Hot, Flat, and Crowded: E.C.E. 101

Last night we had the pleasure of meeting with the members of the book club to which we belong. This is a group of lively, energetic, intelligent, articulate folks who manage to bring varied and wonderful perspectives to everything we read and discuss. This time, we read Thomas L. Friedman’s Hot, Flat and Crowded: Why We Need a Green Revolution – and How It Can Renew America, his thorough take on climate change, the emergence of the Energy-Climate Era (E.C.E), world petropolitics, and the active role the U.S. must play…NOW. 

First, let me warn you that I am a cynic. I have great wishes for but expect little of other people and am rarely disappointed. I am pleasantly surprised when others take seriously the same things that I do. Fortunately for me, Friedman and others are optimists who believe we are capable of rising to the occasion, creating a clean energy industry, gradually diminishing our use of dirty fuels, and continuing to grow our economy and the global economy all at the same time. His book is a very readable exposition of the issues and what we need to do to get past them.

My primary reaction to Friedman’s book was a major sense of urgency. I am not sure why I spend so much time thinking about and writing about health care reform and electronic medical records (EMRs) when we have so much more important challenges on our doorstep. 

If you do not believe that climate change (and our part in it) is an issue that we must address and take action about sooner rather than later but you are open to learning more, please read this book. If you already accept this premise, you might want to read the book to understand some of the complex issues that make it difficult for us as a country to take action on climate change…and to help determine what our personal next step needs to be. If you do not believe that climate change is happening and that we play a part in it and can do something to solve the problem and you know that your opinion is not going to change, that’s fine…but please just get out of our way while we try to take the difficult steps needed to save the planet, our society and our quality of life.

Friedman quoted from the speech of a twelve-year-old girl to the 1992 Earth Summit in Rio de Janeiro, Brazil. Severn Suzuki is probably the most articulate child advocate of anything I have ever heard. If you have 6:42 to invest, take a look at her speech on YouTube. I have strong emotional reactions to speeches…after I finished crying, I started to think about what I wanted to write and what I want to do. One of the decisions I made is that I will write about this subject regularly…you can expect reports a I become more informed and as we take steps to diminish our personal and business CO2 production.

When I got up this morning to write this article, I first checked my email, then I glanced through the N.Y. Times Today’s Headlines to which I subscribe. Nobel prize-winning economist Paul Krugman decided to write about this same subject for today’s paper. His Op-Ed piece Cassandras of Climate expresses succinctly what Friedman’s book does in detail…the time for us to take major action is NOW.

Small, incremental, easy actions are not likely to be enough to keep our children and grandchildren from experiencing significant discomfort and disruption of their lives…but we must start somewhere. Those of us who accept the scientific opinions of virtually all the climate scientists in the world need to get off our duffs and do something…… NOW.  We must find ways to mobilize all the talents of all our citizens to accomplish the difficult tasks before us.

What are you doing about climate change? Many of you are so much farther along than the rest of us. Please share your experience, ideas and the information you have gleaned to help the rest of us move along.

Meaningful Use & Behavioral Health Providers

I have been avoiding writing about the second draft of the Meaningful Use of Electronic Medical Records (EMRs) definition released by the federal Health IT Policy Committee on July 16. I had been hoping I would hear something that would make me believe the definition would in some significant way benefit our customers. I am disappointed to report that it still appears that the ARRA stimulus funds for adoption of EMRs will be largely unavailable to behavioral health providers, except psychiatrists, unless some change is made through regulation.

Just to clarify my statements above: ARRA provided $19 billion in funding for EMRs. $2 billion will be provided to the states to distribute for grants. Community Behavioral Health Organizations (CBHOs) are included in the eligible organizations for these funds. Unfortunately, it appears that this funding is going to be used by the states where they see fit. I have heard from a representative of at least one children’s psychiatric hospital who was told that funding would be used by the state to build Health IT (HIT) infrastructure and data exchange capability. They were informed that providers could get their funds from the incentives. I will be very curious to see how much (if any) of that $2 billion winds up in the hands of providers of any sort.

The larger part of the funding, $17 billion for Medicare and Medicaid incentives, is designed to encourage providers to purchase EMRs and use them to improve the care of their patients. Of the providers eligible to receive these reimbursements, the only behavioral health providers who are eligible are psychiatrists and certain nurse practitioners. They would purchase a system and then receive reimbursements for some or all of what they have spent depending on a variety of complex formulas. If you are a psychiatrist and you do not see Medicaid or Medicare patients, you are not eligible for funding. If you do treat these populations, you will only be able to get funding from one source, Medicare or Medicaid. The amount of reimbursement you can receive depends upon what proportion of your patients are Medicaid or Medicare recipients, along with other complex criteria.

Senator Jay Rockefeller of West Virginia introduced the Health Information Technology Public Utility Act of 2009 in late April. This bill was intended to assure that certain “safety net” providers like rural clinics and mental health providers could also access funds. That bill has not moved. Unless something happens in regulation, it is not likely that psychologists, social workers, mental health counselors, addiction treatment programs, psychiatric hospitals, or community behavioral health service providers are going to benefit from the stimulus funds to help purchase EMRs.

