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FDA’s Social Media Guidance Insights

I had a chance to watch parts of a Google+ hangout discussing the latest FDA social media guidance with David Harlow from Health Blawg. I’ve had a chance to work on a number of things with David and he’s a really smart guy that’s on top of a lot of the regulations that affect healthcare. I guess that’s a feature of being a healthcare lawyer. For those who missed it, you can check out the full video interview with David below:

For those who prefer the cliff notes version, David published some bullet points on his blog that do a great job summarizing the main points and key takeaways:

  • The draft guidance makes use of Twitter and platforms like Google Ads extremely unattractive, because the vast majority of the “real estate” must be given over to brand and generic names, indications for use, benefits, risks, and a link to fuller information about risks.
  • The FDA addressed itself to short-form communication without considering the way in which it is used most effectively – not as a canvas for ads, but as a forum for conversation.
  • Unbranded tweetchats, Facebook pages, and the like were OK before the draft guidance was issued, and they still are.
  • The correction of misinformation guidance lowers the regulatory bar for corrections (vs. marketing messages that must meet higher standards and may be subject to pre-review).
  • The misinformation guidance does not require a drug or device manufacturer to address all misinformation online about its products. Corrections must be focused responses to what others put out there on line, and should link to fuller information where appropriate, but corrections should not include or link to promotional material.
  • The misinformation guidance delineates an area of opportunity for drug and device manufacturers.

You can read more on his blog post including someone getting in trouble for liking a patient’s status. Think about that for a minute. Is it any wonder that pharma’s been really careful with social media?

July 23, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

The Impact of Meaningful Use on EHR Development

I’ve been getting a really strong response to my post calling for EHR vendors to expand their definition of customer service. Although, the title doesn’t do the post justice since I also talk about the impact of meaningful use on EHR development. Many of the readers of EMR and HIPAA (and if you don’t read EMR and HIPAA you should go subscribe to the emails now) have highlighted some important points I wanted to share with a broader audience.

First, Peggy Salvatore provides this insight about the impact of billions of dollars of EHR incentive money:

Almost 15 years ago, I wrote material for Intel (the computer chip company) based on research they were doing on physician workflow to make EHRs more usable. It was one of the early efforts to tackle this issue. I mention this to say that a lot of spade work has been done in this field but (in my humble opinion) government regulation has gotten in the way of software businesses trying to build electronic patient record products that work for the end users. Experience has shown time and again that customers will drive product improvements, and the same is true in the healthcare industry as in all others. The government has wasted tens of billions of dollars requiring systems be installed to meet timelines that were not realistic given the budgets and time available, or, to this point, to install products that were not really ready for prime time. Let the customers – in this case – the providers and the patients – drive development and you will end up with products that solve problems, not create them.

Brenden Holt, CEO of Holt Systems, offers this startling commentary on the EHR industry:

To me it is more clear. EHR Vendors, large and small and all points in between are currently working on the support nightmare (R&D and Direct Support) of Meaningful Use. It is the same when CCHIT was coming out, and not much different then the 100′s, if not 1000′s, of current copy cat products, all in one way or another a copy of the master Logician (GE).

Innovation does not bring in customers in the current environment. Government Adherence and more importantly relationships (Marketing and Sales) accomplish this. That is to say products need to be improved upon, but only to the extent of meeting the Government Regulatory Demands and the demands of the Large Organizations that are buying these things in bulk.

Innovation is available, but more then likely will take some time, as will thinking of how we document patient care as a whole, which is antequated methodology.

So as a CEO of a software company, one in the sea of many, I will say, innovation will happen when the phones get off the hook form highly demanding end users who want to make sure the MU is met and a Government Final Ruling that will get Government out of Development. Government is a terrible manufacture of innovation. One other major issue is that the end users don’t really want to pay for the innovation, if the EHR is working they are happy with the LOB application. That in and off itself is a issue, new features don’t translate to higher fees, the opposite is the case, less features in a Free Package can be much more attractive as both meet the basic LOB requirements.

We are the US, as much as the rest of the world tries, inguinity is what makes us great, our leading export, but in this vertical it is all but dead.

Catherine Huddle offered this insight about MU not just derailing EHR development innovation, but also possibly making things worse:

As for MU, as an EHR vendor I would agree that it and related government programs such as PQRS and PCMH have significantly derailed most other product development. Not only was Stage 2 a development “hog” but it brought in required changes that are often unnatural in a practice’s workflow and overly complicated.

MU has changed the goal from delivering what providers need to finding the best way to deliver MU to make it easiest for the providers and other staff – while still trying to make other improvements to the EHR. Unless the government repeals MU and the Medicare penalties the winning EHRs will be the ones that make MU as easy as possible.

