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hsph_logoNext Monday I’ll be participating in the Public Health & Technology (PHAT) Forum at the Harvard School of Public Health, an event by and large organized by Harvard’s Public Health grad students.  I feel honored to be moderating the afternoon panel that will address “Patient Empowerment Through HIT.”  Last I heard, there were still a few openings left so if you are in the area, encourage you to attend this event.

Organizers have put together a top notch panel that includes:

Esther Dyson, well known in consumer health IT circles and now on the Advisory Panel of the new e-Journal, the Journal for Participatory Medicine.

Steve Munini, COO of the employer led health platform Dossia.  Steve hosed Chilmark’s recent visit to Dossia for an in-depth briefing resulting in the post, “Round Two: A Dossia Update”

Fred Smith, from Centers for Disease Control and Prevention (CDC) where he leads the interactive media team within CDC’s National Center for Health Marketing.

George Willock, CEO and co-founder of the employee health & wellness service HealthString.  Had the pleasure to be briefed by George at their offices in Chicago, which was quite uplifting after a pretty depressing visit to the HIMSS annual conference.

While I have not prepared any specific questions for the panelists, yet, I have broken down my ideas into three thematic areas (Note: as roughly 50% of the audience will be grad students, I have tried to target thoughts and questions towards exposing and reflecting on what the future may hold and less on yesterday and today):

Innovation: An ever increasing array of consumer-facing, healthcare apps, devices and services are entering the market enabling a citizen to take on more direct responsibility for managing their health and/or the health of a loved one. Such innovation empowers the citizen and making them less dependent on a healthcare provider. How will this change the role of healthcare providers in the future?

ARRA, Meaningful Use & Digital Records: The federal government is investing some $36B+ into digitizing the healthcare sector.  Unfortunately, virtually all of this is going directly to hospitals and healthcare providers and little has been discussed or earmarked directly towards citizens, with the exception of “meaningful use,” and even that remains fuzzy.  What will the impact be to care, citizen empowerment, and more broadly healthcare reform through the digitization and distribution of medical records?  What are the risks and are we adequately prepared to meet them?  In five years time will we see a much deeper engagement between citizens and clinicians as a result of this investment?

Provider-centric vs. Patient/Citizen-centric Care: As citizens are being asked to take on an ever increasing responsibility for their care (insurance co-pays, health incentives, disease mgmt, etc.) and are given the tools (HIT) for greater empowerment, we ill see a shift from a provider-centric care model (and IT architecture that goes with it) to one that is patient/citizen-centric. What does this shift mean to current HIT architectural models?  How will this shift impact future care delivery models?

Yesterday’s post took a look at the future for the Health Information Exchange (HIE) market putting forth the projection that successful HIEs will move towards a platform as a service (PaaS) cloud computing model. Market forces (meaningful use) and simple logic are driving this transition.

Since putting up the post, Chilmark has received several emails from HIE vendors; without exception, all state that they are now moving in this direction.

But what yesterday’s post failed to mention were some of the likely challenges HIE vendors will face in making this transition.  The figure below outlines the top three we foresee.

PaaS challenge

What do you foresee as the top three challenges for incumbents? Will new entrants simply leapfrog over incumbents or as in the past, will these new entrants simply burn up a lot of cash/resources and walk away from this market (this seems to have repeated itself in the HIT sector numerous times) with little to show for all their efforts?

A bit miffed right now with the Huffington Post.

A couple of weeks ago I was interviewed by one of their reporters regarding the proposal to rename and refocus the federal government’s National Health Information Network (NHIN) the Health Internet.  The reporter did a fine job on the article, well researched, well written and I was quoted.

Problem was my attribution.  Initially, the article read John Moore, healthcare blogger.  No, that is incorrect I told the reporter on Monday.  I am an industry analyst and founder of the analyst firm Chilmark Research LLC.  I requested that they change the attribution to reference my affiliation to Chilmark Research.  No go. The best they said they could do was to reference me as an analyst.

Now if it were an analyst firm like Gartner, Forrester, heck even IDC, they would likely reference these firms along with the analyst quote.  So why not a small firm such as Chilmark Research that is relatively new to the market?  No answer.