That said, the Health IT Policy Committee did seem to take into account the input they received from the public about the initial attempt at defining “meaningful use of EMRs”. They have drafted a plan that widens definitions, expands time frames, and provides more opportunities for providers to demonstrate that they are using EMRs meaningfully. Their PowerPoint presentation does a good job of summarizing their points. Details can be found in their updated grid and matrix.

1. The primary goal of the definition is to improve the outcomes of healthcare interventions through data capture and sharing and use of advanced clinical processes. They want providers to focus on health outcomes, not on software. HIT is to be a primary aid to healthcare reform, not use of software for the sake of earning incentive money.

2. It is the intention of the committee that there be a phasing in of meaningful use criteria. The public was concerned that if providers could not meet the 2011 criteria in 2011, they would always be behind the train. The committee now recommends that a provider who does not adopt an EMR until 2012 (or 2015) will start at the 2011 criteria and progress from there.

3. Changing work flows to assure the proper use of IT tools is an essential part of the solution. Trying to use CPOE (computerized physician order entry) can actually cause problems if there are not work flow modifications to make sure the process flows smoothly. An unintended consequence of CPOE in at least one study was diminishing of appropriate care because it was inconvenient to enter the order for the care.

4. Since data-based decision support is the real payoff of using an EMR, the committee wants to see this happen sooner, even it if means implementing only one rule in the decision making process.

5. Since engaging patients in their care is crucial to reduction in costs, providing access to an electronic version of their health record needs to be higher priority and come earlier in the process than previously envisioned.

6. Certification of software should be done by more than one body; CCHIT should not be the sole arbiter of which products should be certified.

While the Health IT Policy Committee has now presented their second draft of the “meaningful use” policy, it has until the end of 2009 to finalize the rules. It appears, however, that the direction is set. If you want to get some of the incentive money to help you buy an EMR, you will need to demonstrate that you can use that EMR and can report a variety of metrics to show how your practice is handling a number of issues. So far, none of those metrics are vaguely related to mental health.

Do you expect your organization/practice to be seeking incentive funding to purchase an EMR? How are you proceeding to assure that outcome? Do you think it is important for behavioral health to be included in the adoption of EMRs?

Just click on the title of this article and enter your comments in the box a the bottom of the page. Thanks for sharing your thoughts.

Wal-Mart and Mental Health EMR: Unlikely

For the past week the health IT news world (NYTimes; Chicago Sun Times; MSN; ) and blogosphere (FierceHealthIT; Healthcare Informatics) have been abuzz with Wal-Mart’s announcement that they will begin selling electronic health record (EHR) software to doctor’s offices starting this Spring. They will do so in partnership with eClinicalWorks and Dell through their Sam’s Club stores.  

Our initial reaction was panic. After all, if the world’s largest retailer decides to get into our market space, how can we possibly survive? And what does this mean for our customers?

Then we started reading the fine print. The cost for the first physician in the practice will be $25,000 plus $10,000 for each additional physician. The first year’s price includes hardware, installation, some training, technical support, and a variety of other odds and ends. And that is for software as a service. That means you do not own a license for the software; rather you connect into the company’s system and maintain your records there.  (This is the model that some people believe is the only viable one for a broad national system, but many dispute that.) After the first year, the cost per doctor is $500 per month.

John D. Halamka, M.D., CIO of the CareGroup Health System and Harvard Medical School among many other posts, is convinced that this pricing is fair and that Wal-Mart’s expertise in supply chain management and their own experience with IT systems inhouse will make their coordination of this project a success. In fact, he says that its a “good deal“. 

While this sort of price point might be cost effective and competitive for general and speciality medical physician practices, it is certainly not so for those in behavioral health practices. Most community based behavioral health organizations are also not likely to find this pricing structure something they can build into their budget.

If this is the Sam’s Club bargain software, where does that leave mental health providers? While there are currently a few companies with very reasonably priced electronic medical records (EMRs) aimed at the behavioral health community, time will tell whether meeting the requirements for CCHIT certification and paying to acquire that certification will allow the products of this small cadre of companies to remain affordable.

What’s your take on the Wal-Mart announcement? Where do you see this search for the EMR going for you? 

To add your comment, click on the title of the article and enter your thoughts in the box at the bottom of the page.

 


ARRA’s New Privacy and Security Requirements

I was all set to write an article Monday morning on the expanded privacy and security requirements in the American Recovery & Reinvestment Act of 2009 (ARRA) when I remembered that I was registered for a webinar presented by FairWarning (a privacy surveillance company) Monday afternoon on just that subject. I am really glad I waited to write, because this webinar provided a wealth of information on the new requirements. [By the way, you will also see this section of ARRA (Title XIII) referred to as the Health Information Technology for Economic and Clinical Health (HITECH) Act. Subtitle D contains the Privacy provisions.]

