I finished my master’s degree program last week and decided to tackle the mountain of books I accumulated over the last 2 years. The opportunity cost of carefully reading 50+ books is way too high, so the time came to experiment.

Here is the technique (order is important):

1. Look through the table of contents to frame the book’s contents
2. Skim the last chapter
3. Skim the first chapter
4. In reverse order, read the chapter title, the last paragraph followed by the first paragraph of each chapter, taking brief notes of important points (with page numbers), action items, and questions. Make note of chapters you want to cover in more detail.
5. Skim chapters that you want to cover in more detail. Go through the chapter in reverse order, 1 page at a time, taking notes as appropriate.

When you are finished, you should end up with a page or two of critical points with references for you to go back to at a later date, action items and questions for you to follow up on. All this should take roughly one hour. This method works because most non-fiction books follow a prescribed format of state, describe, and restate. You miss some of the details, but you generally don’t retain these details anyways. This way, you only go back to read details that are important.

For a sample, check out the notes I took from Never Eat Alone (I took 3 pages, but it really should be shorter). Highlighted items are my action items or follow-up questions.

Let me know if you have other clever methods for getting all you can out of a non-fiction book in the shortest amount of time possible.

• Hamish Fraser, Director of Informatics & Telemedicine, Partners in Health
• Mike McKay, Former Country Director, Baobab Health Malawi
• Bobby Jefferson, Senior Health Informatics Advisor, Futures Group
• Jonathan Jackson, Co-Founder, President, CEO, Dimagi
• Josh Nesbit, Co-Founder & Executive Director, Frontline SMS
• Donald Yansen, Chief Operating Officer & Co-Founder, ClickDiagnostics
• Alvin Marcelo, Director, National Telehealth Center, University of the Philippines, Manila
• Jessica Haberer, Harvard Initiative for Global Health

In addition, PHAT has partnered with GHDonline.org, an online platform of communities developed by the Global Health Delivery Project, to provide a forum for continuing the dialogue about the topics discussed at the event. I have just posted the content from the session titled Effective EMR: Moving Beyond the Technology, along with discussion questions in the GHDonline.org Health IT Community. You can access the discussion here: What non-technological factors make EMR effective?. If you are not already a member of GHDonline.org, I encourage you to join! It is a fantastic resource for engaging others with similar interests across the globe.

One of the processes that Baobab uses to support sites after implementing the Baobab system is the “Proactive Help Desk,” in which the help desk calls each site at least once per week to ask if they have any questions, are any systems not functioning, or any problems. They do this in addition to being available for normal help desk requests.

This incredibly simple idea of the Proactive Help Desk is one of the most obvious ways I’ve heard of to create a useful feedback loop between system administrators and users, yet I’ve never heard of it before! By giving their users the opportunity to provide weekly feedback on the Baobab system, on the workflows, and on their particular context, they dramatically improve their ability to support users and to iterate the system and related processes to addresses immediate user needs.

Community Services Council of Tulsa, Tulsa, Okla. – $12,043,948

Leverage broad community partnerships with hospitals, providers, payers, and government agencies  to expand a community-wide care coordination system, which will increase appropriate referrals for cancer screenings, decrease unnecessary specialist visits and (with telemedicine) increase access to care for patients with diabetes.

Delta Health Alliance, Inc., Stoneville, Miss. – $14,666,156

Focus on achieving improvements for diabetic patients by electronically linking isolated systems and practices for care management, medication therapy management and patient education.

Eastern Maine Healthcare Systems, Brewer Maine – $12,749,740.

Expand community connectivity, including long-term care, primary care and specialist providers, to existing Health Information Exchange and promote the use of telemedicine and patient self-management in order to improve care for elderly patients and individuals needing long-term or home care.

Geisinger Clinic, Danville, Pa. – $16,069,110

Enhance care for patients with pulmonary disease and congestive heart failure by creating a community-wide medical home, promoting Health Information Exchange and extending Geisinger’s proven model for practice redesign  to independent healthcare organizations throughout region.

HealthInsight, Salt Lake City, Utah – $15,790,181

Improve Diabetes management performance measures by increasing availability, accuracy and transparency of quality reporting, leverage Intermountain Healthcare’s strategies to reduce health systems costs throughout the region, and improve public health reporting.