I even argued that numerous publications including InformationWeek, Health Data Management, HealthIT News, the AMA, and many others recognize Chilmark Research as a viable firm. And certainly my clients, including several Fortune 500 firms also recognize Chilmark Research.

So what gives Huffington Post?  Why do you choose not to acknowledge a small firm?  Again, no answer.

And to think, I once thought Huffington Post was a truly reputable eZine.  They have certainly slipped a few notches in my book.

iaas-paas-saasAn interesting, and somewhat overlooked press release came out last week from the health information exchange (HIE) vendor Axolotl wherein they announced that a third party independent software vendor (ISV), eHealth Global Technologies, would be available on top of the core Axolotl HIE application, Elysium Exchange.  The new app, Elysium Image Exchange allows for secure image exchange among HIE participants.  Though the new application may appear like nothing more than Axolotl contracting out the building of an app desired by its HIE customers, there is a more here than meets the eye.

HIE Vendors as Future PaaS for Clinical Needs

Independent HIE vendors (not part of a larger EMR vendor) such as Axolotl, Covisint, dbMotion, InterSystems, Medicity and RelayHealth are in a unique position to become more than just an HIE focusing on the exchange of clinical records but could become Platform as a Service (PaaS) vendors providing a wide range of services and apps on top of their core infrastructure, OS and App Server stack.  The following two figures illustrate what is possible should these vendors open up their application programming interface (APIs) to allow other ISVs to build apps on top of their HIE platform.

HIE1

HIE2

HIE vendors are in an ideal position to become a PaaS for they already have the key features necessary.  As aggregators and distributors of clinical data in a secure fashion, these vendors have the core infrastructure already in place.  They have the data repository, they have the master patient index (MPI) and they understand what is required to address privacy and security requirements of data exchange within a network.  What these vendors, by and large have not done is open their APIs to third party ISVs to truly create a PaaS.

In speaking with Axolotl’s president Glenn Keet he stated that they came to the realization that they alone could not move fast enough to meet the needs of the market.  While they currently offer an CCHIT certified “EMR lite” for small physician practices there are a multitude of other services that they foresee.  For example, within the “meaningful use” criteria that physicians will need to demonstrate to receive reimbursement for EHR adoption, there are a number of quality reports that must be created and filed with CMS.  Keet envisions ISVs leveraging Axolotl’s APIs to create services to automate such reporting.  Meaningful use criteria also will require physicians to sponsor a PHR for their customers.  Again, with an open API, PHR ISVs could sit on top of the Axolotl (or other HIE vendor) platform and provide such capabilities. Clinical decision support (CDS) tools are another app/service that would be ideally suited to sitting on top of an HIE PaaS.

Microsoft is another vendor who is now venturing in to the HIE market with its Amalga platform, which is the foundation for the Wisconsin HIE (WHIE).  Using its core Amalga UIS along with HealthVault, Microsoft could also create a clinical PaaS with a multitude of ISVs providing services to the physician market. To date and to our knowledge, this has not occurred but we’re pretty sure Microsoft is looking into providing such capabilities as it would be in alignment with other actions that they have done to date in the healthcare sector.

What this may portend is the creation of PaaS that support the concept of substitutable apps as laid out by Ken Mandle and Issac Kohane of Children’s Hospital Informatics Program (CHIP) Boston. Another proponent is David Kibbe with what he refers to as Clinical Groupware a concept he first described back in Febuary 2009.  In each of these examples, the dominant theme is the move away from monolithic EMR/EHR apps to small, lightweight apps that are invoked when needed.  More information on this concept can be found at the recently created site: ITdotHealth (Note: Unfortunately, at the recent meeting at Harvard Medical School, Health Information as a Platform, which was organized by Mandl and Kohane, outside of Microsoft, there did not appear to be any representation from HIE vendors.)

An Opportunity for RHIOs to Become Viable?

