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No, The Market Can’t Solve Health Data Interoperability Problems

Posted on July 6, 2016 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.

I seldom disagree with John Halamka, whose commentary on HIT generally strikes me as measured, sensible and well-grounded. But this time, Dr. Halamka, I’m afraid we’ll have to agree to disagree.

Dr. Halamka, chief information officer of Beth Israel Deaconess Medical Center and co-chair of the ONC’s Health IT Standards Committee, recently told Healthcare IT News that it’s time for ONC and other federal regulators to stop trying to regulate health data interoperability into existence.

“It’s time to return the agenda to the private sector in the clinician’s guide vendors reduce the products and services they want,” Halamka said. “We’re on the cusp of real breakthroughs in EHR usability and interoperability based on the new incentives for outcomes suggested by MACRA and MIPS. {T}he worst thing we could do it this time is to co-opt the private sector agenda more prescriptive regulations but EHR functionality, usability and quality measurement.”

Government regs could backfire

Don’t get me wrong — I certainly appreciate the sentiment. Government regulation of a dynamic goal like interoperability could certainly backfire spectacularly, if for no other reason than that technology evolves far more quickly than policy. Regulations could easily set approaches to interoperability in stone that become outmoded far too quickly.

Not only that, I sympathize with Halamka’s desire to let independent clinical organizations come together to figure out what their priorities are for health data sharing. Even if regulators hire the best, most insightful clinicians on the planet, they still won’t have quite the same perspective as those still working on the front lines every day. Hospitals and medical professionals are in a much better position to identify what data should be shared, how it should be shared and most importantly what they can accomplish with this data.

Nonetheless, it’s worth asking what the “private sector agenda” that Halamka cites is, actually. Is he referring to the goals of health IT vendors? Hospitals? Medical practices? Health plans? The dozens of standards and interoperability organization that exist, ranging from HL7 and FHIR to the CommonWell Health Alliance? CHIME? HIMSS? HIEs? To me, it looks like the private sector agenda is to avoid having one. At best, we might achieve the United Nations version of unity as an industry, but like that body it would be interesting but toothless.

Patients ready to snap

After many years of thought, I have come to believe that healthcare interoperability is far too important to leave to the undisciplined forces of the market. As things stand, patients like me are deeply affected by the inefficiencies and mistakes bred by the healthcare industry’ lack of interoperability — and we’re getting pretty tired of it. And readers, I guarantee that anyone who taps the healthcare system as frequently as I do feels the same way. We are on the verge of rebellion. Every time someone tells me they can’t get my records from a sister facility, we’re ready to snap.

So do I believe that government regulation is a wonderful thing? Certainly not. But after watching the HIT industry for about 20 years on health data sharing, I think it’s time for some central body to impose order on this chaos. And in such a fractured market as ours, no voluntary organization is going to have the clout to do so.

Sure, I’d love to think that providers could pressure vendors into coming up with solutions to this problem, but if they haven’t been able to do so yet, after spending a small nation’s GNP on EMRs, I doubt it’s going to happen. Rather than fighting it, let’s work together with the government and regulatory agencies to create a minimal data interoperability set everyone can live with. Any other way leads to madness.

Halamka Ponders The Need to Leave Medicine If We Continue Our Current Trajectory

Posted on May 5, 2016 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.

The famous Dr. John Halamka, Hospital CIO, Doctor, Former member of the HIT Policy committee, blogger at Life as a Healthcare CIO, recently read the 962 page MACRA NPRM and he wrote up a detailed look at the IT elements of MACRA. The post is worth a read if you’re interested in MACRA. Especially if you don’t want to spend the 20 hours reading it that he spent.

MACRA aside, he ends his post with this bombshell of a comment:

As a practicing clinician for 30 years, I can honestly say that it’s time to leave the profession if we stay on the current trajectory.

A doctor in the comments shared a similar view to Dr. Halamka:

Wow, I feel exactly the same as you do. As a front line ortho provider in a small group. I think now I get the message. CMS and ONC wants us out of private practice, either retire, or join as a salaried doc or hospital employee. That is the only justification for this 1000 page nightmare.

We’ve written a lot about physician burnout and many doctors distaste of all this government regulation, but having someone like John Halamka comment like this is quite telling. What’s scary for me is that I don’t see much light at the end of the MACRA tunnel from a physician perspective. Do you?

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.

The Meaningful Use Revolution

Posted on May 29, 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.