While there’s plenty to be pessimistic about what’s happened with EHR, I’m still optimistic that we’ve passed through the meaningful use waters and that the future will bring forth opportunity for EHR development innovation. I’m hopeful (although not 100% certain) that the people in Washington have seen the toll that meaningful use has paid on the industry and they’ll lighten the load so that EHR vendors can start listening to end users instead of regulators.

July 22, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Meaningful Use Stage 2 Save Doctors’ Time

I recently saw an older document from an EHR vendor that outlined some reasons why a doctor should take part in meaningful use stage 2. They suggested that meaningful use stage 2 would save our healthcare system money, save doctors’ and hospitals’ time and save lives.

All of these are noble goals worthy of consideration. If meaningful use could achieve this triple aim, then I think every doctor and healthcare organization would happily hop on this new triple aim. Let’s look at each and see how meaningful use stage 2 is doing with this meaningful use stage 2 triple aim:

Save Our Healthcare System Money – This one is interesting because many of the doctors I talk to are afraid that this is exactly what’s going to happen with meaningful use stage 2. They’re deeply afraid that meaningful use is really a way for the government to get access to a physician’s data so that they can pay the physician less. You have to remember that if we save the healthcare system money that means that some organization is going to get paid less.

While I think that the fear these doctors portray is a little overstated, it is true that the government wants the data to be able to pay people using that data. One could argue that a doctor doing good work has nothing to fear and it’s only the crooks that are over billing for their services are the ones that have to worry. Although, we know that data isn’t perfect and there will be collateral damage. I would just argue that the government doesn’t know what to even do with the data right now. So, we won’t see this change happen in the near future. We’ll see if they can achieve this goal long term.

Save Doctors’ and Hospitals’ Time – This suggestion is so ridiculous that I had to make it the title of the post. What I think is possible is that EHR adoption can save an organization time, but I think we need to be careful substituting EHR adoption with meaningful use. Sure, the EHR incentive money has pushed EHR adoption forward, but any time savings that has come from EHR adoption has been lost to the meaningful use check boxes that are required.

Save Lives – Once again, with this one you have to balance the idea of EHR adoption against meaningful use adoption. However, I am hopeful that things like clinical decision support, ePrescribing (ie. legible prescriptions) and a myriad of other things can save some people’s lives. This is hard to quantify, track and measure and so I don’t think we really know. I think there are anecdotal stories of times where care was improved and even lives saved because of something in an EHR. Certainly there’s also some evidence that EHRs can make care worse. Although, I think that is usually just as anecdotal as the lives saved. For now, I’d say this is a bit of a wash, but long term I like the potential of what EHRs can do to save lives. Although, I’m not sure that MU will be the basis for the lives saved.

July 21, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Another EHR Glass Implementation

HealthTech has a really terrible write up of the latest EHR vendor to put out a Google Glass EHR implementation. The iPatientCare EHR application is called miGlass. However, the article states that it’s the first wearable EHR App for glass, but we’ve already written about one from DrChrono and Kareo’s Google Glass implementation was probably the first one that I saw. Plus, there are a number of hospital based EHR implementations that have happened as well. Maybe iPatientCare was the first and they just didn’t get any coverage until now.

Timing aside, the article lists the technology available on this new Google Glass EHR application, miGlass:

  • Web browser based EHR and PM System
  • Microsoft .net Technology
  • Services Oriented Architecture
  • HL7 CCD and ASTM CCR for Interoperability
  • HL7 Integration with leading Lab
  • Information Systems
  • SureScripts/RxHUB Certified ePrescribing
  • Reporting & Analytics using Cognos and Business Objects
  • Available on iPhone and iPad

Maybe the article just made a mistake (I make them all the time as you know), but that list seems like a list of EHR technology and not Google Glass application functionality. iPatientCare also has a video that’s not even worth linking to since it doesn’t say anything about what the Google Glass application really does.

While I love to see EHR vendors experimenting and testing the integration of Google Glass into their EHR, I still haven’t seen the killer use case in action. Although, there are a few hospital EHR Google Glass implementations that I’d like to see in action. I do love the potential of Google Glass. There’s something beautiful about an always on, always connected application that’s sitting there waiting for you when it’s needed. Plus, as the camera recognition technology gets better, the workflow will get better as well.

Imagine walking into an exam room and as you do it, your Google Glass scans a QR code on the door and pulls up the patient waiting for you in the room. Hopefully that’s the naive and simplistic view of where the technology is going to be taken. As more EHR vendors tinker with the technology it will be really interesting to see what becomes a reality.

July 18, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Risk of Interoperability is Worse Data

I’m a huge fan of healthcare interoperability. I think it needed to happen yesterday and that we could solve a number of our cost issues with healthcare data interoperability and we could save lives. Both of these are very worthy goals.