A lot of effort and money is now being poured into the build-out of public Health Information Exchanges (HIEs) that are commonly referred to as Regional Health Information Organizations (RHIOs).  While many see it crucial to build out this information exchange infrastructure to support care coordination (a key criteria for stimulus funding reimbursement for EHR adoption), the challenge for RHIOs has been to create a business plan that insures long-term viability of a RHIO once grant funding drys up.  The market is littered with failed, failing and simply struggling RHIOs.  Recently, while sitting in on a conference call where a State RHIO discussed their go-live plans a question was asked: Do you have a model for sustaining the RHIO long-term?  To which the Executive Director of the RHIO replied, No.

But might not a RHIO that is actually a PaaS for a given region or State, become a provider of Clinical Groupware including a range of services and applications such as multiple lightweight EMRs to choose from, say one for pediatrics, another for orthopedists, a third for general practioners, quality reporting services, a range of CDS apps, etc. charging a small transaction fee for the use of such services and thereby begin to create viable service-based business? We think so and see this as the next evolution in the HIE market.

Halloween Treat in DC

halloween

On my way to the Metro to attend the mHealth Summit came across this Halloween-themed protest against payers and in support of healthcare reform.  They had the haunted music blaring, the megaphone manned by a Zombie.  How fitting in these times of great controversy regrading reform and just a tad ironic as I headed to a healthcare event where the technology being discussed may lower health disparities and in its own small way contribute to healthcare reform.

Learnings from mHealth Summit

mHealthOver the last two days, been attending the Foundation for the NIH’s event, the mHealth Summit.  This being its inaugural year, the event has been covering a wide gambit of issues, but the majority of panel sessions, keynotes and what not have focused on the use of mHealth tech for addressing public health needs in developing countries.

Key Take-Aways:

mHealth is clearly a top priority of the Obama Administration. Rare that an inaugural event would attract HHS Secretary Kathleen Sebelius as keynote speaker when so much is happening on the Hill regarding healthcare reform. In addition to the Secretary, day two had a keynote by US Ambassador Elizabeth Fawley Bagley.  Brian Dolan of mobihealthnews.com did a nice write-up on the Secretary’s keynote.

mHealth initiatives in developing countries do not have a sustainable business model, all are grant funded. Big problem here as the researchers are not structuring their research to collect the data needed to justify the investment(s) and subsequently define sustainable business models for the mHealth technology they have deployed. Crazy!  This is not basic research folks and those funding these initiatives need to be more diligent in reviewing proposals to insure that such data types (hard and soft savings metrics) are collected. (For a counter view on this issue read ICTworks post on the topic. FYI, ICTworks is part of inveceo, a small company formed out of Josh Nesbitt’s, who is a Stanford student, work in Africa. Josh gave one of th better presentations at this event, very inspiring.)

African countries want a platform that allows them to build mHealth apps that address the priorities they chose in a manner that reflects their culture. Consultants and pre-packaged, shrink-wrap solutions need not apply. (Note: OpenMRS appears to be gaining wide popularity in developing countries.)

Most mHealth efforts/research & roll-out, at least expressed at this event, are very narrowly focused on one disease state. Research has borne out time and again that the vast majority of those with a chronic condition and many with an episodic condition suffer from some other co-morbidity, particularly in the realm of mood disorders.  More work is required to build out these mHealth apps to be still simple to use, but also multi-faceted to address whole health.

There are some really outstanding results in the use of mHealth. One of many examples presented: A public health texting service in South Africa addressing AIDs and TB awareness, encouraging those at risk to call public health clinic, resulted in call volume increase of over 300% to public health clinics that has not subsided.

Iterative user interface design is critical. Those deploying mHealth solutions in the field have found that designing the user interface (UI) is not trivial by any means (is it ever?) requiring an iterative process as one is dealing with very small real-estate inherent in mobile devices.  End users often get icons wrong, mis-enter info, do not complete sections if too lengthy, etc. But even in designing that UI, take user inputs with a grain of salt as users often prefer UIs that they use incorrectly.

Mobile tech may well be the silver bullet to address healthcare disparities. While there has been a significant amount of attention/discussion on health disparities that may arise via Internet-based consumer-facing healthcare services, mHealth apps may provide a balance as both African-American and Hispanic communities in the US are far more heavier users of mobile tech than Caucasians.