Meaningful Use change is afoot in the world of EHR software. Many doctors, hospitals and EHR vendors were set up to step away from meaningful use stage 2. Many would have filed for an exception, others would have opted out of Medicare, and others would have just taken the penalties on the chin. It wouldn’t have been pretty and the people at CMS/ONC/HHS realized this was happening and had to do something to avoid the meaningful use stage 2 fall out. It wouldn’t have looked good to have billions of dollars of EHR incentive money sitting on the table with no one wanting it.

CMS decided to cover this wound with a bandaid fix that essentially delays meaningful use stage 2. There are still a lot of details of the proposed rule that are unclear. For example, can anyone attest to meaningful use stage 1 or is that option only available to those EHR vendors who aren’t ready for meaningful use stage 2? I’ve sent that question to CMS, but still haven’t gotten an answer.

Can you imagine the fallout if this is indeed the case? Basically they’d be saying, “All of you EHR vendors and organizations that were good and stayed up with the latest regulations are going to have to do more work and attest to the stricter MU2 criteria while we reward those EHR vendors and organizations that weren’t ready for MU2 with a simpler option.” Can you imagine the backlash that would occur if this is indeed what they decide to do? For that reason alone, I can’t imagine them keeping it that way. I think they have to just open up all the stages/certifications to anyone and everyone regardless of your EHR vendor’s readiness for MU2. (Note: I haven’t dug in to see if this is really a viable option or if a 2014 Certified EHR required changes to the software which make it so it can’t do both MU2 and MU1, but I think it should work out fine. For example, CQMs are tied to certification year and not MU stage. Update: Lynn Scheps from SRSSoft sent me the following update “Prior to the publication of the proposed rule, 2014 CEHRT was required for everyone who wanted to earn an incentive in 2014, so part of the certification requirements was that the EHR could be used for stage 1 or stage 2.”)

What’s even more important is that this is really just the start of the meaningful use revolution. I’ve pointed out my article to “blow up meaningful use” a few times before and that message is starting to be shared by other healthcare IT influencers. For example, the title of this post came from a post by EHR certification and Meaningful Use expert, Jim Tate’s post “You Say You Want a Meaningful Use Revolution” which was a great follow up to his “Meaningful Use Zombie Land” post.

It has become really clear that there’s a lot of confusion afoot. The thing people want most from government regulation is clarity and ICD-10 and now meaningful use are suffering from a lack of clarity. John Halamka summarizes this issue really well:

at some point we need to recognize that layering fixes on top of existing Meaningful Use regulation, some of which was written by CMS and some of which was written by ONC creates too much complexity. I have direct access to the authors of the regulations and email them on a daily basis. It’s getting to the point that even the authors cannot answer questions about the regulations because there are too many layers. I realize that we are reaching the end of the stimulus dollars, but as we head into Stage 3, I wonder if we can radically simplify the program, focusing on a few key policy goals such as interoperability, eliminating most of the existing certification requirements, and giving very clear direction to hospitals and professionals as to what must be done when.

I’m glad to see that John Halamka and myself are on the same page. We need to simplify meaningful use and focus on interoperability. That’s a simple and clear message that providers will understand. I was excited that EHR vendor athenahealth offered a similar view in their post “We Should Be Pushing Interoperability Boundaries, Not EHR Certification Timelines.”

Jim Tate has a good call to action to those who care about what’s happening with meaningful use. As of last night, only 8 comments had been made during the public comment period for the meaningful use stage 2 delay NPRM. You can submit your comments on the rule incredibly easy at the following link: http://www.regulations.gov/#!documentDetail;D=CMS-2014-0064-0002 I’ll be taking this post and my “blowing up meaningful use” and modifying them as my comments. I hope you’ll take the time and share your thoughts on the delay and the future of meaningful use.

Halamka on Google Glass, Wrong EHR, and EHR Customer Support

Posted on July 29, 2013 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.


Always great to read John Halamka’s view on the latest technology like Google Glass. I think there’s a place for wearable computing in healthcare. Plus, I’m excited that we’re just at the very early stages of its development.


Are the wrong EHR vendors going to die off?


I think it always has made or broken an EHR implementation. It’s not an easy task implementing an EMR. Many underestimate the effort required to do it right.

Adding “Social Documentation” To EMRs

Posted on March 11, 2013 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.

While EMRs store key clinical information, a vast amount of clinical communication goes on outside the system, via instant message, text, e-mail, fax, phone and social media.

Most health IT managers don’t concern themselves much with the chatter outside the EMR, other than to see that — where possible — it takes place in a secure manner. But according to John Halamka, MD, chief information officer for Beth Israel Deaconess Medical Center, this communication is too important to be ignored.

Rather than let these conversations stream on without ever entering the EMR, he argues that it’s time to begin mining these discussions and integrating them into the EMR.  As he sees it, smart devices, the cloud, instant messaging, SaaS and social networking should be combined to create what he calls “social documentation” for healthcare.

