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Who is Adopting EHRs and Why: ONC Turns up Some Surprises

Posted on December 15, 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.

A high-level view of the direction being taken by electronic health records in the U.S. comes from a recent data brief released by the Office of the National Coordinator. Their survey of physician motivations for adopting EHRs turns up some puzzling and unexpected findings. I’ll look at three issues in this article: the importance of Meaningful Use incentives and penalties, the role of information exchange, and who is or is not adopting EHRs.

Incentives and Penalties
The impact of the Meaningful Use bribes–sorry, I meant incentive payments–in the HITECH act are legendary: they touched off a mad rush to adopt technology that had previously aroused only tepid interest among most physicians, because they found the EHRs outrageously expensive, saw no advantage to their use, or just didn’t want to leave the comfort zone of pen and paper. The dramatic outcome of Stage 1, for instance, can be seen in the first chart of this PDF.

This month’s data brief reconfirms that incentives and penalties played a critical role during the period that Meaningful Use has been in play. In the brief’s Figure 3, incentives and penalties topped the list of reasons for adopting records, with nothing else coming even close (although the list was oddly chosen, leaving out credible reasons such as “EHRs are useful”).

The outsized role payments play is both strange and worrisome. Strange, because the typical $15,000 paid per physician doesn’t even start to cover the costs of converting from paper to an EHR, or even from one EHR to another. Worrisome, because the escalator (a favorite metaphor of former National Coordinator David Blumenthal) on which payments put physicians is leveling off. Funding in the HITECH act ends after Stage 3, and even those payments will be scrutinized by the incoming budget-conscious Congress.

In addition, Stage 2 attestations have been dismally low. Critics throughout the industry, smelling blood, have swooped in to call for scaling back, to suggest that meaningful use provisions be eased or weakened, or just to ask for a more concentrated focus on the key goal of interoperability.

The ONC knows full well that they have to cut back expectations as payments dry up, although penalties from the Center for Medicare & Medicaid Services can still provide some leverage. Already, the recent House budget has level-funded the ONC for next year. Last summer’s reorganization of the ONC was driven by the new reality. Recent initiatives at the ONC show a stronger zeal for creating and urging the adoption of standards, which would be consistent with the need to find a role appropriate to lean times.

Health Information Exchange
I am also puzzled by the emphasis this month’s data brief puts on health information exchange. Rationally speaking, it would make perfect sense for physicians to ramp up and streamline the sharing of patient data–that’s exactly what all the health care reformers are demanding that they do. Why should somebody ask a patient to expose himself to unnecessary radiation because an X-Ray hasn’t been sent over, or try to treat someone after surgery without knowing the discharge plan?

Actually, most physicians would. That’s how they have been operating for decades. Numerous articles find that most physicians don’t see the value of information exchange, and can profit from their ignorance of previous tests and treatments the patient has received.

And that’s probably why, after taking hundreds of millions of dollars from governments, the heavy-weight institutions called Health Information Exchanges have repeatedly thrown in the towel or been left gasping for breath. At least two generations of HIEs have come and gone, and the trade press is still searching for their value.

So I’m left scratching my head and asking: if doctors adopt EHRs for information exchange, are they getting what they paid for? Redemption may have arrived through the Direct project, an ONC-sponsored standard for a low-cost, relatively frictionless form of data exchange. Although the original goal was to make HIE as simple as email, the infrastructure required to protect privacy imposes more of a technical burden. So the ONC envisioned a network of Health Information Service Provider (HISP) organizations to play the role of middleman, and a number are now operating. According to Julie Maas of EMR Direct, nearly half a million people were using Direct in July 2014, and the number is expected to double the next time statistics are collected next February.

So far, although isolated studies have shown that HIEs improve outcomes and reduce costs, we haven’t seen these effects nationwide.

What Hinders Adoption
Some of the most intriguing statistics in the data brief concern who is adopting EHRs and what holds back others from doing so. The main dividing line is simply size: most big organizations have EHRs and most small ones don’t.

I have explored earlier the pressures of health care reform on small providers and the incentives to merge. Health care technology is a factor in the consolidation we’re seeing around the country. And we should probabaly look forward to more.

Americans have trouble feeling good about consolidation in any field. We’re nostalgic for small-town proprietors like the pharmacist in the movie It’s a Wonderful Life. We forget that the pharmacist in that movie nearly killed someone by filling a prescription incorrectly. In real life, large organizations can pursue quality in a host of ways unavailable to individuals.

One interesting finding in the data brief is that rural providers are adopting EHRs at the same rate as urban ones. So we can discard any stereotypes of country hick doctors letting teenagers set up the security on their PCs.