This was a good event, but like any inaugural event, there are always a few bugs to work-out.  Hopefully next year’s event (November 9-10) will more effectively address new technologies and modalities that will support mHealth initiatives (most tech on display here is re-purposed tech from 10yrs ago) and expand to include discussions on real outcomes, sustainable business models and consumer-facing mHealth apps with real consumers talking about their personal experiences.

As we’ve said many times in our writings:

Health is Mobile

Health does not occur when you are in front of your computer, it is a part of your every day life and actions. There is tremendous promise in mHealth apps but this market is still extremely young, nascent and immature.  A lot of experimentation occurring today but in a 2-4 years this experimentation will convert into vibrant business models.  Mobile apps will be the future of much of health, wellness, and care.  Any company/software vendor worth their salt in the healthcare space better damn well have a mobile strategy on their white board or they may well become irrelevant.

Round Two: A Dossia Update

dossialogoLast Friday had the chance to meet up with the folks at Dossia, the personal health platform (PHP) formed by a consortium of employers. Purpose of the meeting was to get a deep dive update on Dossia and learn more about what they have done in the last year or so since they went live with Wal-Mart in fall 2008.

Since that go-live, Dossia has been fairly quiet, though they did announce two new “founding members” and released the open API this past summer. But frankly, not much to write home about.

Despite being the first “out the door” PHP, several months ahead of Microsoft’s formal announcement of HealthVault in early October 2007, Dossia has floundered.  First was the break-up with their first development partner, Omnimedix which led to Dossia forming a relationship with Children’s Hospital, Boston to use the open source Indivo PHP.  After nearly a year of work with the Indivo team, Dossia finally had WebMD linked into Dossia.  This integration between WebMD and the core Indivo-based Dossia platform was done under some pretty tight deadlines to meet Wal-Mart’s aggressive roll-out schedule – as part of their annual fall health fairs for employees across the country.  The push led to a less than ideal integration with the WebMD, an integration that could not be readily duplicated with any other third party independent software vendors (ISVs).  Thus, Dossia’s desire to build an ecosystem of apps on top of their PHP was put into stasis as the Dossia team focused on the Wal-Mart roll-out.

A year later much has been learned.

Dossia discovered that Indivo V3.2 was not fully scalable to meet large enterprise needs.

The Indivo platform was developed by Harvard Med School academics to test the concepts and policies associated with a patient-controlled health record system.  Prior to Dossia’s adoption of Indivo, the platform had seen small scale implementations at Children’s Hospital, MIT’s on-campus hospital and at Hewlett-Packard in association with a flu vaccination study. In each of these implementations, no ecosystem of apps was deployed via a common and open application programming interface (API).  This is understandable as Indivo was structured to test concepts, not necessarily structured for large scale commercial roll-out.

Since last fall, the Dossia team hired a completely new team of developers (size of Dossia team on par with Google Health ~15-18 FTEs), completely re-architected their platform to meet scalability requirements, addressed user interface (UI) issues (Indivo lacked a modern, intuitive interface), and developed a stable API that ISVs could use.  On October 15th, the new platform/UI went live.

The new API was released at the end of June and there are now 20 ISVs modifying their apps to sit on the Dossia platform.  As of today, in addition to WebMD, Dossia has eClinicalWorks (eCW is used in Wal-Mart’s retail & corporate clinics – don’t forget that eCW is also being sold through Sam’s Club), Healthtrio, Medikeeper and Metavante, who had acquired CapMed, live on the platform.

Indivo platform did not adequately address the myriad of state laws relating to record consent and sharing for teenagers.

Last year’s Wal-Mart roll-out was targeted at just employees. No incentives were provided, it was completely left up to the employee as to whether or not they wished to participate.  While Wal-Mart obtained “favorable” adoption, a key desire of employees was to have a Dossia account not only for themselves but also for their dependents. This desire led to some fairly significant challenges for Dossia in providing the appropriate consent structure for teenage dependents where State laws vary significantly.  These new consent requirements were built into the new platform as well.

