May 09, 2012

The American Hospital Association Letter

On April 30, the American Hospital Association issued a 68 page letter to CMS outlining their response to the Meaningful Use NPRM.

There are elements of the letter I can appreciate - implementing electronic medication administration records and bedside medication verification can be expensive for a hospital that has not yet begun the process, especially the 1300 critical access hospitals in the US.

Implementing some aspects of interoperability require using technologies that are very new.   Vendor products will need to be enhanced to support efficient health information exchange workflows.

However, as David Blumenthal said with stage 1 of Meaningful Use, we have to set the pace of the policy "escalator" so that it gets us to our destination with reasonable speed but not so fast that passengers fall off.   In my view, the AHA sets the speed too slowwith its patient and family engagement language:

"Patient Portal. CMS proposes as a new objective: provide patients the ability to view online, download, and transmit information about a hospital admission. The AHA recommends that this objective be removed for two reasons: (1) CMS does not have regulatory authority over patients’ access to their health records; and (2) the objective is not feasible as specified."


"Remove the measure on patient use of the portal to both minimize measurement burden and eliminate a provision that makes provider performance contingent on actions of others."

Patient and Family engagement is an area that needs to be pushed aggressively if progress is to be made.  The fears and myths about the burden and expense of implementing it are unfounded in my experience.   Unless we ramp up the policy "escalator" in the patient/family engagement area, vendors will not innovate and providers will not overcome their inertia.

What do I mean?

When the telephone was introduced, there was fear in the medical community that it would disrupt doctor patient relationships.  History has shown that It did not.

When secure email and patient portals were introduced, clinicians believed the burden of communications would escalate.   It did not.

When BIDMC began sharing notes with patients there was fear of litigation, misunderstanding, and level of effort to support patient questions.   Nothing bad happened.

BIDMC has had a patient portal in place since 1999 that does everything required in the Meaningful Use 2014 edition NPRM language.   60,000 patients per month have used it for over a decade.   They can view their records in real time, send secure email, make appointments, refill prescriptions, request referrals, and access numerous patient specific educational materials.   20% of our patients send secure email and look up their records - double the threshold recommended by the NPRM.

The technology is simple and the impact on the hospital (cost, workflow, burden) has been insignificant.

As the spouse of a cancer patient, I can describe firsthand the critical importance of PHRs.   Kathy has navigated her entire cancer care experience by using the BIDMC patient portal to track her care plan, her treatment progress, and her diagnostic test results.   She's securely communicated with her clinicians and accessed patient educational materials.   True, we built this system ourselves in 1999 with a budget of less than $50,000, but today's commercial products such as Epic's MyChart, and eClinicalWorks Patient Portal offer similar functionality.

I'm passionate about patient and family engagement.

I hope that the public response to their letter will encourage the AHA to reconsider their  patient engagement recommendations and ensure they carefully consider the patient record access provisions in upcoming recommendations coming from the Office of Civil Rights.   I welcome the opportunity to share the experiences of early PHR adopters with AHA membership.

Working together as an industry, we can manage the concerns voiced by AHA membership.   I encourage us to push the limits of the "escalator" on  patient and family engagement policies/technologies.   My wife's treatment and patients everywhere depend on it.

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