Lack of staff and lack of support are, however, major barriers to adoption. This is the last perplexing question I take from the data brief. Certainly, it can be hard to get support for choosing an EHR in the first place. (The Meaningful Use program set up Regional Extension Centers to partially fill the gap.) But after spending millions to install an EHR, aren’t clinicians getting support from the vendors?

Support apparently is not part of the package. Reports from the field tell me that vendors install the software, provide a few hours of training, and tip their hats good-bye. This is poetic justice toward physicians, who for decades have sent patients out weak and groggy with a prescription and a discharge sheet. Smart organizations set aside a major percentage of their EHR funding to training and support–but not everybody knows how to do this or has grasped the need for ongoing support.

I certainly changed some of my opinions about the adoption of EHRs after reading the ONC data brief. But the statistics don’t quite add up. We could use some more background in order to understand how to continue making progress.

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.

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 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.

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.

A Look at the Nashville EHR Market

Posted on July 2, 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 the discussions of the top healthcare markets in the US. When I hear this discussion, two cities that don’t likely get enough love and have a lot of healthcare companies are Nashville and Atlanta. Other people love to talk about Boston and San Diego is strong on the biotech side and has a growing mobile health side as well. Those are definitely some of the top cities for healthcare companies.

With this in mind, I was intrigued when Keith Cawley from Technology Advice emailed me some findings from a survey they did of the Nashville EHR market.

Here are the most interesting findings:

  • Epic, the number one national electronic health record vendor, does not rank among the top five vendors in Nashville
  • Nashville healthcare providers are significantly more satisfied with their EHR programs than providers nationwide
  • 16 percent of providers in Nashville have already switched EHRs
  • Adoption rate among certain specialties is significantly higher than national averages
  • Cost appears to be the number one consideration for Nashville EHR buyers

This feels a bit like a slam on Epic, but I don’t think that Keith has a dog in that fight. I think the findings that Epic does well nationwide, but hasn’t done well in Nashville is quite interesting and worthy of further exploration.

They also put out the Nashville EHR market infographic below. Most interesting to me is the percentages and how the EHR market is still very diverse. Of course, the market can be broken down into smaller segments where we see more domination by certain vendors, but we’re still seeing a lot of EHR diversity in every region.

Nashville EHR Market Infographic.

fEMR Targets Pop Up Clinics’ Needs

Posted on April 29, 2014 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

Detroit’s Wayne State University students are pioneering fEMR, a special EMR for pop up clinics. These are transient clinics operating in under served areas with mass medical emergencies.

Beginning after Haiti’s devastating, 2010 earthquake, WSU’s undergraduate, medical students and doctors started staffing several pop ups. Operating with little or no electricity or other basic supports, these clinics often provide residents their only medical services.

Two volunteers, med student Erik Brown, and premed grad Sarah Draugelis, realized the need to create a basic medical record to aid their work and to print out for the patients. They looked at current EHRs, but they were far too complex, as Draugelis told Improvewsu.org,

We needed something that was fitted for high volume short-term clinics,” Draugelis explained. “We don’t have time to scroll and look at all the tabs in the EMR system. We need something very bare bones, very, very basic.” So, they looked into the EMR systems that already existed, but none of them fit the bill.

Last month, Brown and Draugelis told fEMR’s dramatic story on Live in the D TV show,

video platformvideo managementvideo solutionsvideo player

For help, the two turned to WSU Computer Science professor, Dr. Andrian Marcus, who recruited senior, Kevin Zurek, as technical lead.

fEMR is the result. Built using Play, a fast, light platform for web and mobile apps, fEMR incorporates a simple workflow of three steps: Triage, Medical and Pharmacy. Running on iPads, its tap and touch interface is designed for speed.

fEmr Triage Screen

fEmr Triage Screen

I contacted Zurek who gave me a login to their test site running on Chrome. It is, indeed, bare bones and fast. I created a patient, shown in the web shot above, and played with the package. Though a work in progress, it had no surprises, that is, no crashes, mysterious behavior, etc.

I asked Zurek what he sees as fEMR’s future? Are they going to take it commercial, etc.? He told me,

Our target audience generally consists of volunteers, so we have no concrete plans to commercialize fEMR as of right now. The purpose of fEMR is to bring continuity and increase efficiency in transient medical clinics while producing important data that can be used for research purposes.

In terms of the EMR system, we plan on delivering this to the end user in the most intuitive way possible, with as little training as possible. We have come to the conclusion that the best way to approach this is via an open environment that promotes collaboration across the board.

They need help to finish the work. Right now, they have two of six needed iPads. As befits the bootstraps nature of the project, they plan to raise funds with a car wash.

If you know some iPads that are a bit bored and looking for something more interesting to do, drop Zurek a line. He and the WSU team can keep them busy.

Has EHR Become a Bad Brand?