Indiana Health Information Exchange, INC., Indianapolis, Ind. – $16,008,431

Expand the country’s largest Health Information Exchange to new community providers in order to improve cholesterol and blood sugar control for diabetic patients and reduce preventable re-admissions through telemonitoring of high risk chronic disease patients after hospital discharge.

Inland Northwest Health Services, Spokane, Wash. – $15,702,479

Focus on increasing preventive services for diabetic patients in rural areas by extending Health Information Exchange and establishing anchor institutions in close proximity to remote clinics that will promulgate successes in health IT supported care coordination.

Louisiana Public Health Institute, New Orleans, La. – $13,525,434

Reduce racial health disparities and improve control of diabetes and smoking cessation rates by linking technically isolated health systems, providers, and hospitals; and empower patients by increasing their access to Personal Health Records.

Mayo Clinic Rochester, d/b/a Mayo Clinic College of Medicine, Rochester, Minn. - $12,284,770

Enhance patient management and, reduce costs associated with hospitalization and emergency services for patients with diabetes and childhood asthma and address reduce health disparities for underserved populations and rural communities.

Rocky Mountain Health Maintenance Organization, Grand Junction, Colo. – $11, 878, 279

Enable robust collection of clinical data from health systems, providers, and hospitals in order to inform practice redesign to improve blood pressure control in patients with diabetes and hypertension, increase smoking cessation counseling, and reduce unnecessary emergency department utilization and hospital re-admissions.

Southern Piedmont Community Care Plan, Inc., Concord, N.C. – $15,907,622

Improve care coordination for patients with diabetes, heart disease, hypertension, and asthma by engaging patients and providers in bidirectional data sharing through a Health Record Bank, empowering patients and family members to participate in self-management through patient portals, and expanding access to care managers to facilitate post-discharge planning.

The Regents of the University of California, San Diego, San Diego, Calif. – $15,275,115

Expand pre-hospital emergency field care and electronic information transmission to improve outcomes for cardiovascular and cerebrovascular disease, empower patients to engage in their own health management through web portal and cellular telephone technology, and improve continuity of care for veterans and military personnel through the Veterans Affairs/Department of Defense Virtual Lifetime Electronic Record initiative.

University of Hawaii at Hilo, Hilo, Hawaii – $16,091, 390

Implement a region-wide Health Information Exchange and Patient Health Record solution and utilize secure, internet-based care coordination and tele-monitoring tools to increase access to specialty care for patients with chronic diseases such as diabetes, hypertension, and obesity in this rural, health-professional shortage area .

Western New York Clinical Information Exchange, Inc., Buffalo, N.Y. – $16,092,485

Utilize clinical decision support tools such as registries and point-of-care alerts and reminders and innovative telemedicine solutions to improve primary and specialty care for diabetic patients, decrease preventable emergency room visits, hospitalizations and re-admissions for patients with diabetes and congestive heart failure or pneumonia, and improve immunization rates among diabetic patients.

The Argument Against: Electronic medical records rarely improve medical care and can even make it worse. Jeffrey Linder et al found that there was no association with presence of EMR and quality for 17 different measures, and this has been confirmed by other studies.(3) Providers who have experienced gains are generally academic medical centers whose results are not reproducible outside of that setting. In one example, Children’s Hospital of Pittsburgh rolled back a multi-million dollar CPOE implementation in the pediatric ICU after it was discovered that mortality had increased. Physician productivity can drop as much as 20% for the first 6 months after EMR implementation. A good ROI has generally only been obtained by large, integrated networks through savings on administrative overhead. Until technology systems mature and implementation processes improved, resources would be better invested elsewhere.

A Potential Synthesis: Electronic medical records are an enabling technology that supports cost-savings and quality improvement processes only if meaningfully and effectively used. David Cutler maintains that other industries required ten years to realize industry-wide gains from the use of information technology. The health sector started using IT later than other industries, but will be able to realize significant gains after clinical workflows and local cultures adapt. EMR data enables providers to do monitoring and evaluation and quality improvement that would not be possible otherwise, but business processes must be modified to take advantage of them. Providers should first implement technologies and features that have proven to be effective, such as CPOE, automated prescribing and dispensation. National “meaningful use” regulations, while imperfect and politicized, help guide physicians, health system planners and vendors on methods to increasingly leverage technology to improve health.

