is that implementing an EHR requires change. All of us resist change to different degrees, but I have yet to see an EHR implementation that didn’t require change.

What many people don’t like to admit is that sometimes change can be great. As humans, we seem to focus too much on the down side to change and have a hard time recognizing when things are better too. A change in workflow in your office thanks to an EHR might be the best thing that can happen to you and your organization.

One problem I’ve seen with many EHRs is that they do a one off EHR implementation and then stop there. While the EHR implementation is an important one time event, a quality EHR implementation requires you to reconsider your workflow and how you use your EHR on an ongoing basis. Sometimes this means implementing new features that came through an upgrade to an EHR. Other times, your organization is just in a new place where it’s ready to accept a change that it wasn’t ready to accept before. This ongoing evaluation of your current EHR processes and workflow will provide an opportunity for your organization to see what they can do better. We’re all so busy, it’s amazing how valuable sitting down and talking about improvement can be.

I recently was talking with someone who’d been the EHR expert for her organization. However, her organization had just decided to switch EHR software vendors. Before the switch, she was regularly visited by her colleagues to ask her questions about the EHR software. With the new EHR, she wasn’t getting those calls anymore (might say something good about the new EHR or bad about the old EHR). She then confided in me that she was a little concerned about what this would mean for her career. She’d kind of moved up in the organization on the back of her EHR expertise and now she was afraid she wouldn’t be needed in that capacity.

While this was a somewhat unique position, I assured her that there would still be plenty of need for her, but that she’d have to approach it in a little different manner. Instead of being the EHR configuration guru, she should becoming the EHR optimization guru. This would mean that instead of fighting fires, her new task would be to understand the various EHR updates that came out and then communicate how those updates were going to impact the organization.

Last night I had dinner with an EHR vendor who told me that they thought that users generally only used about 50% of the features of their EHR. That other 50% of EHR features presents an opportunity for every organization to get more value out of their EHR software. Whether you tap into these and newly added EHR features through regular EHR workflow assessments, an in house EHR expert who’s constantly evaluating things, or hiring an outside EHR consultant, every organization needs to find a way to regularly evaluate and optimize their EHR workflow.

Open Source Electronic Health Records: Will They Support Clinical Data Needs of the Future? (Part 2 of 2)

Posted on November 18, 2014 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

The first part of this article provided a view of the current data needs in health care and asked whether open source electronic health records could solve those needs. I’ll pick up here with a look at how some open source products deal with the two main requirements I identified: interoperability and analytics.

Interoperability, in health care as in other areas of software, is supported better by open source products than by proprietary ones. The problem with interoperability is that it takes two to tango, and as long as standards remain in a fuzzy state, no one can promise in isolation to be interoperable.

The established standard for exchanging data is the C-CDA, but a careful examination of real-life C-CDA documents showed numerous incompatibilities, some left open by the ambiguous definition of the standard and others introduced by flawed implementations. Blue Button, invented by the Department of Veterans Affairs, is a simpler standard with much promise, but is also imperfectly specified.

Deanne Clark, vxVistA Program Manager at DSS, Inc., told me that VistA supports the C-CDA. The open source Mirth HIE software, which I have covered before, is used by vxVistA, OpenVista (the MedSphere VistA offering), and Tolven. Proprietary health exchange products are also used by many VistA customers.

Things may get better if vendors adopt an emerging HL7 standard called FHIR, as I suggested in an earlier article, which may also enable the incorporation of patient-generated data into EHRs. OpenMRS is one open source EHR that has started work on FHIR support.

Tolven illustrates how open source enables interoperability. According to lead developer Tom Jones, Tolven was always designed around care coordination, which is not the focus of proprietary EHRs. He sees no distinction between electronic health records and health information exchange (HIE), which most of the health IT field views as separate functions and products.

From its very start in 2006, Tolven was designed around helping to form a caring community. This proved useful four years later with the release of Meaningful Use requirements, which featured interoperability. APIs allow the easy development of third-party applications. Tovlen was also designed with the rights of the patient to control information flow in mind, although not all implementations respect this decision by putting data directly in the hands of the patient.

In addition to formats that other EHRs can recognize, data exchange is necessary for interoperability. One solution is an API such as FHIR. Another is a protocol for sending and receiving documents. Direct is the leading standard, and has been embraced by open source projects such as OpenEMR.