Posted on April 25, 2014 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

The other day, I had lunch at DC’s Soupergirl with the redoubtable Chuck Webster, workflow tool maven and evangelist. We talked a lot and discovered that both of us had a warm spot for the classic neighborhoods near Atlanta’s Piedmont Park. He as a transplant and I as a native.

More to this blog’s point, we discussed the state of EHRs and their numerous problems. Chuck wondered if EHR, per se, had become a bad brand? It’s a good question. Have we seen a once promising technology become, as has managed care, a discredited healthcare systems? It’s an easy case to make for a host of reasons, such as these:

Poor Usability. There are scads of EHRs in the marketplace, but few, if any, have a reputation as being user friendly. Whenever I first talk to an EHR user, I wait a few minutes while they vent about:

  • How they can’t put in or get out what they need to,
  • Their PCs being poorly located, inflexible or the wrong footprint,
  • Data that’s either missing, cut off or hard to find,
  • Logging in repeatedly,
  • Transcribing results from one system to put it in another,
  • Wading through piles of boilerplate, to get what they need etc., etc.
  • Having to cover PCs with sticky note workarounds.

As for patients, my friend Joe, a retired astrophysicist, is typical. He says when his doctor is on her EHR she doesn’t face him. She spends so much time keying, he feels like he’s talking to himself.

Now, it’s not completely fair to blame an EHR for how it’s implemented. The local systems folks get a lot of that blame. However, vendors really have failed to emphasize best practices for placing and using their systems.

Missing Workflows. EHRs, basically, are database systems with a dedicated front end for capturing and retrieving encounters and a back end for reporting. To carry out, their clinical role they have to be flexible enough to adapt to varying circumstances with a minimum of intervention.

For example, when you make an appointment for a colonoscopy, the system should schedule you and the doctor. It should then follow rules that automatically schedule the exam room, equipment, assign an anesthetist, and other necessary personnel, etc.

When you come in, it should bring up your history, give your doctor the right screens for your procedure, and have the correct post op material waiting. General business software workflow engines have done this sort of thing for years, but such functions elude many an EHR. EHRs without needed workflow abilities increase staff times and labor costs. They also mean users miss important opportunities and potential errors increase.

Data Sharing. Moving from paper to electronic records promised to end patient information isolation. Paper and faxed records can only be searched manually. However, with a structured electronic record, redundant entry would be reduced and information retrieval enhanced. Or so the argument went, but it hasn’t worked out that way.

While there are systems, such as the VA, Kaiser and various HIEs that fulfill much of the promise, it is still a potential rather than a reality for most of us. There are two basic reasons for this state of affairs: ONC’s mishandling of interchange requirements and one member of Congress’ misplaced suspicions.

ONC’s Role. ONC’s Meaningful Use program is meant to set basic EHR standards and promote data interchangeability.

When it comes to these goals, MU fell down from the start. MU1 could have been concise requiring an EHR to capture a patient’s demographics, vitals, chief complaint and meds.

Most importantly, MU could have made this information sharable by adopting one of HL7’s data exchange protocols. This would have given us a basic, national EHR system. Instead, MU focused on too many nice to have features, leaving data exchange way down the list.

ONC has tried to correct its data interchange a failing in MU2 to a degree, but it’s not there yet. Here’s what GAO, has to say about ONC’s efforts:

HHS, including CMS and ONC, developed and issued a strategy document in August 2013 that describes how it expects to advance electronic health information exchange. The strategy identifies principles intended to guide future actions to address the key challenges that providers and stakeholders have identified. However, the HHS strategy does not specify any such actions, how any actions should be prioritized, what milestones the actions need to achieve, or when these milestones need to be accomplished. GAO Report-14-242, March 24, 2014. Emphasis added.

Ron Paul. The other important obstacle to interchange came from Congress. When Congress passed HIPAA in 1996, it mandated that HHS develop a national, patient ID. However, in 1998 Ron Paul, (R-TX) deduced that since HHS wanted the ID system, it therefore wanted to put everyone’s medical records in a government database. He saw this as a threat to privacy. He got a rider added to HHS’s budget forbidding it to implement the ID system or even discuss one.

The ban’s remained in succeeding budgets. The rider has created a national medical data firewall for each of us, which hinders all of us. Paul’s gone from Congress, but Congress continues the ban. As Forbes’ Dan Munroe wrote about Paul’s ban:

The health data chaos we have today doesn’t allow for interoperability, portability or mobility. It’s why fax machines remain the ‘lingua franca” of U.S. healthcare. Every healthcare entity in the U.S. sees each patient, event and location as unique to them. For lack of a single identifier, there’s no easy or cost-effective way to coordinate patient care. Emphasis added.

While the lack of a patient ID is not EHRs fault, it noticeably reduces their ability to interchange information. State or other HIE’s are, in effect, workarounds for lack of a uniform ID. This situation adds to the perception of EHRs as unresponsive technology.