—-

1. Koppel, JAMA 2005; Bates, 1998; Pestotnik 1996.
2. Perreault L, Metzger J. A pragmatic framework for understanding clinical decision support. Journal of Healthcare Information Management. 1999;13(2):5-21.
3. Jeffrey A. Linder, MD, MPH; Jun Ma, MD, RD, PhD; David W. Bates, MD, MSc; Blackford Middleton, MD, MPH, MSc; Randall S. Stafford, MD, PhD. Electronic Health Record Use and the Quality of Ambulatory Care in the United States. Arch Intern Med. 2007;167(13):1400-1405.

2. Massachusett’s Governor’s National HIT Conference – Health IT: Saving Lives, Reducing Costs & Creating Jobs – April 29-30 (http://mahealthdata.org/Events?eventId=131818&EventViewMode=EventDetails)

3. ONC Releases White Paper on Consumer Consent Options for Electronic Health Information Exchange

———-

1. Networking Event with Jonathan Bush – April 1, 6-8pm @ HBS, Williams Room – RSVP Required

RSVP Required: hit.networking.2010@gmail.com (Include name and organization). Space is limited so reserve your spot quickly!

PHAT and the Health Underground, Boston’s new multi-disciplinary forum for graduate students interested in health IT, invite you to an evening of conversation and networking with Jonathan Bush, CEO of AthenaHealth, on April 1 at the Harvard Business School. Mr. Bush will be sharing the AthenaHealth story and his vision for the future of health IT. Light snacks and drinks provided.

Thursday, April 1, 6-8pm, Williams Room, Harvard Business School

Jonathan Bush, CEO, President and Chairman, AthenaHealth - Jonathan Bush is athenahealth’s Chief Executive Officer, President and Chairman. Mr. Bush co-founded athenahealth in 1997. Prior to joining athenahealth, Mr. Bush served as an EMT for the City of New Orleans, was trained as a medic in the U.S. Army, and worked as a management consultant with Booz Allen & Hamilton. Mr. Bush obtained a Bachelor of Arts in the College of Social Studies from Wesleyan University and an M.B.A. from Harvard Business School.

——

2. Massachusett’s Governor’s National HIT Conference – Health IT: Saving Lives, Reducing Costs & Creating Jobs – April 29-30 (http://mahealthdata.org/Events?eventId=131818&EventViewMode=EventDetails)

Registration for full-time students is only $150!

This is a one-of-a-kind event which will bring together state leaders such as:

• Governors,
• Secretaries of Health and Human Services,
• Medicaid Commissioners,
• HIT Coordinators, and
• key state legislators

along with federal officials and the Massachusetts healthcare community to discuss how we can successfully implement health information technology and health information exchange.

You don’t want to miss the opportunity to hear the remarks from federal and state leaders and to meet and network with people from around the country that are addressing the challenges of HIT policy development and implementation. The program will be held at the Westin Waterfront Hotel, conveniently located near Logan Airport and downtown Boston.

—————–

3. ONC Releases White Paper on Consumer Consent Options for Electronic Health Information Exchange

The whitepaper examines issues regarding whether, to what extent, and how individuals should have the ability to exercise control over their health information in an electronic health information exchange environment.  It looks at existing approaches and details policy options, considerations, and analysis.  This whitepaper will serve as input to, and be reviewed by, the HIT Policy Committee’s Privacy and Security Workgroup as it prepares to make recommendations related to consumer consent in an electronic health information exchange environment.  The whitepaper is the first in a series of privacy and security reports developed by George Washington University under contract with ONC.

The whitepaper can be downloaded at http://healthit.hhs.gov/portal/server.pt?open=512&objID=1147&parentname=CommunityPage&parentid=32&mode=2&in_hi_userid=11113&cached=true

The Massachusetts Health IT Draft Plan was released for public comment in January 2010 and the commenting period is now closed. The plan outlines high-level statewide goals and strategies for achieving improved health outcomes and reduced costs through the use of interoperable EHR systems and health information exchange (HIE). The document sets up governance structures and policy priorities for the planning for use and implementation of federal HI-TECH funds. Currently MA has been awarded ~$25mil, $14mil to MeHI for regional extension centers (RECs) and $10mil to MeHI for HIE. After the MA HIT Plan is adopted, the HIT Council is responsible for the governance structure and MeHI is the Project Management Office (PMO).