The second requirement I looked at, support for analytics, is best met by opening a platform to third parties. This assumes interoperability. To combine analytics from different organizations, a program must be able to access data through application programming interfaces (APIs). The open API is the natural complement of open source, handing power over data to outsiders who write programs accessing that data. (Normal access precautions can still be preserved through security keys.)

VistA appears to be the EHR with the most support for analytics, at least in the open source space. Edmund Billings, MD, CMO of MedSphere, pointed out that VistA’s internal interfaces (known as remote procedure calls, a slightly old-fashioned but common computer term for distributed programming) are totally exposed to other developers because the code is open source. VistA’s remote procedure calls are the basis for numerous current projects to create APIs for various languages. Some are RESTful, which supports the most popular current form of distributed programming, while others support older standards widely known as service-oriented architectures (SOA).

An example of the innovation provided by this software evolution is the mobile apps being built by Agilex on VistA. Seong K. Mun, President and CEO of OSEHRA, says that it now supports hundreds of mobile apps.

MedSphere builds commercial applications that plug into its version of Vista. These include multidisciplinary treatment planning tools, flow sheets, and mobile rounding tools so doctor can access information on the floor. MedSphere is also working with analytic groups to access both structured and unstructured information from the EHR.

DSS also adds value to VistA. Clark said that VistA’s native tools are useful for basic statistics, such as how many progress notes have not been signed in a timely fashion. An SQL interface has been in VistA for a long time, DSS’s enhancements include a graphical interface, a hook for Jaspersoft, which is an open source business intelligence tool, and a real-time search tool that spiders through text data throughout all elements of a patient’s chart and brings to the surface conditions that might otherwise be overlooked.

MedSphere and DSS also joined the historical OSEHRA effort to unify the code base across all VistA offerings, from both Veterans Affairs and commercial vendors. MedSphere has added major contributions to Fileman, a central part of VistA. DSS has contributed all its VistA changes to OSEHRA, including the search tool mentioned earlier.

OpenMRS contributor Suranga Kasthurirathne told me that an OpenMRS module exposes its data to DHIS 2, an open source analytics tool supporting visualizations and other powerful features.

I would suggest to the developers of open source health tools that they increase their emphasis on the information tools that industry observers predict are going to be central to healthcare. An open architecture can make it easy to solicit community contributions, and the advances made in these areas can be selling points along with the low cost and easy customizability of the software.

Mobile EHR Use

Posted on November 14, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

One of the most fascinating sessions I attended recently was by Mihai Fonoage talking about the “Future of Mobile” at EMA Nation (Modernizing Medicine’s EHR user conference where I was keynote). At the start of the presentation, Mihai provided a bunch of really interesting data points about the EMA EHR use on mobiles:

  • 3,500,000 Screens Viewed Daily
  • 50,000 New Visits Each Day
  • 35,000 Photos Taken Daily
  • 12,000 New Consents Each Day
  • 8,000 Rx Prescribed Daily

The most shocking number there is the 35,000 photos taken daily. That’s a lot of photos being stored in the EHR. It is worth noting that Modernizing Medicine has a huge footprint in dermatology where photos are very common and useful. Even so, that’s a lot of photos being taken and inputted into an EHR.

The other stats are nearly as astounding when you think that Modernizing Medicine is only in a small set of specialities. 3.5 million screens (similar to pageviews on a website) viewed daily is a lot of mobile EHR use. In fact, I asked Modernizing Medicine what percentage of their users used their desktop client and what percentage used their iPad interface. Modernizing Medicine estimated that 80% of their EHR use is on iPads. This is a hard number to verify, but I can’t tell you the number of people at EMA Nation I saw pull out their iPads and log into their EMA EHR during the user conference. You could tell that the EMA iPad app was their native screen.

I still remember when I first saw the ClearPractice iPad EHR called Nimble in 2010. It was the first time I’d seen someone really make a deep effort to do an EHR on the iPad. DrChrono has always made a big iPad EHR effort as well. I’d love to see how their iPad EHR use compares to the Modernizing Medicine EMA EHR numbers above. Can any other EHR vendor get even close to 80% EHR use on an iPad application or any of the numbers above?

I’d love to hear what you’re seeing and experiencing with EHR iPad and other mobile EHR use. Is Modernizing Medicine leading the pack here or are their other EHR competitors that are seeing similar adoption patterns with their mobile EHR product lines?