Onerous Agreements. As many an EHR buyer has found, vendors see EHRs as a sellers’ market. They use this to write onerous license agreements exempting their products from adhering to standards such as MU or from responsibility for costly errors or omissions.

These agreements not only limit liability, but often silence a buyer’s adverse comments. The effect is to cut buyers from any meaningful recourse. This shortsighted practice adds one more layer to the EHR industry’s image as unresponsive, self serving and defensive.

Whither the Brand?

The question then is are things so bad that EHR needs rebranding? If so, how should this be done by calling EHRs something else, advocating for a different technology, or yet another alternative?

For some brands, a new name along with some smart PR will do. That’s how Coca Cola reversed its New Coke fiasco. EHRs have a tougher problem. EHRs are not a one vendor product. They are a program class. Reforming EHR’s brand will take more than effective PR. It will take pervasive technical and policy changes.

Change From Where?

Change in a major technical field, as in public policy, requires either overcoming or going around inertia, habit, and complacency. EHRs are no exception. Here are some ways change could happen.

External Events. The most likely source of change is a crisis that brings public pressure on both the industry and government. There is noting like a tragedy to grab public attention and move decision makers off the dime. I don’t want it to occur this way, but nothing like a tragedy makes events go into fast forward and move issues from obscure to inevitable. Given EHRs many patient safety problems, this is all too likely an outcome.

ONC Initiative. ONC could step in and help right matters. For example, as I have advocated, ONC could run NIST’s usability protocols for all systems seeking MU certification. It could then publish the test results giving users a needed, common benchmark. This, in turn, could be a major push to get vendors to regard usability, etc., as an important feature.

ONC is not inclined to do this. Instead, it asks vendors to pick one of several versions of user centric technology. As Bennett Lauber, Chief Experience officer of The Usability People recently told HIEWatch:

“Usability certification for meaningful use really isn’t a test the way the rest of the certification process is. (Testers) go out and observe users, and report back to the certifiers,” Lauber reports. “There seem to be different sets of evaluation criteria because ONC has not really defined usability yet….” Emphasis Added.

Recently appointed ONC Coordinator, Dr. Karen Desalvo, unlike her predecessors, has been frank about changing ONC’s course. She’s revamped her advisory committee structure and spoken about going beyond meaningful use to big data.Notably, she understands the need for and the problems of interoperability. However, she’s not offered any changes in standards. ONC is in the best position to implement real standards, but for both political reasons; it’s unlikely to do so.

To chill things politically, vendors only have to find a few Congressmen who’ll, for a well placed contribution, will send ONC vendor drafted letters threatening its appropriation, committee reviews, etc. It can happen otherwise, but as Damon Runyon has said, “The race is not always to the swift, nor the battle to the strong, but that’s the way to bet.”

User Revolt. The most notable user push back to the status quo has involved unilateral EHR vendor agreements.

As Katie Bo Williams of Healthcare Drive (edited by Hospital EMR and EHR’s Anne Zieger) has notably described, major lawsuits are costing some vendors dearly. The industry, however, has yet to set buyer agreement standards that could aid its and EHRs’ reputation.

These lawsuits might chastise vendors, but users will need to become bolder if they want change. EHR vendors have an association to protect their interests. So do hospitals, physicians, practice managers, etc. Users are the one group that’s not represented.

You may belong to this or that product’s user group, but there is no one group that looks after EHR user’s interest. If there were a well organized and led EHR user group that lobbied for better usability, workflow tools and universal data exchange etc., then these issues would become more visible. More importantly, users would be able to demand a place at the table when ONC, etc., makes policy.

Those interested in patient safety, too, are taking some new directions. Recently, ECRI convened the Partnership for Promoting Health IT Patient Safety to promote changes, within “a non punitive environment,” that is, in a collaborative setting among vendors, practioners, safety organizations, etc. While the group has not issued any reports, it offers two hopeful signs.

The group’s advisory panel includes experts, such as, MIT’s Dr. Nancy Leveson, who works in aeronautic and ballistic missile safety systems. The other factor is that the group has consciously sought to give vendors a place where they see the impact their products have on patient safety without the threat of litigation. Whether the group can bring this off and influence the market remains to be seen.

Technical Fix. It’s possible users may decide to fix EHR’s problems themselves. For example, the University of Pittsburgh Medical Center  (UPMC) uses a combination of EPIC, Cerner and its own clinical systems. It wanted to pull patient information into one, comprehensive, easily used profile. To do this, the Center developed a new, tablet front end that overcomes a variety of common EHR problems.

Once a major actor, such as Pitt, shows there is a market, others will explore it. You’ll know it’s a real trend, when a major vendor buys a front end start up and brands it as its own.