The HIT Plan was created in response to a number of MA statutes, including Chapter 305, MA 201 CMR 17:00, and Executive Order 504. The original plan was publicly announced in Jan 2009, but withdrawn due to the announcement of the HITECH Act portion of ARRA. The HIT Council and MeHI contracted Deloitte to update the plan to correspond with the HITECH Act and Meaningful Use regulations.

The tentative milestones lay out an aggressive plan in line with federal meaningful use requirements.

Tentative Milestones

Statutory Overview

• Chapter 2008 passed in August 2008
• MA Legislation Chapter 305 formed the HIT Council
• The HIT Council was charged with creating a statewide HIT Plan and updating it annually. Plans must be approved by the council and the MA Technology Collaborative Board
• HIT Council Members – (look this up), includes Karen Bell
• Background – contracted BCG to create plan which was completed by Jan 2009, right when the Stimulus bill & HITECH Act were released, so plan was pulled back. Deloitte was contracted to create updated plan which was released Jan 2010
• “Community-Based Approach” – inspired by Mass eHealth Collaborative’s 2004 EHR deployment in 3 communities with attempted interoperability, supported by $50mil MA BCBS grant
• MA Plan adopts opt-in HIE and anytime opt-out (which is different than many other states which are opt-out)

MA HIT Plan – Table of Contents

• Executive Summary
• Introduction
• Establish Multi-stakeholder governance
• Establish a Privacy Framework to Guide the Development of a secure HIT environment
• Implement interoperable electronic health records in all clinical settings and assure they are used to optimize care
• Create a local workforce to support HIT related initiatives
• Monitoring success
• Path forward

Discussion

• ARRA
  • Regional Extension Centers (RECs): Provided ~$14mil to MeHI (the MA regional extension center) for implementation of regional extension centers in MA ($625mil total, and ~$100mil given out so far)
  • Health Information Exchange (HIE): Provided $10.6mil for HIE funds to MeHI (again, the state-selected entity), to create the plan (and no one knows where the plan will take us)
• Carol Rodenstein, MeHI Program Director
• HIT Council Members
  • JudyAnn Bigby, MD, Secretary of HHS Massachusetts
  • Deborah A. Adair, Director of Health Information Services and Privacy Officer, MGH
  • Meg Aranow, VP & CIO, Boston Medical Center
  • Karen Bell, MD, Sr. VP of HIT Services, Masspro
  • Lisa Fenichel, MPH, eHealth Consumer Advocate
  • Jay Gonzales, Secretary of Administration and Finance, Massachusetts
• Median practice size in MA is 3 physicians
• Masspro has a lot of experience with small practices and workflow issues associated with EHR implementation
• End of April, governor is inviting governors from entire country, all 50 HIT coordinators, all 50 Medicare reps, all 50 Mecaid reps, and others to bang heads re: conference
• Health care is the largest employer in Mass, employing ~450k workers with $29bil in revenue in 2005.
• Small practices aren’t going away…will lead to the rise of the IPAs
• Health delivery will look a lot different in 2015

High Level Policy Goals:

• Goal 1: Improve access to comprehensive, coordinated, person-focused health care through widespread provider adoption and meaningful use of certified EHRs
• Goal 2: Demonstrably improve the quality and safety of health care across all providers through HIT that enables better coordinated care, provides useful evidence-based decision support applications, and can report out data elements to support quality measurement.
• Goal 3: Slow the growth of health care spending through efficiencies realized from the use of HIT.
• Goal 4: Improve te health and wellness of the Commonwealth’s population through public health programs, research, and quality improvement efforts enabled through efficient, reliable and secure health information exchange processes.