Full Disclosure: Modernizing Medicine is an advertiser on this site.

Generation Who Doesn’t Know Paper Chart World – EHR Natives

Posted on November 13, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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 loved this insight from a doctor at EMA Nation, Modernizing Medicine’s EHR user conference. When making the comment, he was talking about how many MAs in his office don’t know how to keep the clinic going in a non-EHR world (ie. the EHR is down). Obviously, that’s an example of where dependence on EHR goes too far. However, I’ve found that a great leader in a practice can easily quell and comfort these MAs (and other clinical staff) when the EHR is down or otherwise unavailable. It’s never a fun experience, but it can be managed.

While dependence on EHR has its challenges, it also illustrates where the industry is headed. Very quickly not just the MAs, but the RNs, doctors and all of your staff will be EHR natives. What’s an EHR native? It’s someone who has only practiced medicine or worked in a clinic where an EHR was present.

The number of EHR natives is still rather small, but it’s starting to grow very quickly. Soon, we won’t even be having a discussion of going back to paper charts, because a large majority of users won’t even know what it was like to practice on a paper chart. In fact, they’ll likely not even understand how someone could practice medicine on a paper chart.

This is a dramatic cultural shift that is happening right before our eyes. However, the shift is slow and gradual, so many people don’t even realize that it’s happening. While it currently is important to talk about EHR acceptance, this will be gone forever with EHR natives. Many of the paper chart culture will just disappear from healthcare.

I personally look forward to this day. That’s not to say that many of the paper chart natives can’t learn EHR as well. They can and do. Although, I know the cost of learning something new and it’s high. Trust me. I just added snapchat to my cell phone. All I longed for was to go back to SMS, Facebook, and Twitter. It’s definitely hard to teach an old dog new tricks. It’s possible, but possible doesn’t mean it’s easy.

Open Source Electronic Health Records: Will They Support the Clinical Data Needs of the Future? (Part 1 of 2)

Posted on November 10, 2014 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

Open source software missed out on making a major advance into health care when it was bypassed during hospitals’ recent stampede toward electronic health records, triggered over the past few years by Meaningful Use incentives. Some people blame the neglect of open source alternatives on a lack of marketing (few open source projects are set up to woo non-technical adoptors), some on conservative thinking among clinicians and their administrators, and some on the readiness of the software. I decided to put aside the past and look toward the next stage of EHRs. As Meaningful Use ramps down and clinicians have to look for value in EHRs, can the open source options provide what they need?

The oncoming end of Meaningful Use payments (which never came close to covering the costs of proprietary EHRs, but nudged many hospitals and doctors to buy them) may open a new avenue to open source. Deanne Clark of DSS, which markets a VistA-based product called vxVistA, believes open source EHRs are already being discovered by institutions with tight budgets, and that as Meaningful Use reimbursements go away, open source will be even more appealing.

My question in this article, though, is whether open source EHRs will meet the sophisticated information needs of emerging medical institutions, such as Accountable Care Organizations (ACOs). Shahid Shah has suggested some of the EHR requirements of ACOs. To survive in an environment of shrinking reimbursement and pay-for-value, more hospitals and clinics will have to beef up their uses of patient data, leading to some very non-traditional uses for EHRs.

EHRs will be asked to identify high-risk patients, alert physicians to recommended treatments (the core of evidence-based medicine), support more efficient use of clinical resources, contribute to population health measures, support coordinated care, and generally facilitate new relationships among caretakers and with the patient. A host of tools can be demanded by users as part of the EHR role, but I find that they reduce to two basic requirements:

  • The ability to interchange data seamlessly, a requirement for coordinated care and therefore accountable care. Developers could also hook into the data to create mobile apps that enhance the value of the EHR.

  • Support for analytics, which will support all the data-rich applications modern institutions need.

Eventually, I would also hope that EHRs accept patient-generated data, which may be stored in types and formats not recognized by existing EHRs. But the clinical application of patient-generated data is far off. Fred Trotter, a big advocate for open source software, says, “I’m dubious at best about the notion that Quantified Self data (which can be very valuable to the patients themselves) is valuable to a doctor. The data doctors want will not come from popular commercial QS devices, but from FDA-approved medical devices, which are more expensive and cumbersome.”