Natural Turnover. Finally, John recently raised the question of EHRs’ future in What Software Will Replace EHR? He thinks that change will come organically as more technically robust software pushes out the old.

Slowly replacing current EHRs with new tools is the most likely path. However, a slow path may be the worst outcome. Slow turnover would give us a mixture of even more incompatible systems. This would make the XP installed base problem look simple.

The EHR brand reminds me of a politician with both high positives and negatives. It may be liked by many, however, it also has a lot of baggage. As with a candidate in that position, something will have to change those negatives or it will find itself just an also ran.

Reply to Dr. Jacob Reider on NIST Dissects Workflow: Is Anyone Biting?

Posted on March 31, 2014 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

One comment on my latest post, NIST Dissects Workflow: Is Anyone Biting?, deserves a more than casual reply.

Here’s the comment from Jacob Reider (Note: Dr. Reider is ONC’s Acting Principle Deputy National Coordinator and Chief Medical Officer. He has made major contributions to the HIT field and is one of its significant advocates.)

Carl, ONC’s UCD requirement references ISO 9241–11, ISO 13407, ISO 16982, NISTIR 7741, ISO/IEC 62366 and ISO 9241–210 as appropriate UCD processes.

We also require summative testing as defined in NISTIR 7742.

Might “Refuses to incorporate NIST recommendations” be a bit of an overstatement?

We solicited public comment in our proposed rule for 2015 certification and would welcome specific suggestions for how we can/should improve user experience of health IT products for efficiency and safety.

Dr. Reider, thank you for your comment – it certainly falls into the category of you never know who’s reading.

Let’stake a look at your last comment first, “Might ‘Refuses to incorporate NIST recommendations’ be a bit of an overstatement?”

Obviously, I don’t think so, but I am not alone.

I based my comment on ONC’s statement in its rule making that refers to NIST’s usability protocols. It says:

While valid and reliable usability measurements exist, including those specified in NISTIR 7804 “Technical Evaluation, Testing and Validation of the Usability of Electronic Health Records,” (21) we are concerned that it would be inappropriate at this juncture for ONC to seek to measure EHR technology in this way.

Sounds like a rejection to me, however, don’t take my word. Here’s the AMA’s response to this decision. First, they demur and quote ONC:

We disagree with ONC’s assertion in the Version 2014 final rule that, “[w]hile valid and reliable usability measurements exist, including those specified in NISTIR 7804 ‘‘Technical Evaluation, Testing and Validation of the Usability of Electronic Health Records,’’ we expressed that it would be inappropriate for ONC to seek to measure EHR technology in this way.”

It then says:

To the contrary, we believe that it is incumbent upon ONC to include more robust usability criteria in the certification process.  The incentive program has certainly spurred aggressive EHR uptake but has done so through an artificial and non-traditional marketplace.  As a consumer, the physician’s choice of products is limited not only by those EHRs that are certified but also by the constraint that all of these products are driven by federal criteria.  The AMA made several detailed recommendations for improving Version 2014 certification in our Stage 2 comment letter, which were not adopted, but still hold true, and we recommend ONC consider them for the next version.  Testimony of AMA’s Health IT Policy Committee’s Workgroups on Certification/Adoption and Implementation, July 23, 2013, pp. 5-6

I recognize that ONC says that it may consider the protocols in the future. Nevertheless, I think the plain English term rejected fits.

In the first part of his statement, Dr. Reider cites several ISO standards. With the exception of the Summative Testing, all of these have been referred to, but none have been adopted. Reference to a standard is not sufficient for its inclusion under the operation of the federal Administrative Procedure Act, which governs all federal agency rulemaking. In other words, these standards are important, but ONC simply calls them out for attention, nothing more.

I think two factors are at work in ONC’s reluctance to include the NIST usability protocols. The first is that the vendors are adamantly opposed to having them mandated. However, I believe there is a way around that objection.

As I have argued before, ONC could tell vendors that their products will be subject to a TURF based review of their product for compliance and that the results would be made public. That would give users a way to judge a product for suitability to their purpose on a uniform basis. Thus, users looking at the results could determine for themselves whether or not one or more non compliance was important to them, but at least they would have a common way to look at candidate EHRs, something they cannot do now , nor under ONC’s proposed approach.

The other factor is more complex and goes to the nature of ONC’s mission. ONC is both the advocate and the standards maker for HIT. In that, it is similar to the FAA, which is vested with both promoting and regulating US aviation.

It’s well established that the FAA’s dual role is a major problem. It’s hard to be a cheerleader for an industry and make it toe the line.

With the FAA, its dual mandate is exacerbated when the highly respected NTSB investigates an incident and makes recommendations. The FAA, acting as industry friend, often defers NTSB’s authoritative and reasonable recommendations to the public’s determent.