Employers wanted support for dental records.

Another request from employer consortium members was the ability to support dental record data.  As part of the platform rebuild, Dossia has also embedded a dental data schema.  To the best of our knowledge, Dossia is the only PHP who has this capability today.

User interface needed to be simpler, more intuitive to provide easy access to personal health information (PHI).

During the meeting, Dossia provided a demo of its new interface, which was very simple to navigate, ranking on par with Google’s and a more intuitive experience than that of HealthVault.  Dossia has a slight advantage here in that employers define which apps employees have access to and upon sign-up populate an employee’s account with their claims and pharmacy benefits management (PBM) data.  For either Google Health or HealthVault, most consumers must go through the actions of loading their own data, choosing their own apps, etc., to establish a viable and personally value producing account.  This is similar to the adage “with freedom comes responsibility.”

Challenges Remain:

Dossia has made impressive progress since its initial launch last fall.  They have addressed the scalability issue, they have finally released an open API for ISVs to create an ecosystem of future apps and several other consortium members will be going live on the platform in the near future.  Despite these gains, challenges remain.

Where’s the lab data?

While Dossia has the ability to support clinical data in either CCR or CCD formats, today they are only importing claims and medication data from PBM firms.  Dossia, like Google Health and HealthVault does not support images today.  In somewhat of a surprise, Dossia also does not currently support lab data imports from either Quest or LabCorp.  This is a surprise for two reasons: First, viewing labs online has been found to be one of the most desired attributes of a a personal health account and secondly, both Google and Microsoft can import lab data from either of these national testing labs that represent some 80%+ of all labs done in the US.  If Google and Microsoft can do it, why not Dossia?

What’s the value proposition for employers?

Chilmark still struggles to understand what the value proposition is an employer to adopt the Dossia platform for their employees. Yes, Dossia may be a non-profit looking to provide a common platform that will provide employers more flexibility in the health-related tools (PHRs, HRAs, wellness apps, etc.) they can offer their employees to better manage employee health and wellness, but is that enough? Today, few employers see the strategic advantage of providing even the simplest of such tools (e.g. a WebMD account, an online wellness program, a disease management program that actually works, etc.) to their employees. If it is difficult for them to see value here, how can they realistically make the leap to considering a health platform with an ecosystem of apps?

And the value prop for employees is…?

Yes, the interface is much improved and yes, PHI data is automatically imported into an account and an employee’s Dossia account is fully their own, but beyond that, why would an employee sign-up to have an account? What other attributes and services does Dossia provide that are attractive to a consumer? According to Kaiser-Permanente and others, those who adopt and use such system use them to look at their lab data and conduct simple transactions such as Rx refills and appointment scheduling, all features that Dossia does not support.  So again, the value for a consumer in using Dossia is?

A couple of suggestions:

Rev up the marketing engine

If Dossia’s claims are indeed true, that the platform is stable, scalable and open to third party ISVs to build-out the ecosystem, then it is time for Dossia to become more aggressive on the marketing front.  Who better to market Dossia than its consortium members?

To date, Dossia’s consortium members have been extremely quiet and they are arguably, Dossia’s strongest marketing partner.  But if Dossia’s founding members are not out there promoting the platform, clearly stating the value proposition they see in being a member and even, as in the case of Wal-Mart, begin talking about the successes they have seen since launching Dossia, then how is any other employer suppose to buy-in to the concept?

And a concept it is for there are few in the industry today, including health benefits management firms and consultants, that fully understand what the ecosystem/PHP model represents and the value it may deliver to employers over the long-term.  The best advocates, the best marketing Dossia can receive at this critical juncture, is the vocal support of its members. So where are they?

Get the labs

Ability to access, view and share lab data is one of the top features that early adopters of PHRs and PHPs appreciate.  Dossia needs to get this issue addressed immediately. End of story.