Some health reformers also cast doubt on the value of analytics. One developer on an open source EHR labeled the whole use of analytics to drive ACO decisions as “bull” (he actually used a stronger version of the word). He aired an opinion many clinicians hold, that good medicine comes from the old-fashioned doctor/patient relationship and giving the patient plenty of attention. In this philosophy, the doctor doesn’t need analytics to tell him or her how many patients have diabetes with complications. He or she needs the time to help the diabetic with complications keep to a treatment plan.

I find this attitude short-sighted. Analytics are proving their value now that clinicians are getting serious about using them–most notably since Medicare penalizes hospital readmissions with 30 days of discharge. Open source EHRs should be the best of breed in this area so they can compete with the better-funded but clumsy proprietary offerings, and so that they can make a lasting contribution to better health care.

The next installment of this article will look at current support for interoperability and analytics in open-source EHRs.

Burned In EHR Workflows

Posted on November 7, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

One of the hospital CIOs at The Breakaway Group focus group at the CHIME Fall Forum talked about what he called “Burned IN EHR Workflows.” I thought the concept was really interesting and no doubt something we can all relate with. We all know when the workflows we do are finally burned into our psyche. We often call it our daily routine and we all hate when our routine is disrupted.

As I thought about this idea, I wondered at what point the EHR workflow is finally “burnt in.” There are a lot of factors that go into burning in the EHR workflow. I’d say it rarely happens during EHR training. Although, with the right EHR training it could be the case. The key question is how well your EHR training emulates the actually environment and workflow of the user. Are you just training them on the EHR software or are you training them on the EHR workflow with the new EHR software? I always did the later and found it so much more effective.

As another CIO at CHIME said, “Users don’t want to know the 10 ways to do the same thing. They want to know the single most effective way to do it.” Of course, figuring out the most effective way to do something is the hard part and why so many EHR trainings fall short.

The good thing about burnt in EHR workflows is that if you’ve implemented a great workflow, then it’s great. The problem is that we often burn in sub optimal EHR workflows. I had this happen to me all the time. I’d ask one of my EHR users why they did something a certain way when it would be so much easier to do it another way. It was just the way the EHR workflow was burnt in.

Changing that already burned in EHR workflow is really hard. Although, it’s not impossible and is often necessary. You just have to burn in a new workflow. However, it also often requires an explanation of why the new workflow is better. Good luck changing someone’s workflow when they liked the old workflow. You better have a good reason or they’re unlikely to change.

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 15 blogs containing almost 6000 articles with John having written over 3000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 13 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.

Cracking Open the Shell on the Personal Health Record

Posted on November 5, 2014 I Written By

Andy Oram is an editor at O'Reilly Media, a highly respected book publisher and technology information provider. An employee of the company since 1992, Andy currently specializes in open source, software engineering, and health IT, but his editorial output has ranged from a legal guide covering intellectual property to a graphic novel about teenage hackers. His articles have appeared often on EMR & EHR and other blogs in the health IT space. Andy also writes often for O'Reilly's Radar site (http://radar.oreilly.com/) and other publications on policy issues related to the Internet and on trends affecting technical innovation and its effects on society. Print publications where his work has appeared include The Economist, Communications of the ACM, Copyright World, the Journal of Information Technology & Politics, Vanguardia Dossier, and Internet Law and Business. Conferences where he has presented talks include O'Reilly's Open Source Convention, FISL (Brazil), FOSDEM, and DebConf.

The concept of maintaining your own health data enjoyed a brief flurry of activity a few years ago with Google Health (now defunct) and Microsoft HealthVault (still active but not popular). It has gotten a second chance with Apple HealthKit, Google Fit, and other corporate offerings explicitly tied in with the convenience of mobile devices. Microsoft itself has galvanized HealthVault with a Microsoft Health initiative similar to Apple’s HealthKit. Recently I’ve been talking to health care reformers about the business and political prospects for personal health records (PHRs).

Patient access to data was enshrined as a right back when HIPAA was passed and is still championed by the US government through Meaningful Use (whose Stage 3 may well focus on it) and other initiatives, and has been endorsed by the industry as well. But this requirement won’t be satisfied by the limited patient portals that hospitals and clinics are hanging out on the Web. Their limitations include:

  • Many provide only viewing data, not downloading or transmitting it (all of these are mandated by Meaningful Use).
  • Data maintained by providers can’t easily be combined into a holistic, comprehensive view, which is what providers need to provide good care.
  • Data on portals is usually a thin sliver of all the data in the record: perhaps prescriptions, appointments, and a few other bare facts without the rich notes maintained by clinicians.
  • You can’t correct errors in your own data through a portal.
  • Clinicians rarely accept data that you want to put in the record, whether personal observations or output from fitness devices and other technical enhancements.