I believe that something similar is going on with ONC. NIST’s relationship to ONC is roughly analogous to that of the NTSB’s to the FAA.

NIST is not an investigative agency, but it is the federal government’s standards and operations authority. It isn’t infallible. However, ONC dismissing NIST’s usability protocols, in one word, inappropriate. It did this without explanation or analysis (at least none that they’ve shared). In my view, that’s really inappropriate.

ONC has a problem. It’s operating the way it was intended, but that’s not what patients and practioners need. To continue the aviation analogy, ONC needs to straighten up and fly right.

NIST Dissects Workflow: Is Anyone Biting?

Posted on March 26, 2014 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

Psst. Hey, Buddy, wanna see an EHR, visit’s workflow? Here it is, thanks to the National Institutes of Standards and Technology’s (NIST) new report, NISTIR 7988, Integrating Electronic Health Records into Clinical Workflow, etc.

Returning Patient Ambulatory Workflow NIST

What It Represents

NIST wants to make EHRs usable and useful. It first took aim at patient safety EHR functions that endangered, confused users or were error prone. To counter these, it developed and recommended EHR usability protocols.

Now, in an extensive report, it’s tackled EHR workflow to determine where problems occur. The result is a comprehensive work with significant findings and recommendations. The question is: Is anyone listening?

NIST’s Analytical Approach

NIST decided to create a typical workflow by interviewing knowledgeable physicians, who it calls Subject Matter Experts, SMEs. The physicians had different specialties and used different EHRs, though who they were, NIST doesn’t say.

From their discussions, NIST’s analysts created the above chart, NIST’s Figure 2. NIST’s authors recognize that actual workflows will vary based on setting, sequences, staffing, etc., but that it provides a useful way to look at these issues.

What They Did With It

Working with their physicians, NIST’s analysts broke down the workflow into three sections: before, during and after the visit. Then, they broke down, or decomposed, each of those sections, like opening nested Russian dolls. For example, they segmented the physician’s encounter, below, and once again, broke each down into its functions.

Returning Patient, Physician Encounter - NIST

What They Found

It was at this stage the analysts found significant variations among the EHRs used by their physicians,

[T]here appeared to be high variation in whether and how the EHR was used during this period, how extensive each of the activities typically were for each SME, different based upon the type of patient, how complex the patient was, context of how busy the day was, and other factors. NSTIR 7988, p 18.

Despite these differences, the physicians identified two issues that crossed their EHRs:

  • Working Diagnoses. The physicians wanted systems that let them create a working diagnosis and modify it as they worked until they made a final diagnosis. Similarly, they wanted to be able to back up and make changes as needed, something current systems make hard.
  • Multiple Diagnoses. Diagnoses usually involve multiple causes, not single factors. They wanted their EHRs to support this.

These types of issues aren’t new to those familiar with EHR problems. What’s new is NIST, as an independent, scientific organization, defining, cataloguing and explaining them and their consequences.

What They Recommended

From this work, NIST’s analysts developed extensive and persuasive recommendations, in three categories:

  • EHR Functions
  • System Settings, and
  • System Supports

EHR Functions

NIST’s recommends reducing practitioner workload, while increasing their options and supports. For example, they suggest:

  • Workload Projections. Give practitioners a way to see their patient workloads in advance, so they can plan their work more effectively
  • Notes to Self. Let users create reminder notes about upcoming visit issues or to highlight significant ,patient information. These would be analogous to their hand written notes they used to put on paper charts.
  • Single Page Summaries. Create single page labs summaries rather than making users plow through long reports for new information.
  • Single Page Discharge Summaries. Eliminate excessive boiler plate with more intelligent and useful discharge sheets.
  • Highlight Time Critical Information. Segregate time critical information. Often they get mixed in with other notices where they may be overlooked or hard to find.
  • Allow Time Pressure Overrides. When time is critical, EHRs should allow skipping certain functions.
  • System Settings

NIST recommendations echo the familiar litany of issues that characterize poor implementations:

  • Allow Patient Eye Contact. Exam room designs should put the doctor and patient in a comfortable, direct relationship with the computer as a support.
  • Login Simplification. Allow continuous logins or otherwise cut down on constant login and outs.

System Supports

The physicians recognized they often caused workflow bottlenecks. NIST recommended off loading work to medical assistants, nurse practitioners, physician assistants, etc.. For example, physician assistants could draft predicted orders for routine situations for the physician to review and approve.

Progress Note Frustrations

In the thorny area of clinical documentation, the report details physician frustration with their EHRs. All experienced excessive or missing options, click option hell, excessive output, puzzling terms, etc. These were compounded by time consuming system steps that did not aid in diagnosis or solving patient problems. The report discusses their attempts at improving documentation:

Several of the SMEs had attempted and then abandoned strategies to increase the efficiency of documentation. One SME reported that copying and pasting and “smart text” where typing commands generate auto-text had a “vigilance problem.” The issue was that it would be too easy to put the wrong or outdated information in or in the wrong place and not detect it, and then someone later, including himself, could act on it not realizing that it was incorrect.