Delivery a value proposition that employees will appreciate and use

Critical to the success of the most popular personal health systems in the market today are their ability to support transactional processes.  While it would be extremely difficult, if not impossible for Dossia to support such functions as appointment scheduling, Rx refills, eVisits with one’s primary care doctor, there is one transaction area where they could excel: providing health-related financial decision support tools.  Such tools would provide support for health savings accounts, plan deductables and balances, pricing transparency for common procedures, medications, etc., special employee health discounts, and the list goes on.   There are a number of interesting apps now entering the market that provide such capabilities and Dossia would be wise to focus on these ISVs providing an added level of assistance to get them on-board quickly.

Wrap-up:

Walking into the briefing, expectations were quite low for what we might hear from Dossia. Their quiet, reclusive nature, lack of partners, and seemingly little progress being demonstrated to the market left one thinking that Dossia will fade over the next couple of years.  The briefing put many fears to rest.  Dossia is proceeding ahead at a careful measured pace and has accomplished much over the last year.  It is far too early to count them out.

But will Dossia ultimately succeed, will they be a force to be reckoned with will they become a key market influencer?

Still too early to tell.  The platform is stable, the API is there for third party ISVs and with Dossia representing over 8 million potential users (employees) this is a market nearly 3x the size of the most popular PHR today, that of Kaiser-Permanente – a very sizable and attractive market for most any ISV.  But without strong vocal support (marketing) by executives of its consortium members, Dossia will struggle to make its presence known, struggle to clearly articulate its value proposition and struggle to influence the market and subsequently drive market adoption among employers on behalf of their employees.

frustrationThis has been a year that I will not be sad when it is laid to rest.

In June I fractured my right heel while hiking in Tevas. (Note to self, if you are hiking, where hiking boots!). July rolls around, a number of stressful events occur and I end up with some sort of stress related, intestinal nightmare. Been on Prilosec for last couple of months, saw GI last week, endo scheduled for mid-December.  Then, in a charitable act I do the local benefit ride, Hub on Wheels, only to go down in a wet corner, fracturing right wrist and receiving a nasty laceration above right eye.

How many separate institutions have been involved in my care over the last six or so months (physicians, clinics, lab and hospitals)?

Heel, 2: Radiologist and podiatrist, each separate practices.

Intestinal problem, 2: Primary care doctor (clinic), lab work, (clinic), specialist (Boston Medical Center).

Bike crash, 2: Trauma/ER (Brigham & Women’s), plastic surgeon (Faulkner Hosp.), orthopedist (brigham & Women’s).

Six separate institutions, each with their own separate systems, distinct policies and procedures for gaining access to/copies of one’s records.  And in my initial inquiries, I’ve yet to find any of these institutions that will provide my records neatly packaged in a common CCD or CCR format on a CD or USB that I could then easily upload into my personal health platform (PHP).  All institutions stated I can certainly get a copy, but it will require going to separate offices, facilities, filling out release forms what have you to get those records, and they will be, rum roll please…

on paper.

Since none of the institutions mentioned above have a relationship with either Google Health or HealthVault, if I want my information stored in one of these accounts, I will have to enter the information myself or use one of the services on these platforms (Health Postbox Express or yourHealth), which you can send your records to (or automatically retrieved from your clinician) and they’ll upload your personal health records for a small fee.

My God that seems like a lot of work. I work in this industry and find this task of collecting my records daunting.  Is it any wonder that consumer adoption of these platforms and PHRs in general is so lackluster?

There is a sliver of hope in that the meaningful use requirements for HIT adoption under ARRA do support consumer access to their records and better yet that physicians provide their customers a PHR in 2013 (still don’t know what that PHR might be, could be a disaster if it is nothing more than a tethered, portal view into EMR), but that still does not overcome the basic challenge for just about anyone:

  • How do I get copies of my records?
  • How do I know my records are complete and accurate?
  • If the records are incomplete or inaccurate, how do I rectify?
  • What format (standard) should I ask for if I have a choice?
  • How do I get these records into my personal health record account?

These may seem like basic questions, but they are very real and there is no clear and compelling document out there today (if you find one please provide a link in comments section) that lays it out in plain English (or other language of your choice).

Google Health, HealthVault, WebMD, Dossia and PHR vendors are you listening?