While I’m a huge fan of healthcare data interoperability, we also have to be careful that we do it right. While there are huge potential benefits of exchanging healthcare data, there are also huge risks involved in it as well. We have to address those risks so that interoperability doesn’t get a black eye because it was poorly implemented.

A great example of the potential risk of interoperability is making sure that we process and connect the data properly. Some might argue that this isn’t that big of an issue. Healthcare organizations have been doing this forever. They get a medical record faxed to their office and the HIM team lines up that medical record with the proper patient. I’m sure the medical records folks could tell us all sorts of stories about why matching a faxed medical record to a patient is a challenge and fraught with its own errors. However, for this discussion, let’s assume that the medical records folks are able to match the record to the patient. In reality, they’re certainly not perfect, but they do a really amazing job given the challenge.

Now let’s think about the process of matching records in an electronic world. Sure, we still have to align the incoming record with the right patient. That process is very similar to the faxed paper record world. For the most part, someone can take the record and attach it to the right patient like they did before. However, some EHR software are working to at least partially automate the process of attaching the records. In most cases this still involves some review and approval by a human and so it’s still very similar. At least it is similar until the human starts relying on the automated matching so much that they get lazy and don’t verify that it’s connecting the record to the correct patient. That’s the first challenge.

The other challenge in the electronic world is that EHR software is starting to import more than just a file attached to a patient record. With standards like CCDA, the EHR is going to import specific data elements into the patient record. There are plenty of ways these imported data elements could be screwed up. For example, what if it was a rule out diagnosis and it got imported as the actual diagnosis? What if the nurse providing care gets imported as a doctor? Considering the way these “standards” have been implemented, it’s not hard to see how an electronic exchange of health information runs the risk of bad health data in your system.

Some of you may remember my previous post highlighting how EMR perpetuates misinformation. If we import bad data into the EMR, the EMR will continue to perpetuate that misinformation for a long time. Now think about that in the context of a interoperable world. Not only will the bad data be perpetuated in one EMR system, but could be perpetuated across the healthcare system.

Posts like this remind me why we need to have the patient involved in their record. The best way to correct misinformation in your record is for the patient to be involved in their record. Although, they also need a way to update any misinformation as well.

I look forward to the day of healthcare data interoperability, but it definitely doesn’t come without its own risks.

July 17, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Healthcare IT and EHR Conferences – Fall 2014

I’m regularly asked which Health IT and EHR conferences I’ll be attending and also asked for suggestions on which conferences people should attend and sponsor. After thinking about the best way to let everyone know the answers to these questions, I decided to create a page of Health IT and EHR Conferences and events that I’ll update regularly.

As you’ll see, I’ve broken the page into three sections: conferences I’m attending, important annual conferences, and user conferences. This is not meant to be an all inclusive list. There are some other people who do that pretty well. Instead, I wanted to focus on those events that are annual events that I attend or would like to attend regularly (I’m trying to limit my travel, but that’s not working so well. Although, you’ll see the bias towards Vegas events since I live in Vegas.). Plus, we’ll include discount codes to the events when we can.

I’d love to hear if there are other events that you think we should add to the list. I especially would like to know about the various Health IT and EHR user conferences that are happening. I’ve really fallen in love with those events because you get so many of the in the trenches users at the events.

I love to connect with readers, so if you’re at one of these events let me know so we can meet and say hi. I’ll also likely be speaking at some of the events as well, but I’m finalizing the details of that now.

Hopefully you’ll find this list useful. Also, you’ll notice that Healthcare Scene readers can get a discount to the Digital Health Conference in New York City. Just use the discount code “HCS” when you register and you’ll get a 20% discount on your registration. It’s a great event and one I look forward to every year.

Looks like it’s going to be a fun fall full of too much travel, but worth it to meet with hundreds of amazing people. I hope to see you at one of the events. Let me know what events you have on your list for Fall 2014.

July 16, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Have You Ever Tried to Cancel an EHR?

A caller’s attempt to cancel their Comcast service is going around the internet. About 10 minutes into the call, the husband got on the line and started recording the call for all of us to see how the Comcast retention rep acted. You can listen to it embedded below.

I imagine most of us have had an experience trying to cancel our service at one time or another. It’s not a fun experience. Although, I know some people who call to cancel their cable service every 3 months in order to have the customer retention representative give them a lower cost deal. You know that offering you a 3 month lower cost (or something like that) is one way they try to retain you as a customer.

As I listened to the call, I was thinking about some of the experiences I’ve read and heard about clinics cancelling their EHR service. Unlike a cable or TV service where it’s quite easy to switch services, switching EHR software is a much more involved process. In many cases EHR vendors hold you “hostage” more than the Comcast retention rep above.