One physician described an attempt to use automated speech recognition for dictation for a patient with scleritis, which is inflammation of the white of the eye. He stopped using the software when what was documented in the note was “squirrel actress.”

Another SME described that colleagues relied upon medical assistants to draft the note and then completed it, but they did not like that approach because it was too tempting to rely upon what was typed without reviewing it, and he felt the medical knowledge level was not high enough for this task.

One SME described a reluctance to use any scribe, including a medical student, because the risk would be too high of misunderstanding and thus not correctly documenting the historical information, diagnosis, and treatment plan. This was particularly problematic if the physician had information from prior visits, which contributed to these elements, which were not discussed in detail during the visit. NSTIR 7988, p. 28

Coding their diagnoses into progress notes also came in for criticism:

All SMEs described frustration with requirements to enter information into progress notes, …, which were applied to the notes in order to have sufficient justification to receive reimbursement for services. Although all of the SMEs acknowledged the central importance of receiving reimbursement in order to function as a business, this information was often not important for clinical needs. NSTIR 7988, p. 28

Role Based Progress Note

Unlike other areas of the report, the doctors could not agree on what to do, nor does NIST offer any specific cures for documentation problems. Instead, NIST recommends using a new, role based, progress note:

[T]he progress note for a primary care physician would have a different view from a specialist such as a urologist physician, who might not need to see all of the information displayed to the primary care physician. Similarly, the view of the note for primary care providers could differ from the view of a billing and coding specialist. … NSTIR 7988, p. 28

Will ONC Respond?

In this and its prior reports, NIST covers a lot of EHR issues making sensible recommendations that not only improve functionality, but more importantly improve patient safety. However, NIST’s recommendations are just that. It’s not a regulatory agency, nor is supposed to be one. Instead, its role is to work with industry and experts to develop usable, practical approaches to tough technical, often safety related, problems. To its credit, it’s done this in a vast number of fields from airplane cockpits, nuclear reactors, and atomic clocks to bullet proof vests.

However, its EHR actions have not gained any noticeable traction. If any EHR vendor has implemented NIST’s usability protocols, they haven’t said so. They are not alone.

Notably ONC, one of NIST’s major EHR partners, refuses to incorporate any of NIST’s usability recommendations. Instead, ONC requires vendors to implement User Centered Design, but does not define it, letting each vendor do that for themselves.

NIST has many answers to common EHR workflow and usability problems. The question is, who will bring them to bear?

An Eclectic Gathering of EHR Usability and Project Resources

Posted on March 10, 2014 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

Here are a few resources that I use to solve a variety of design, project management and other problems. Some, such as NIST’s protocols, are directly EHR related; others aren’t, but easily apply to EHR problems.

So here, as was once said, are a few of my favorite people and things:

  • Dan Bricklin. Hopper and Jobs are gone. Woz is a sage. Gates, Kapor and Norton long ago stopped being systems innovators in favor of being philanthropists. Bricklin, however, the electronic spreadsheet’s inventor, soldiers on. His personal site has much to offer, especially his video on interface development for different types of devices and users.
  • Donald Norman. If you only read one of Norman’s many works on usability, make it The Design of Everyday Things. When you do, you’ll find one of the most cogent, funny and thoughtful studies of user centered design. From his account of slide projectors from hell, to post office doors that trap the unwary, to the best ways to arrange light switches, Norman has good advice for all of us. I first read this twenty years ago, but the advice still resonates. He’s recently revised it and added a free on-line course. After Norman, you won’t look at doors, appliances, much less screens the same way again.
  • Jakob Nielsen. There are people who think if you know Nielsen’s usability approach, you need little else. Then, there are those who think if you know Nielsen’s approach, all hope is lost. No one has a monopoly on good interface design, but Nielsen’s site is a place to stop for tons of notable examples.
  • NIST Protocols. NIST works with the private sector to solve major, operational problems. After Three Mile Island close call NIST redesigned all US nuclear power plants’ control rooms. Recently, they’ve developed EHR usability standards. These are the best, most comprehensive treatment of what not to do. You’ll find them in an appendix in their publication, NISTIR 7804.
  • ONC Repository. Most those in the EHR field know ONC, for better or worse due to its Meaningful Use standards. There’s a lot more. Buried on ONC’s site is its Implementation Resources. The repository has dozens of videos, guides, white papers, toolkits and templates all centered on improving EHR selection, implementation and use.
  • Ross Koppel. Koppel is a grouch. He grouches about the dozens different ways EHRs record simple things, such as, blood pressure. Writing often in JAMA, he notes how health IT systems spawn workarounds, confusion and give users choices that are false, misleading or illogical. In short, he’s produced a treasure trove of frightening observations, embarrassing questions and pointed observations, but his bête noire findings also include correctives. All of this is written in a careful, thoughtful style that makes the subject compelling and chilling.
  • Tom Demarco. Demarco of the Atlantic System Guild has produced a wealth of insightful books, lectures and articles on project management. In the 60s, DeMarco asked himself, if a civil engineer can build a bridge from requirements to operation, why can’t we do the same thing with software. His first take was Structured Analysis and System Specification. It’s still in print and full of practical advice and approaches for project managers. Other works include Peopleware: Productive Projects and Teams, where he takes the odd position that you should treat your staff like people and help them be productive. I especially love his The Deadline: A Novel About Project Management in which the main character is kidnapped and forced to manage a project under threat of death. It’s a comedy.