Strategies to Accomplish these  Goals:

1. Establish multi-stakeholder governance
   1. The components of the proposed governance structure are:
      1. These organizations: HIT Council, MTC, MeHI
      2. 6 Ad Hoc workgroups: Clinical Quality and Public health, consumer engagement, education, and outreach, Privacy and security, regional extension center, HIE, workforce development
   2. Estimated that this will be >= 90% private funded
   3. HIT Council oversees governance structure
   4. MeHI is acting Project Management Office
2. Establish a privacy framework to guide the development of a secure HIT environment
   1. ONC’s 6 Privacy Principles: Individual Access, Correction, Openness and Transparency, Individual Choice, Collection, Use and Disclosure Limitation, Data Quality and Integrity
   2. Commonwealth’s privacy and security framework will focus on four key areas: Compliance with policies and standards, Secure HIE technology, Process for certification, Consent management
   3. Privacy/Security rules based on the following previous rulings:
      1. Federal: HIPAA, HITECH Act, FISMA, MITA, HITSP, NIST 800 Series, Privacy Act of 1974
      2. State: Chapter 305, MA 201 CMR 17:00, and Executive Order 504
3. Implement interoperable health records in all clinical settings and assure they are used to optimize care
   1. MA  has officially adopted the goal of meaningfully used EHR in all physician practices by January 1, 2015
   2. MA will provide direct assistance to ~2500 providers to achieve Meaningful Use by contracting with Implementation Optimization Organizations (IOOs)
   3. To ensure adequate funding – 1) promote a loan program, 2) endorse use of state funds, 3) provide support to providers to receive Medicare incentives
   4. Build an effective REC program for the Commonwealth focusing on: individual & small group practices, public and critical access hospitals, community health centers and rural health clinics, other clinics serving the underserved
4. Develop and implement a statewide HIE infrastructure to support care coordination, patient engagement, and population health
   1. HIE Priorities: administrative simplification, e-prescribing, electronic laboratory ordering, electronic public health reporting, quality reporting, prescription status, coordination of care/clinical summary exchange
   2. Will continue to support PHR’S currently supported by MA providers and payers
   3. This effort will be lead by MeHI
   4. Existing HIE Initiatives in MA: Northern Berkshire eHealth Collaborative, Newburyport, SAFEHealth, CHAPS, and NEHEN
   5. MeHI has selected a hybrid HIE model (as opposed to centralized or federated) which will use both centralized and distributed data repositories, allowing the majority of the data to stay at the site of collection
5. Create a local workforce to support HIT related initiatives
   1. High demand and low supply right now for health IT employees
   2. Estimated through 2016 that 64k new health care jobs will be created in the Commonwealth
   3. Development of training programs using federal dollars focusing on implementation, project management, practice management, and data management. Programs will intentionally seek out unemployed persons.
6. Monitor success
   1. Quality measurement program for REC, HIE, and Workforce Development programs
   2. Indicators selected for reporting will fit into the objectives of the high-level goals of the MA HIT Plan
   3. The HIT Council is responsible for selecting the indicators

Then there’s cyberbusiness. What is cyberbusiness? We’re promised instant catalog shopping–just point and click for great deals. We’ll order airline tickets over the network, make restaurant reservations and negotiate sales contracts. Stores will become obselete. Right. So how come my local mall does more business in an afternoon than the entire Internet handles in a month? Malls are going bankrupt all over the country. Even if there were a trustworthy way to send money over the Internet–which there isn’t–the network is missing a most essential ingredient of capitalism: salespeople. Economists have been wrong this whole time, salespeople are the key to capitalism, not competitive free markets!

Enjoy!

2. Global Health Technologies Coalition: Advancing Innovation to Save Lives – useful website with lots of information on technology innovation – www.ghtcoalition.org

3. MIT Sloan Bioinnovations Conference – March 12 – see event details below…

4. PHAT/Health Underground Networking Event w/ AthenaHealth’s Jonathan Bush – April 1 (website coming soon)

——————-

Save the Date!
MIT Sloan BioInnovations 2010 Conference: The New Age of Opportunity

http://web.mit.edu/bbc/bioinnovations/2010/

Friday, March 12, 2010
9:00 AM – 4:00 PM
Boston Marriott Cambridge (next to Kendall Square T-stop)

Register before March 1 for Early-Bird Discounts:

http://www.acteva.com/booking.cfm?bevaid=197535

Keynote Speakers:

Peter Wirth, Esquire
Executive Vice President, Genzyme Corporation

Dr. Robert Langer
M.I.T. David H. Koch Institute Professor

Matthew W. Emmens
Chairman, CEO, and President, Vertex Pharmaceuticals

Panels:

Healthcare Reform
Emerging Markets
Bringing Innovation to Market
Connected Healthcare

BioInnovations is a premier gathering of nearly 300 healthcare pioneers from a broad range of industries; from bio-pharma and medical devices to healthcare providers and non-profits.

