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	<title>Comments on: Our Meaningful Use Comments</title>
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	<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/</link>
	<description>Providing perspective on key IT trends in the healthcare sector</description>
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		<title>By: Remember: Technology is but a Tool &#124; The Health Care Blog</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-7195</link>
		<dc:creator><![CDATA[Remember: Technology is but a Tool &#124; The Health Care Blog]]></dc:creator>
		<pubDate>Wed, 30 Mar 2011 17:01:17 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-7195</guid>
		<description><![CDATA[[...] would be one of the greatest challenges in adoption and use of EHRs and recommended to ONC in our 2009 comments that ONC consider relaxing the schedule to allow to allow sufficient time for process [...]]]></description>
		<content:encoded><![CDATA[<p>[...] would be one of the greatest challenges in adoption and use of EHRs and recommended to ONC in our 2009 comments that ONC consider relaxing the schedule to allow to allow sufficient time for process [...]</p>
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		<title>By: Remember: Technology is but a Tool &#124; Health</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-7194</link>
		<dc:creator><![CDATA[Remember: Technology is but a Tool &#124; Health]]></dc:creator>
		<pubDate>Wed, 30 Mar 2011 16:43:13 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-7194</guid>
		<description><![CDATA[[...] would be one of the greatest challenges in adoption and use of EHRs and recommended to ONC in our 2009 comments that ONC consider relaxing the schedule to allow to allow sufficient time for process [...]]]></description>
		<content:encoded><![CDATA[<p>[...] would be one of the greatest challenges in adoption and use of EHRs and recommended to ONC in our 2009 comments that ONC consider relaxing the schedule to allow to allow sufficient time for process [...]</p>
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		<title>By: Remember: Technology is but a Tool &#171; Chilmark Research</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-7188</link>
		<dc:creator><![CDATA[Remember: Technology is but a Tool &#171; Chilmark Research]]></dc:creator>
		<pubDate>Tue, 29 Mar 2011 22:32:34 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-7188</guid>
		<description><![CDATA[[...] would be one of the greatest challenges in adoption and use of EHRs and recommended to ONC in our 2009 comments that ONC consider relaxing the schedule to allow to allow sufficient time for process [...]]]></description>
		<content:encoded><![CDATA[<p>[...] would be one of the greatest challenges in adoption and use of EHRs and recommended to ONC in our 2009 comments that ONC consider relaxing the schedule to allow to allow sufficient time for process [...]</p>
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		<title>By: Stay Tuned, Meaningful Use Part Deux Forthcoming &#171; Chilmark Research</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-3198</link>
		<dc:creator><![CDATA[Stay Tuned, Meaningful Use Part Deux Forthcoming &#171; Chilmark Research]]></dc:creator>
		<pubDate>Thu, 16 Jul 2009 13:28:08 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-3198</guid>
		<description><![CDATA[[...] the HIT Policy Committee along with some 900+ written comments in the comment period that followed (here&#8217;s Chilmark Research&#8217;s own comments).  The meaningful use workgroup chaired by Paul Tang and Farzad Mostashari (don&#8217;t be [...]]]></description>
		<content:encoded><![CDATA[<p>[...] the HIT Policy Committee along with some 900+ written comments in the comment period that followed (here&#8217;s Chilmark Research&#8217;s own comments).  The meaningful use workgroup chaired by Paul Tang and Farzad Mostashari (don&#8217;t be [...]</p>
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		<title>By: Privacy Lawyer</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-3139</link>
		<dc:creator><![CDATA[Privacy Lawyer]]></dc:creator>
		<pubDate>Wed, 01 Jul 2009 16:01:14 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-3139</guid>
		<description><![CDATA[I like the patient centric access comments because at the end of the day it is the patient that needs empowerment. Patients will no longer tolerate being treated as a sideshow to be dictated to by the government, insurance companies and providers.