What the market needs, heck what I need is a clear and concise QuickStart Guide that addresses the questions above. Any takers?

consumer_controlLast week, HHS sent a notice to a limited number of people in the healthcare space soliciting their comments on a Draft Requirements Document for Consumer Preferences.  The Draft seeks to establish a common framework allowing a consumer to define (preferences) how their personal health information (PHI) will be shared within the context of EHRs, HIEs and more broadly, the NHIN (Health Internet). The Draft Requirements, will ultimately be used to “inform the future development of certification criteria…”

A couple of things surprised Chilmark Research regarding the Draft.  First, that distribution seemed limited to those that had signed up on the HHS site to receive any notices.  Secondly, and more importantly, was the very limited time-frame for submitting comments, they are due Oct. 16th.  Having downloaded and read the 40+ page document, following is our assessment.

While the scope of Customer Preferences addressed seems adequate:

The Consumer Preferences Requirements Document describes a framework for the electronic exchange among multiple stakeholders of the preferences consumers may have regarding the management of and controlling access to their information and potentially sensitive health information (SHI) utilizing standard message formats, terminologies and data sets. The scope of this Requirements Document includes a high-level description detailing:

  • Key actors involved in the expression and creation of consumer preferences, namely the consumers, providers and organizations handling this information
  • Descriptions of the expression, transmission and application of consumer preferences
  • How consumer preferences are exchanged between electronic systems
  • The exchange of health information authorized by a consumer preference
  • The potential types of consumer preferences
  • The location of a consumer preference’s origin and storage.

And understand why they did not wish to address:

  • The details surrounding consumer education processes and requirements
  • The process for reconciling situations where multiple, conflicting preferences exist for one consumer/patient
  • The consequences of not following appropriate consumer preference procedures as prescribed by state, local or entity policy

Chilmark was quite surprised that these requirements decided not to address:

  • Policies regarding whether or not a consumer preference is expected to be honored or accepted when sent from one entity to another
  • The process and requirements for classifying and segmenting an individual’s demographic and clinical information in a way that supports that individual’s expressed preferences regarding what information or data types should be designated as sensitive health information

While both are critical, the first is a particularly thorny issue.  What happens when a consumer defines clear preferences to their provider, the provider shares the consumer’s PHI with another provider for care coordination, a key “meaningful use” criteria under ARRA? Today there are no rules beyond HIPAA (if they are a covered entity or business associate) as to what that second provider/receiver of PHI may do with the consumer’s data.  HHS’s decision not to address this issue head-on is a serious case of “dropping the ball.”

The second point is almost as important.  As the ultimate owner and trustee of their PHI, the consumer ought to be able to decide what information is shared and with whom.  One’s podiatrist may not need to know that the consumer contracted an STD in college, however, this is information one should share with their PCP.  Granted, to keep it simple, HHS may have decided to postpone addressing this issue until a later date as today, it is extremely rare to find the capability to discretely tag data within a PHI repository for sharing.  Regardless, if indeed this Draft Requirements document is to be used in the context of “certification criteria” discrete data tagging will need to be addressed within the next 2-3 years.

Arguably, the most interesting section and thought provoking section is Section 4: Issues and Policy Implications.  It is here that the authors take a closer look on what consumer defined preferences mean to the broader healthcare market and outstanding issues that require careful consideration.  Chilmark found sub-section 4.4 particularly interesting.