The Public Form on HIT National Policy is hosting a free conference this morning (it is starting right now!) with a great lineup of speakers, including David Blumenthal, the National Coordinator for Health IT, Marc Overhage, Director of Med Informatics at Regenstrief Institute, Aneesh Chopra, US Chief Technology Officer at the White House, and several others. Registration is free and the entire event will be webcasted. Blumenthal speaks from 9-9:30am. Content will be available online for 6 months…

2. Free OpenMRS Developer Training Week starting Feb 8

The Regenstrief Institute at Indiana University, the developers of OpenMRS, the popular open-source medical record system, are hosting a free week-long training session at IU beginning Monday, Feb 8. Most of the event will be webcasted. For more details: http://openmrs.org/wiki/OpenMRS_Developer_Training_Week_8-February-2010

3. Health Affairs February Issue on e-Health in the Developing World

This month’s Health Affairs issue is focused on e-health in the developing world, and includes articles on “An Agenda For Action On Global E-Health”, “e-Health Technologies Show Promise in Developing Countries”, and others on cell phones, EMR, informatics, and more.

http://content.healthaffairs.org/content/vol29/issue2/

He opened: “Today, my hope is to do justice to Haiti not by chronicling the events of the past two weeks, which are well known to you, but by attesting to the possibility of hope for the country, and of the importance of meaningful investment and sustainable development in Haiti. That said, I will not pretend that hope is not at times difficult to muster.”

“In my role as the UN Deputy Special Envoy for Haiti, as well as from my long-standing homes at Partners In Health and at Harvard, I have witnessed the many varieties of privation endured by Haiti as well as the country’s extraordinary resilience. But in more than twenty-five years of working there, I have never seen devastation or suffering on this scale. The response from our community has been equally immense: acts of great courage within Haiti, and of great generosity beyond it.

“I know that Haiti can and will recover. I believe that there is an opportunity to build Haiti back better. I am convinced that it will require a massive and ongoing commitment on all of our parts, and that the road will be a long one. We are fortunate to have many partners in this effort, in addition to the five thousand employees of Zanmi Lasante: my colleagues now joining them in Haiti, many of whom have been sharing updates with us and with you; the extraordinary team in Boston; the legions of PIH supporters, old and new, as well as our organizational partners and our colleagues at the Clinton Foundation and the UN. Together, we are all working to serve the people of Haiti, especially those marginalized by chronic poverty as well as the acute insult (to use medical terms) of January 12.”

Read the full script of Paul Farmer’s testimony: http://standwithhaiti.org/haiti/news-entry/pih-co-founder-paul-farmer-testifies-at-senate-foreign-relations-committee/

President Obama delivered his first State of the Union Address last night. The Presidential blog at www.whitehouse.gov/blog has an excellent summary of all the initiatives Obama announced and the entire 90 minute video. The full script is also available at http://www.whitehouse.gov/the-press-office/remarks-president-state-union-address.

I am going to highlight just a few initiatives that are particularly important to me:

• 3-year federal budget freeze – Beginning in 2011, Obama has called for a 3-year federal budget freeze that applies to everything but defense, Medicare/Medicaid, and Social Security. He claimed that without true health reform, it would be impossible to freeze spending on health.
• Financial reform package – use the Stimulus bank bailout money that banks are repaying to go towards funding small business loans; create a small business tax credit; eliminate all capital gains taxes on small businesses (the latter 2 received bipartisan clapping while imposing a fee on large banks to repay the stimulus bailout is not supported by republicans)
• College Financing Reform – this one is big! “To increase college access and completion, the Administration will make student loans more affordable by limiting a borrower’s payments to 10 percent of his/her income and forgives remaining debt after 20 years – 10 years for public service works. We will also make permanent the American Opportunity Tax Credit. The President urges the Senate to pass the American Graduation Initiative, which invests more than $10 billion over the next decade in reforming our nation’s community colleges, promoting college completion, and moving toward the President’s goal of having the highest proportion of college graduates in the world by 2020. The President is also asking colleges and universities to do their share to make college affordable for all Americans cutting their own costs.”
• Health IT – despite all the political action surrounding health IT right now (and a good amount of talk for and against it), this was not mentioned at all
• Nuclear Power Plants – FINALLY the government is going to pave the way to open up some more power plants, after a 30-yr hiatus
• Changing the way the government does business – The administration is going to continue with lobbying reform, increasing government transparency, and creating a public “earmarking” database so that the public can see what budget amounts have been earmarked for certain purposes. To see how serious this administration is about transparency, check out www.data.gov. For a very specific example, I have been able to call into every workgroup meeting and download the materials related to the Office of the national Coordinator’s work on meaningful use and the HITECH Act. Here’s the schedule: http://singularityblog.wordpress.com/2010/01/11/upcoming-hit-policy-standards-committees-workgroup-meetings/

• Risk assessments – There is still a lot of concern about the lack of clarity surrounding risk assessments. The ONC will need to ensure that education on risk assessments is available, especially targeted at small providers. Most organizations currently think they are HIPAA compliant, but few would feel comfortable if the government performed a HIPAA audit, because there is no guidance as to what the government would audit against. Guidance is needed on the “intended outcomes” of MU Security objective and greater transparency, such as Audit Program Compliance Guidelines, is needed on the audit process that will be used. It is unlikely that any guidance will be available by the time the final rulings are released. Large organizations commonly perform internal or 3rd party security/privacy audits, but this is rare (and not feasible) among smaller providers. Many of the comments related to this topic will not change the objective but how the ONC responds to the need for additional information.
• “Implement security updates as necessary” – The term “updates” is both a technology (i.e. software update) and business process (i.e. modify password policy) term, and its intended meaning (whether one or the other or both) should be clearly stated. Time requirements were discussed, such as software security patches must be updated within 90 days of release, but this was thrown out due to complications of implementing updates, especially in enterprise settings.
• HIPAA Investigations – ~5k HIPAA investigations are currently underway. Unclear if these are ~5k different hospitals, individual doctors, multiple investigations per entity, etc. Unclear if an open investigation will prevent an eligible professional or hospital from receiving incentive payments. The “expected” length and cost of investigations will be important to allow providers to make informed decisions. Unclear which HIPAA investigation types are relevant to MU.
• Privacy and Data Transparency – No objectives or measures for privacy and data transparency are present in Stage 1. The Committee wants to propose these for Stage 2. “Accounting of disclosures” is included in Stage 1 and is already required by HIPAA. The connection between the security/certification piece and the MU/privacy piece is weak. For example, the capability to prevent many breaches is a part of certified EHR, but there are no objectives or measures to guide providers in the use of these certification criteria.
• “Consumer-preference” – Also referred to as “patient-choice” requirements, consent management, or access control. There was some disagreement as to what the proper language was to discuss  patient preference. Dixie Baker, who is also involved in the Security Standards Workgroup, posted a presentation (available on the ONC website), to address Access Control and its relation to privacy. There is no IFR criteria for access control to help entities manage the patient consent requirement with which they must comply. This discussion was cut short due to time and will probably be completed in private conversation.

Refer to my previous post to join in on future workgroup meetings: http://singularityblog.wordpress.com/2010/01/11/upcoming-hit-policy-standards-committees-workgroup-meetings/

CCHIT released 3 gap analyses for Eligible Providers, Hospitals, and Security to assist those that were previously CCHIT Certified get into compliance with MU Stage 1. The gap analyses and certification program details are available here: http://www.cchit.org/get_certified.

CCHIT is hosting a public “Town Call” on January 27 at 3PM CT to discuss the gap analyses and ARRA Preliminary Certification programs. For details about connecting to this call, go here: http://www.cchit.org/about/towncalls/hhs-ifr-hit-gap-analysis.