Just what is social documentation?  Here’s his definition:

I define “social documentation” as team authored care plans, annotated event descriptions (ranging from acknowledging a test result to writing about the patient’s treatment progress), and process documentation (orders, alerts/reminders) sufficient to support care coordination, compliance/regulatory requirements, and billing.

So, in social documentation, the various channels clinicians are already using to connect with each other go from ancillary information to key ingredients in a team approach to care. But Halamka breaks it down further. Social documentation, he says:

*Incorporates data input from multiple team members, reducing the documentation burden for each participant
*Eliminates redundant entry of the same information by different caregivers (nurse, pcp, specialist, resident, social worker)
*Supports Wikipedia like summaries (jointly authored statement of history, plans, and decision making)
*Supports Facebook/Twitter like updates i.e. “Patient developed a fever, ordered workup, will start antibiotics”
*Incorporates data already present in the EHR such as orders and results without having to re-describe them in narrative form

I don’t know about you, but to me this makes enormous sense. As Halamka himself concedes, creating a new modular architecture that can support such documents might be “burdensome” but it’s still something to bear in mind as we move forward.

Beth Israel Deaconess Asking Patients To Opt In To HIE Data Sharing

Posted on July 9, 2012 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.

One of the less-obvious, but critical, issues in rolling out an HIE is how management handles patient consent for widespread use of the data.  Providers who don’t ask for detailed permissions as to which HIE partners may use patient data when may someday find themselves at the barrel end of a high-caliber lawsuit.

To avoid such entanglements, Beth Israel Deaconess Medical Center (BIDMC) CIO John Halamka, MD has announced that it will require its 1,800 affiliated ambulatory care providers get patient opt-in for data sharing among clinicians on their case.  The permission slip Halamka wants patients to sign will cover not only care within BIDMC but also care provided by outside clinicians.

The process BIDMC has developed is quite interesting, both in what it demands from clinicians and how the IT department is involved:

*  Doctors who have a need to see patient info for treatment, payment or operations can electronically request a view from a community practice.  To make the query, doctors hit what BIDMC is calling a “magic button” which works as follows (info below from Halamka’s blog):

1.  The clinician clicks on a button inside their EHR.   This click launches a query containing Name, Gender, Date of Birth, and Zip Code to a responding EHR.    The physician does not need to respecify the patient or log in to a separate portal since the patient identity information and security credentials are sent from the querying EHR automatically.
2.  The responding EHR checks the security, looks up the patient, and responds with a medical record number if the patient is found.
3.  The querying EHR sends a new query incorporating the returned medical record number.
4.  The responding EHR launches a web-page which displays clinical data for that medical record number.
5.  All transactions are audited in the responding EHRs.

* Doctors can only get data for patients shared between the two organizations

* All requests will be audited

* There will be no “break the glass” feature allowing clinicians to override patient preferences

* Patients can opt-in later if they choose not to now

The audit aspect of this is especially interesting.   How often? By whom? What protocols are in place to respond when something seems to be out of order?

But I must say the whole thing is intriguing.  It seems to me that BIDMC is making the right choice, but anything involving consumers has a bunch of fail points that don’t pop up at first.  I wonder how consumers will feel about this plan six to twelve month after it’s enacted.  Much to learn here.

Engaged, Connected, E-Patients – Major EHR Developments Per Halamka

Posted on November 1, 2011 I Written By

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

In my ongoing series of Major EHR Developments from John Halamka (see my previous EHR In The Cloud, Modular EHR Software and A Network of Networks posts), his fourth major EHR development from the Technology Review article is: Engaged, Connected, E-Patients.

I think this is one of the sections that Halamka makes some of the most interesting points about the future of healthcare. You should go read this whole section. One major conclusion is that patients are going to be much more involved in their healthcare. Gone are the days that patients just come into the office largely trusting what the doctors tells them. Part of that is likely do to the changing culture of question everything and the other part of it has to do with the access to healthcare information that the internet has provided.

Halamka does mention that research shows that shared decision making between doctors and patients results in better outcomes and that an engaged patient is less likely to sue. Both great reasons for doctors to want an engaged patient. Yet, there are still many of them that don’t like this change. However, most have come to realize that they really won’t have much choice going forward.

Halamka also mentions the new reimbursement models that focus on keeping patients healthy (see all the ACO talk) as opposed to paying best on services rendered (often called fee for service). I’m not sure how much this will be a driver in the engaged, connected, e-Patients. I think the patients will actually run over the doctors with their desire for engagement and their involvement in their healthcare well before any reimbursement model changes occur.