Also, the focus on small practices is critical. The adoption of EHRs will force small providers to pay attention to the HIPAA Security Rule in a way that will overwhelm them by an order of magnitude vis-a-vis there attempts at compliance with HIPAA Privacy Rule.]]></description>
		<content:encoded><![CDATA[<p>I like the patient centric access comments because at the end of the day it is the patient that needs empowerment. Patients will no longer tolerate being treated as a sideshow to be dictated to by the government, insurance companies and providers.</p>
<p>Also, the focus on small practices is critical. The adoption of EHRs will force small providers to pay attention to the HIPAA Security Rule in a way that will overwhelm them by an order of magnitude vis-a-vis there attempts at compliance with HIPAA Privacy Rule.</p>
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		<title>By: John</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-3132</link>
		<dc:creator><![CDATA[John]]></dc:creator>
		<pubDate>Sun, 28 Jun 2009 17:12:30 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-3132</guid>
		<description><![CDATA[Thank you Rob and Jan for your thoughtful comments.  Now in response...

Rob, you raise a good point on what is meant by complete and you are correct in assuming that with the exception of some psych notes, I am referring to the complete record available to the patient/consumer.  2011 may be too aggressive of a schedule for a complete record in light of the cultural challenges that such a move presents, but ultimately this is a goal to strive for.  So for 2011, lets strive for labs, meds, immunizations, allergies and summary record.

As to who actually pays for the PHR, eg is this a cost borne by a practice to create and support such?  No, see two paths here: For those with the resources, they can create/host a PHR for their customers which does have benefits.  For smaller entities, they can facilitate customer&#039;s use of a PHR by providing portability of the record. 

And Jan, while you state that providing the patient their own complete record could lead to greater confusion due to multiple records, is that not what we have today?  A cousin of mine with a couple of serious illnesses has 1 GP and 5 specialists.  She must compile the complete longitudinal record, carries the stack of clinical notes, etc. to each appt to share with the various clinicians for they do not share the info amongst themselves.  Now that is a mess.

What I am suggesting is to take that mess we have today and put it into a digital construct that the patient has complete rights of ownership to and allow them to lead the care effort.  After all, do they not have the most to gain or lose?

That being said, do agree with you that certain safeguards/policies need to be put in place to insure overall public health &amp; safety, e.g., a citizen who has a history of drug abuse, suicidal tendencies, etc.

Again, thank you both for your thoughtful and insightful comments. It will require discussions such as this to reach a comment ground of understanding to indeed move from defensive medicine to one that is inclusive and proactive.]]></description>
		<content:encoded><![CDATA[<p>Thank you Rob and Jan for your thoughtful comments.  Now in response&#8230;</p>
<p>Rob, you raise a good point on what is meant by complete and you are correct in assuming that with the exception of some psych notes, I am referring to the complete record available to the patient/consumer.  2011 may be too aggressive of a schedule for a complete record in light of the cultural challenges that such a move presents, but ultimately this is a goal to strive for.  So for 2011, lets strive for labs, meds, immunizations, allergies and summary record.</p>
<p>As to who actually pays for the PHR, eg is this a cost borne by a practice to create and support such?  No, see two paths here: For those with the resources, they can create/host a PHR for their customers which does have benefits.  For smaller entities, they can facilitate customer&#8217;s use of a PHR by providing portability of the record. </p>
<p>And Jan, while you state that providing the patient their own complete record could lead to greater confusion due to multiple records, is that not what we have today?  A cousin of mine with a couple of serious illnesses has 1 GP and 5 specialists.  She must compile the complete longitudinal record, carries the stack of clinical notes, etc. to each appt to share with the various clinicians for they do not share the info amongst themselves.  Now that is a mess.</p>
<p>What I am suggesting is to take that mess we have today and put it into a digital construct that the patient has complete rights of ownership to and allow them to lead the care effort.  After all, do they not have the most to gain or lose?</p>
<p>That being said, do agree with you that certain safeguards/policies need to be put in place to insure overall public health &amp; safety, e.g., a citizen who has a history of drug abuse, suicidal tendencies, etc.</p>
<p>Again, thank you both for your thoughtful and insightful comments. It will require discussions such as this to reach a comment ground of understanding to indeed move from defensive medicine to one that is inclusive and proactive.</p>
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		<title>By: Jan Oldenburg</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-3128</link>
		<dc:creator><![CDATA[Jan Oldenburg]]></dc:creator>
		<pubDate>Sat, 27 Jun 2009 16:20:49 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-3128</guid>
		<description><![CDATA[You&#039;ve done a nice job, John, of laying out both a practical and challenging vision on meaningful use.

