New Meaningful Use Interim Standards Require Encryption Capabilities

New Meaningful Use Interim Standards Require Encryption Capabilities

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Anybody building or implement EHR with Meaningful Use as a goal should consider MU and HIPAA as parallel objectives.  HIPAA compliance should not be new to anybody involved in delivering care to patients or those who fall under the definition of Business Associates.  Encryption requirement under HIPAA is pretty robust, though it is in some ways more lax than PCI requirements for handling credit card information (funny how that is the case…)  The policy and processes have to be in place whether you implement an EHR or not.

At the same time, the EHR itself needs to fulfill Meaningful Use requirements.  If you use a hosted EHR as a physician, you will want your vendor to give your assurances that they do not only meet MU but also HIPAA requirements.  Does that make sense?

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A Healthcare Consumer’s Experience in 2016

After reading John Halamka’s blog titled A history of our healthcare future, I got an idea.  You can actually put together a  video of what a patient might experience, if all the Meaningful Use criteria do become rules and the healthcare delivery processes change as intended.  Is it a desirable future?  I am sure everybody has his or her own perspective given how partisan this topic has become…

Say in 2016, Joan Smith, aged 52, comes down with an ailment while traveling for business.  While it was not extremely serious, she was in great discomfort so she makes an appointment for a doctor in the city she’s staying first thing in the morning, and manages to get an appointment for 2pm the same day.  Her doctor’s clinic automatically checks her insurance eligibility when the appointment is made.  When Joan arrives at the clinic, her chart is already available fully on the doctor’s futuristic (yes I have been trying to use this word) handheld device.  The doctor confirms with Joan the drugs she is on and examines her based on her complaints.  As the doctor is recording the new Note, the handheld device recommends a couple of questions or examinations for the patient, which the doctor performed.  The device also makes Joan’s medical history available for the doctor to call up if he has concerns about existing conditions.

There was nothing serious with Joan Smith’s ailment and a simple prescription of antibiotics would do.  However, Joan is allergic to the most common antibiotics so the doctor’s system warns about this while providing the formularies that Joan’s insurer would pay for.  All in all, it was a pretty painless 20 minutes for Joan to get a prescription, avoid unnecessary tests and skip a trip to the ER due to adverse reaction to a medicine.  In a subsequent routine visit to her regular physician, Joan is able to tell her doctor that the prescription cured her problem but did cause some minor side effects with her digestive tract.

6 months later, a researcher studying female patients between the age of 50 to 60 with the ailment that Joan has is able to generate a report that the drug prescribed for Joan is 70% effective for the ailment.  At the same time, it did cause substantial side effects 15% of the time.  This is added to the drug guide that doctors use in the course of care delivery.

This is a very cursory exploration of how healthcare can be in 2016.  It may very well already work this way for you.  I would love to hear it if that is the case.  Sadly, this is not how it works for me and many others.  Doctors cannot share records easily and information is often not available to help physicians make the best recommendations for the patient.  Even today, the fact that a doctor has an EMR implemented does not necessary mean anything other than the EMR vendor has made another 50k to a couple million dollars.  This has to change.

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The future of CCHIT

During the year of 2009, when the HITECH act allocated stimulus funds and assigned the responsibility for specifying the criteria for physicians to qualify for these funds, people in the Healthcare IT business have been wondering what would happen to CCHIT (The Certification Commission for Health IT) which is a non-profit consortium made up of among others the traditional large EMR vendors.  If the government wanted to make HIT easier, cheaper and more effective, it could not just adopt the CCHIT methodology which hadn’t been very effective in promoting EMR adoption.

From the start, it was clear that the requirement for Meaningful Use would not fit neatly into the CCHIT requirements, so the relevance of the organization was in doubt.  Centers for Medicare & Medicaid Services (CMS)’s Notice of Proposed Rule Making (NPRM) on January 13, 2010 made it clear that the government wanted to be vendor neutral in its requirements.  Thus, CCHIT had to do something to play a role in this new development in the EHR marketplace.

This article from InformationWeek reports the first steps being taken by CCHIT since the January 13 rules (which were actually released on Dec 30, 2009).  Basically they have introduced a scaled down version of their “Comprehensive” certification program called the “Modular” program.  They also offer to certify for ARRA stimulus those vendors who have already spent a huge amount of money to pass their Comprehensive program.  Of course, such certification program does not really exist yet because the rules for certification have not yet been finalized.

To make this situation even more interesting is the perspective from Practice Fusion.  You probably already realize that nobody speaks without self-interest in this muddy puddle we call Healthcare IT.   As an upstart in the EMR/EHR space, Practice Fusion obviously enjoys watching the established vendors in the CCHIT organization squirm.  The fact that the National Institute of Standards and Technology has contracted with Booz Allen Hamilton to develop testing methods and process of certification of EHR will keep the squirming going a while longer.

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