Yes, I think patients will start to demand (in the customer demand sort of way as opposed to the arrogant demands kind of way) their doctors support new forms of engagement. Certainly this will include a number of devices that monitor a patients health. Also, the teleconsultation will become very big as technology brings your doctor back into your home.

As I’ve written about before, I’m excited by the idea that a new form of doctor will be treating “healthy” patients.

Modular Software Unleashes Innovation – Major EHR Developments Per Halamka

Posted on September 23, 2011 I Written By

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

In my ongoing series of Major EHR Developments from John Halamka (see my previous EHR In The Cloud post), his second major EHR development from the Technology Review article is: Modular Software Unleashes Innovation. The following excerpt from his article sums it up well:

Until very recently, innovation in medical IT has depended upon the development schedules of a few very large vendors who sell hospital systems with $100 million price tags. In the future, electronic health records will become increasingly modular, similar to the online app stores where consumers download games or programs for their phones.

The idea of modular healthcare IT has been around for a long time. I think I first saw this concept when I learned about a group called the Clinical Groupware Collaborative. I haven’t heard much out of them recently, but every once in a while I see that they’re still working to make Halamka’s comments about modular EHR software a reality.

I’m certain that Judy from Epic would argue that such modular EHR software is a risk to the healthcare industry. She’s probably right. There are risks to modular software. However, there are even more risks and disadvantages associated with a monolithic EHR vendor that won’t interact with other modular clinical software. I believe that one day this will come back to bite Epic as new CIO’s who weren’t part of the $100 million hospital software purchase will start to embrace a more modular strategy.

Turns out that I think providers will actually be the strongest proponents of the modular strategy. They’re already buying mobile devices with money out of their own pockets and so they’re going to start using apps that will help them provide better care. Hospitals will have a hard time controlling it and they’ll eventually realize that the best way to control it is to embrace it.

The most unfortunate part of this EHR development is that it’s going to take a long time for this development to become a reality. However, little by little we’ll get there.

EHR In the Cloud – Major EHR Developments per Halamka

Posted on September 14, 2011 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.

As most of you know, John Halamka is publishing content everywhere. In fact, maybe I should see if he’ll publish some here. Halamka is really smart and respected by many for good reason. So, I was intrigued to find an article in the Technology Review (an MIT publication) where Halamka higlights what he considers the major EHR and healthcare IT developments over the next five years.

I’ve been doing a number of series lately on EMR and EHR & EMR and HIPAA and since people seem to really like them, I decided I’d make Halamka’s major EHR developments into a series as well.

The first Major EHR Development is: EHR In the Cloud

In the article above, Halamka offers some interesting comments about doctors being doctors and not tech people, the issues of privacy in the cloud and hospitals leaning towards “private clouds.” Let’s take a look at each of these.

Doctors Don’t Want to be Tech People
While there are certainly exceptions to the rule, it’s true that most doctors just want their tech to work. They don’t want to spend a weekend installing a server. There’s little argument that a SaaS EHR requires less in office tech. This fact will end up being a major driving force behind the adoption of SaaS EHR software over the client server counterparts.

Certainly, many doctors will still feel comfortable with their local IT help doing the work for a client server install. Also, many still feel more comfortable having their EHR data stored on a server in their office. This issue will continue to fester for a long time to come. At least until the SaaS EHR vendors provide doctors a copy of their data which they can store in their office. Plus, SaaS EHR are much faster today than they were, but there’s still a few things that a client server can do that is just flat out faster than client server.

I still see the ease of implementation and “less tech” helping SaaS EHR software to continue to gain market share.

Privacy in the Cloud
The biggest problem here is likely that doctors aren’t technical enough to really understand the risks of data in the cloud or not. Plus, I think you can reasonably make an argument that both sides have privacy risks. Most people are becoming much more comfortable with data stored in the cloud. I expect this trend to continue.

Private Clouds for Hospitals
Halamka claims that he, “estimates that moving infrastructure and applications to my hospital’s private cloud has reduced the cost of implementing electronic health records by half.” Of course, we have a lot of possible definitions of “cloud” and I’m not exactly sure how Halamka defines his private cloud. However, anyone who’s managed client installs of EHR software, including client upgrades, etc knows some of the pains associated with it. I’d be interested to know what other savings Halamka and Beth Israel Deaconess Medical Center get from their “private cloud.”

Cloud and EHR
There’s one thing I can’t ever get out of me head when I think about EHR and the cloud. Someone once told me (sorry I can’t remember who), “The cloud has always won in every industry. It will win in EHR too.” I hate when people use terms like always and every, but I haven’t (yet?) found an example to prove that person wrong.