All these problems could be solved by flexible and well-designed personal health records. But how does the health care field navigate the wrenching transition to giving people full control over their own data?

Dr. Adrian Gropper has investigated PHRs for years and even considered building a simple device to store and serve individual’s health data. Now he says, “I can’t recall any physician in my medical society that has ever said they wished their patient had a PHR. Nor do I, after many years on the Society for Participatory Medicine list, ever recall a patient praising the role of their PHR in their care. Today’s PHRs are clinically irrelevant.”

This is not a condemnation of PHRs, but of the environment in which vendors try to deploy them. Many health reformers feel that several aspects of this care environment must evolve for PHRs to be accepted:

  • PHR data must become appealing to doctors. This means that device manufacturers (and perhaps patients themselves) must demonstrate that the data is accurate. Doctors have to recognize value in receiving at least summaries and alerts. Many benefits can also accrue from collecting vital statistics, behavioral data, and other aspects of patients’ daily lives.
  • The doctor’s EHR must seamlessly provide data to the patient, and (we hope) seamlessly accept data from the patient–data that the doctor acts on. Currently, most manufacturers store the data on their own sites and offer access through APIs. Another programming step is required to get the data into the PHR or the doctor’s EHR.
  • Clinicians have to agree on how to mark and collect the provenance of data. “Provenance” deals with assertions such as, “this data was generated by a Fitbit on October 10, 2014″ or “this diagnosis was challenged by the patient and changed on August 13, 2010.”
  • Add-on services must make the data interesting and usable to both patients and physicians. For instance, such apps can alert the patient, clinician, or family members when something seems wrong, let them visualize data taken from the PHR and EHR over time, get useful advice by comparing their data to insights from research, and track progress toward the goals they choose.

“A critical force in increasing consumer engagement in digital health is the development of compelling, easy to use tools that make it simple to collect, understand and use health information to reach the goals consumers define for themselves, whether that’s managing a chronic condition, saving money, or fitting into their ‘skinny jeans’,” writes Lygeia Ricciardi, former director of the Office of Consumer e-Health at the ONC. “In an age of ‘one click purchasing,’ it must become incredibly easy for patients to access and share their own health information digitally–if it’s too complex or time consuming, most people probably won’t do it.”

In addition to sheer inertia, a number of disincentives keep PHRs from congealing.

  • Many doctors are afraid of letting patients see clinical notes, either because the patient will ask too many questions or will be upset by the content.
  • Hospitals and clinics want control over records so that patients will return to them for future treatment.
  • Marketing firms live off of rich data lodes on our health data.
  • Other organizations with dubious goals, commercial and governmental, want to track us so they can deny us insurance or control our lives in other ways.

Wait–what about the patients themselves? Why haven’t they risen up over the past several years to demand control over their data? Well, maintaining your health data is intimidating. The data is highly detailed and full of arcane medical concepts and terminology. Most patients don’t care until they really need to–and then they’re too sick and disabled to form an effective movement for patient control.

Still, several leaders in health care believe that a viable business model can be built on PHRs. The spark of hope comes from the success of apps that make people pay for privacy, notably SnapChat and Whatsapp. Although some sloppy privacy practicies render these services imperfect, their widespread use demonstrates that people care about protecting their personal data.

Private storage can be offered both in the cloud and by personal devices, using standardized services such as Direct and Blue Button. These will start out as high-end services for people who are affluent and have particular concerns about storing their own data and choosing how it is shared. It will then become commoditized and come down in price.

What about people who can’t afford even the modest prices for cloud storage? They can turn patient data into a civil rights issue. There’s a potent argument that everyone has the right to determine who can get access to their health data, and a right to have data generated during their daily lives taken into account by doctors.

We don’t need one big central service–that’s insecure and subject to breaches. Multiple services and distributed storage reduce security risks.

We’ll see change when a substantial group of people start to refuse to fill out those convoluted forms handed to them as them enter a clinic, saying instead, “Get it from my web site before you treat me.” Before that protest begins, there’s a lot of work in store for technologists and businesses to offer patients a usable record system open to the wide range of data now available for health.