Many people and organizations have opined that EHRs will not take hold in general medical settings or in behavioral healthcare until consumers and providers trust that the EHR products and the means of transferring data are truly secure and protect the privacy of the patient. Webinar presenter Deven McGraw, of the Center for Democracy & Technology, most articulately presented the aspects of ARRA that will increase the privacy and security requirements that healthcare providers must follow. She indicated changes in four broad areas including substantive modifications to HIPAA statutory requirements, increased enforcement of HIPAA, provisions to address health information held by entitites not covered by HIPAA, and a variety of administrative changes.

The new law incorporates and expands upon the HIPAA requirements.

  • There has been an attempt to more clearly define certain terms, like just what a “breach” of privacy is.
  • Previously, covered entities where the only ones required to report breaches of privacy; now the same requirement is placed upon Business Associates.
  • HITECH strengthens the individual’s right to restrict disclosures of health information to their insurance plan and even allows the individual to “opt out” of electronic recording and sharing of their information if they pay for their services privately and in advance. Mental health services are frequently cited as  sensitive content that an individual may want left out of their electronic record.
  • The HIPAA mandate requiring that a provider not release psychotherapy notes to the insurer has been included in this act, and the Secretary of Health and Human Services (HHS) has been ordered to study whether psychological test data should be included in this exception.
  • ARRA improves upon the HIPAA “minimum necessary” standard requiring that only the minimum amount of patient information should be disclosed depending upon the specific request for information.
  • The legislation places requirements upon companies that provide Personal Health Records (PHR) for the security of the data in those records, and prohibits the sale of protected health information.
  • Most importantly, the law provides an ongoing process for setting privacy and security standards and evaluating their effectiveness. 

brief summary of these changes written by the American Psychological Association was published by Behavioral Healthcare magazine in February.

Perhaps the most important thing behavioral health providers need to realize is that the move toward mental health EHRs is happening. How exactly those records will interface with the rest of the National Health Information Network and exactly what information will be shared with other healthcare providers remains to be seen, but this endeavor is irrevocably marching forward. Where will you be in this process?

To comment on this article, click on the title and insert your comment in the box at the bottom of the page.

Behavioral Health EHR: Dream or Reality, Obstacle or Asset

Last month I wrote an article about movement toward Electronic Health Records (EHR) in the behavioral health community. I was stunned by your silence on the issue. So much of my energy for the past two years has been focused on EHRs, their use in general medicine and in mental health, that I was very surprised that our readers were not interested in discussing EHRs. I am not sure whether the booming silence was a reflection of denial about movement toward these products, lack of information about them, or some other factors. So let’s start with some information.

In May, 2003 the President’s New Freedom Commission on Mental Health reported that the mental health community has been much slower to adopt Electronic Medical Records than the general medical community in spite of the potential benefit for consumers being just as great. The Commission concluded that a substantial effort should be made to develop the infrastructure to support interoperable electronic medical records and personal health records, and that the behavioral health community should move forward with adoption of appropriate products.

Early in 2006, a SAMHSA (Substance Abuse and Mental Health Services Administration)-funded Behavioral Health EHR Profile Workgroup, a multi-stakeholder effort to develop an EHR Conformance Profile for behavioral health began work. I joined that workgroup early in 2007 and participated through the adoption of a standard for Behavioral Health EHRs by HL7 this past summer. The Certification Commission for Healthcare Information Technology (CCHIT) has formed the necessary workgroup to develop testing and certification standards for Behavioral Health EHRs and plans to begin such certification by summer 2010.

The thinking about EHRs and their benefit are multiple. Primarily, they are believed to improve the quality of care by minimizing errors and duplication, by providing decision support for the provider, by offering evidence-based practice options, and by making all that information available rapidly to other providers. Adding Personal Health Records (PHRs) into the mix and connecting everything by way of a National Health Information Network (NHIN) or Health Information Exchanges (HIEs) will provide real-time information access for both consumers and providers of health care services.

The election of Barack Obama has spurred lots of discussion about the direction that healthcare reform will take. He mentioned electronic medical records in speeches and debates, but there is not yet much information about how he will pursue policy in that arena. The current financial crisis and recession will undoubtedly take priority over healthcare reform, but the cost of healthcare makes it a pressing issue for everyone.

I have heard providers talk about EHRs in widely varied ways. Some (including some of our customers) have used software products to maintain their clinical records for years and would not want to practice without one. Some clinicians believe that such a product would create obstacles to best care of their clients. Others are concerned about workflow interruption and the amount of time it might take to utilize an EHR. And those of us who work in the industry and are clinicians by training have major concern about privacy and security of health records generally and EHRs in particular.

What are your thoughts about EHRs? Do you see them becoming a part of the picture for your organization? Do you have a plan for purchase of such a product? Do you already use an EHR? How well does it do the job for you? Please let us know your thoughts. What providers think and how they plan to behave will control how this all unfolds.

You can comment on this post by clicking on the title of the post and entering your Comment in the form below.

Thanks for your thoughts.