4.4 Segmentation of Health Information
1. Clarification may be needed for consumers to explain the protections relating to and the differences between Sensitive Health Information (SHI), Protected Health Information (PHI) and Individually Identifying Health Information (IIHI). A national discussion that explores the definition of sensitive health information and how that information might be classified would help to advance the meaningful creation and use of standards and policies for identifying and managing these different classes of information. Public education is necessary to insure that consumers know first what their rights are, second what information they have and how it may be used. Not so sure we need to educate the consumer on these various classes of data as what may be SHI to one, is PHI to another.  Give the consumer credit to figure that out on their own but do educate them on their core rights to their PHI and sharing thereof.
2. A universal process or policy may be needed for classifying sensitive health information for the purposes of upholding consumer preferences. This may include a common taxonomy for defining elements that collectively articulate consumer preferences within electronic health records and other data stores.  To make the defining and sharing of customer preferences work a common taxonomy is certainly necessary.  We would go on to state that within that taxonomy, let’s insure that the consumer again has a clear understanding of what they are sharing.  This issue will become particularly critical as we look to allowing the consumer to define preferences at the level of discrete data elements of their record.
3. A national policy or standard may be needed to address a consistent method of expressing consumer preferences within the varying state laws and healthcare entity policies. These policies accommodate varying levels of granularity and protections among states and prescribe conflicting levels of responsibility. A harmonized method to accommodate the variances in consumer preferences policies may be required for interoperability.  Oh boy, ain’t that the truth.  Today, the myriad of state and local laws, in addition to those at the healthcare facility level make it extremely difficult to define and share consumer preferences across the continuum.  This will not be easy to accomplish, but is absolutely necessary not only for consumer preferences, but more broadly for care coordination regardless of physical location.

The Wrap:

All in all, we found the Draft Recommendations to be a good piece for beginning the national discussion of how consumers will define and share their PHI sharing preferences.  There are some pretty significant gaps that the creators purposely decided not to address but if this document will ultimately be used to set certification criteria, these gaps must be addressed now to set the stage for true consumer ownership of their PHI and ultimately a true consumer-driven healthcare system.

itriage

iTriage is a slick iPhone app that we first took a look at back in April.  A couple of weeks back we had a chance to meet with the CEO, Dr. Peter Hudson (yes, he’s an ER doc who still practices medicine) who was in Boston to attend a conference.  During that meeting, Peter gave us a brief update on progress to date, including their recent announcement with HCA to become a premier listing service for South Florida.  Following is what we learned.

Since its launch in April 2009, iTriage has maintained an enviable position as one of the top downloaded apps in the iPhone AppStore, currently in the top 10% of all apps downloaded.  When one thinks about all the 35,000+ apps currently available and some 1 billion apps downloaded to date, that is pretty impressive for a small company.  Clearly, they must be doing something right.  That being said though, if they are such a popular app, why don’t they at least show up on the AppStore Health & Wellness or Medical sections in the list of top paid apps? Curious.

The parent company’s (Healthagen) business model is to solicit providers, mostly large integrated delivery networks (IDNs) to become premier sponsors who pay an annual subscription fee (based on number of hospitals & clinics) to Healthagen to have their facility listed along with some brief marketing content, including the ability to upload videos, as to why one would want to go to their facility (typically ER) versus others. Thus, Healthagen is tapping into the marketing budgets of IDNs. With home offices in Colorado, Healthagen has done a good job of landing the big IDNs in Colorado including Centura Health.

On October 5th, HCA announced that they would become a premier sponsor as well for their facilities in South Florida.  What is particularly cool about this announcement is that in addition to the standard promotional marketing content that one may find in iTriage on a given HCA facility, HCA will also be providing real-time information on expected wait-times in ER, right there in the palm of your hand on your iPhone and in a recent upgrade of the software, a Blackberry as well.  (In November, they’ll release versions for Android and PalmPre.) This is all part of a larger push by HCA, which includes posting wait-times on billboards in this region to drive consumers seeking medical attention to their facilities as a significant percentage of those admitted to ER wind up being admitted for more extensive care.

Granted, someone having a heart attack will dial 911 and go to the nearest facility, or as in my recent case, choose a hospital known for excellent care based on a recommendation (the EMT that treated triaged me suggested I go to Brigham & Women’s as they have the physicians to treat nasty cuts, in my case a plastic surgeon stitched me up). But there may be other cases where someone who is feeling ill and cannot get an appointment with their primary care physician or are on travel, may find this feature useful.

Now, if I can only get something like a change:healthcare feature embedded into iTriage for costing information, a medication checker like PharmaSURVEYOR or DoubleCheckMD (who knows, maybe that new med I was prescribed is causing all the grief) to evaluate current meds I am on and while we are at it, a more user friendly mobile interface (yes, they do have an avatar on the Web) then we really would have one powerful app to support consumer-driven healthcare.

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