Interested in EHR usability? Join my LinkedIn group: EHRUsability.

Drop In Clinics: Another EHR Quandary

Posted on March 5, 2014 I Written By

When Carl Bergman isn't rooting for the Washington Nationals or searching for a Steeler bar, he’s Managing Partner of EHRSelector.com, a free service for matching users and EHRs. For the last dozen years, he’s concentrated on EHR consulting and writing. He spent the 80s and 90s as an itinerant project manger doing his small part for the dot com bubble. Prior to that, Bergman served a ten year stretch in the District of Columbia government as a policy and fiscal analyst.

If you go to a walk in health clinic, you’re in good company. These clinics and their users are growing rapidly. So, too, is their using EHRs to document your stay. That EHR use is both good and bad news.

 Clinic Types

There are two basic types of these no appointment, walk in clinics: Retail Health and Urgent Care:

  • Retail Health. These treat minor problems or do basic prevention that usually doesn’t require a physician visit. For example, they give flu shots, treat colds, ear infections, and strep throat, etc. The clinics are often one person operations staffed by a nurse practitioner. You can find them in stand alone settings, but more frequently now they are in major, retail chains such as Target, Wal-Mart, CVS, etc. In addition to their location accessibility, these clinics usually have evenings and weekend hours.
  • Urgent Care Clinics. These perform all the services of retail clinics, and also have extended hours. Importantly they add physician services. For example, they will treat burns, sprains, or run basic lab tests. These clinics usually are part of a clinical chain or may be associated with a local hospital. Unlike retail health clinics, they generally are in their own store fronts.

While their services and settings differ, both accept health insurance. With the projected growth of the insured population under the ACA, their managers are expanding their networks.

Clinic EHR to PCP EHR Problem

Unlike practices and hospitals that have undergone, often painful, transitions from paper to EHRs, these clinics, skipped that phase and have, by and large, used EHRs from the start.

EHRs give them a major advantage. If you visit Mini-Doc Clinic in Chamblee, Georgia and then go to one in Hyattsville, Maryland, the Maryland clinic can see or electronically get your Georgia record. This eliminates redundancy and gives you an incentive to stay with a service that knows you.

If you only go to Min-Doc for care, then all your information is in one place. However, if you use the clinic and see you regular doctor too, updating your records is no small issue. Coordination of medical records is difficult enough when practices are networked or in a HIE. In the case of a clinic, especially one that you saw away from home, interface problems can compound.

With luck, the clinic you saw on vacation may use the same EHR as your doctor. For example, CVS’ Minute Clinic uses Epic. However, your clinic may use an EHR tailored to walk ins. Examples of these clinic oriented, tablet, touch optimized EHRs are:

Your physician may not have the technical ability to read the clinic’s record. Getting a hospital to import the clinic’s data would require overcoming bureaucratic, cost and systems problems for what might be a one time occurence. Odds are the clinic will fax your records to your doctor where they will be scanned or keyed in, if at all.

This is not a hypothetical issue, but one that clinic corporate execs, patient advocates and physicians are concerned about. There is no easy solution in sight.

Recently, on point, NPR’s Diane Rehm show had a good discussion of the clinic phenomena, and included the clinic to PCP EHR record issue. You can hear it on podcast. Her guests were:

  • Susan Dentzer. Senior Policy Adviser, The Robert Wood Johnson Foundation and on-air analyst on health issues, PBS NewsHour.
  • Dr. Nancy Gagliano. Chief Medical Officer, CVS MinuteClinic.
  • Dr. Robert Wergin. Family Physician, Milford, Neb., and President-elect, American Academy of Family Physicians, and
  • Vaughn Kauffman. Principal, PwC Health Industries.

All the actors in this issue know that the best outcome would be transparent interoperability. However, that goal is more honored in the breach, etc., for EHRs in general. The issue of clinic to PCP EHR is only at a beginning and its future is unknown.