In most cases, the EHR vendor will go radio silent on you or responses to your inquiries will take a really long time. Plus, when you ask for access to your EHR data, you’ll often get hit with a hefty price tag. It’s a shameful practice that many EHR vendors employ to try and lock their customers in and prevent them from switching EHRs. We’re entering the era of EHR switching and this is going to impact a lot of practices going forward.

I’ve debated for a while now creating an EHR “naughty” and “nice” list which outlines the good and bad business practices by EHR vendors. One of the challenges is defining what’s naughty and what’s nice. There’s a lot of grey area in the middle. Although, I think that aggregating this type of information would be really valuable. I’m just afraid that many EHR vendors won’t want to share.

I’ve written posts before about why I think holding a practice’s EHR data hostage is a terrible business practice. The medical community is small and an EHR vendor that tries to do this will definitely suffer from negative word of mouth. What do you think? Should we create a list of EHR vendors and their policy on EHR cancellations?

July 15, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Comical Patient Portal Discussion

I’ve long been interested in how offices communicate their use of an EHR and patient portal to their patients. Long time readers might remember this EMR Under Construction sign that one office used.

I had a doctor send me this email exchange which isn’t necessarily a great suggestion for a practice, but it does illustrate many physicians view of what’s happening with EHR and patient portals:
Comical Patient Portal Comments
I’ll call back to Carl Bergman’s post asking “Has EHR Become a Bad Brand?” I think many doctors consider the EHR and patient portal as one thing. Of course they’re not always the same, but emails like this illustrate how the patient portal and EHR brand are doing…not so well. Although, my guess is that meaningful use has an even worse image in the eyes of doctors.

July 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Is Full Healthcare Data Interoperability A Pipe Dream?

It’s always been very clear to me that healthcare interoperability is incredibly valuable. I still wish most organizations would just bite the bullet and make it a reality. Plus, I hope meaningful use stage 3 is blown up and would just work on interoperability. I think there are just so many potential benefits to healthcare in general for us not to do it.

However, I had a really interesting discussion with an EHR vendor today (Side Note: they questioned if interoperability was that valuable) and I asked him the question of whether full healthcare interoperability is even possible.

I’d love to hear your thoughts. As we discussed it more, it was clear that we could have full interoperability if the data was just exported to files (PDFs, images, etc), but that’s really just a glorified fax machine like we do today. Although it could potentially be a lot faster and better than fax. The problem is that the data is then stuck in these files and can’t be extracted into the receiving EHR vendor.

On the other end of the spectrum is full interoperability of every piece of EHR data being transferred to the receiving EHR. Is this even possible or is the data so complex that it’s never going to happen?

The closest we’ve come to this is probably prescriptions with something like SureScripts. You can pull down a patient’s prescription history and you can upload to it as well. A deeper dive into its challenges might be a great study to help us understand if full healthcare data interoeprability is possible. I’m sure many readers can share some insights.

I’m interested to hear people’s thoughts. Should we trim down our interoperability expectations to something more reasonable and achievable? We’ve started down that path with prescriptions and labs. Should we start with other areas like allergies, family history, diagnosis, etc as opposed to trying to do everything? My fear is that if our goal is full healthcare data interoperability, then we’re going to end up with no interoperability.

July 11, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.

Study on the Economic Impact of Inefficient Communications in Healthcare

Efficient communication and collaboration amongst physicians, nurses and other providers is critical to the coordination and delivery of patient care, especially given the increasingly mobile nature of today’s clinicians and the evolution of the accountable care organization (ACO) model.

For healthcare IT leadership, the ability to satisfy the clinical need for more efficient communications technologies must be balanced with safeguarding protected health information (PHI) to meet compliance and security requirements. As a result, the industry continues to rely primarily on pagers, which creates inefficiencies that can have a considerable economic and productivity impact.

To quantify this impact, the Imprivata Report on the Economic Impact of Inefficient Communications in Healthcare worked with the Ponemon Institute to survey more than 400 healthcare providers in the U.S. about the typical communications process during three clinical workflows: patient admissions, coordinating emergency response teams and patient transfers.

This report is chalk full of good information on the communication challenges in healthcare. Here’s one example chart from the report:
Wasted Time in Hospitals Due to Poor Communication

While it’s good to see that 52% think pagers are not efficient, I’d hope that the number were much higher. I think that most don’t realize how inefficient a pager really is to their organization. It’s interesting that 39% don’t allow text messaging, but it would be interesting to see how many of the 61% that allow text messaging use a secure text message solution.

I think the use of technology to facilitate communication in healthcare is one of the most exciting opportunities out there today. Certainly we have to be careful to follow HIPAA, but we need to not use HIPAA as an excuse for why we don’t use the technology to facilitate better communication.

There’s a lot more in the report that’s worth a read. I’m sure I’ll be covering more details of the report in the future.

July 9, 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 14 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and Google Plus. Healthcare Scene can be found on Google+ as well.