I also agree with Dr. Rob that we have to figure out how to have a meaningful dialogue about both doctor&#039;s needs to have a medical record that they can control and attest to and consumers&#039; desire to own and control their medical record.  Without careful and thoughtful dialogue about what the balance is between those two poles, we run the risk of creating a mess, where we have multiple digital records of an individual&#039;s care, all claiming to have &quot;the truth&quot; about one person&#039;s medical history.  We run the risk of too much noise and not enough clarity.

It may be helpful for all of us to spend time thinking about the use cases in a future world.  Imagine that I get a copy of my record from my doctor&#039;s EHR and place it into a stand-alone PHR, then change, delete, or hide a diagnosis on that record.  Following the Markle Foundation&#039;s principles, there is no indication that I have deleted anything when I present my PHR to my next physician.  Will he/she trust it enough to act on it without verifying everything through costly testing?  In that situation, wouldn&#039;t good medicine indeed be defensive medicine?

It&#039;s certainly true today that doctors never assume that their patients are telling them the whole truth, and that records received from another provider may have HIPAA-authorized omissions, but aren&#039;t we trying to create a future where there&#039;s accurate data and defensive medicine doesn&#039;t need to be standard practice?

I&#039;m hoping that these are some of the issues being explored at the various Health Camps that are taking place.]]></description>
		<content:encoded><![CDATA[<p>You&#8217;ve done a nice job, John, of laying out both a practical and challenging vision on meaningful use.</p>
<p>I also agree with Dr. Rob that we have to figure out how to have a meaningful dialogue about both doctor&#8217;s needs to have a medical record that they can control and attest to and consumers&#8217; desire to own and control their medical record.  Without careful and thoughtful dialogue about what the balance is between those two poles, we run the risk of creating a mess, where we have multiple digital records of an individual&#8217;s care, all claiming to have &#8220;the truth&#8221; about one person&#8217;s medical history.  We run the risk of too much noise and not enough clarity.</p>
<p>It may be helpful for all of us to spend time thinking about the use cases in a future world.  Imagine that I get a copy of my record from my doctor&#8217;s EHR and place it into a stand-alone PHR, then change, delete, or hide a diagnosis on that record.  Following the Markle Foundation&#8217;s principles, there is no indication that I have deleted anything when I present my PHR to my next physician.  Will he/she trust it enough to act on it without verifying everything through costly testing?  In that situation, wouldn&#8217;t good medicine indeed be defensive medicine?</p>
<p>It&#8217;s certainly true today that doctors never assume that their patients are telling them the whole truth, and that records received from another provider may have HIPAA-authorized omissions, but aren&#8217;t we trying to create a future where there&#8217;s accurate data and defensive medicine doesn&#8217;t need to be standard practice?</p>
<p>I&#8217;m hoping that these are some of the issues being explored at the various Health Camps that are taking place.</p>
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		<title>By: ICMCC Website - Articles &#187; Blog Archive &#187; Our Meaningful Use Comments</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-3127</link>
		<dc:creator><![CDATA[ICMCC Website - Articles &#187; Blog Archive &#187; Our Meaningful Use Comments]]></dc:creator>
		<pubDate>Sat, 27 Jun 2009 06:45:06 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-3127</guid>
		<description><![CDATA[[...] Article John Moore, Chilmark Research, 26 June 2009 SHARETHIS.addEntry({ title: &quot;Our Meaningful Use Comments&quot;, url: &quot;http://articles.icmcc.org/2009/06/27/our-meaningful-use-comments/&quot; }); [...]]]></description>
		<content:encoded><![CDATA[<p>[...] Article John Moore, Chilmark Research, 26 June 2009 SHARETHIS.addEntry({ title: &quot;Our Meaningful Use Comments&quot;, url: &quot;<a href="http://articles.icmcc.org/2009/06/27/our-meaningful-use-comments/&#038;quot" rel="nofollow">http://articles.icmcc.org/2009/06/27/our-meaningful-use-comments/&#038;quot</a>; }); [...]</p>
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		<title>By: Rob</title>
		<link>http://chilmarkresearch.com/2009/06/26/our-meaningful-use-comments/#comment-3126</link>
		<dc:creator><![CDATA[Rob]]></dc:creator>
		<pubDate>Sat, 27 Jun 2009 02:29:37 +0000</pubDate>
		<guid isPermaLink="false">http://chilmarkresearch.com/?p=1784#comment-3126</guid>
		<description><![CDATA[Comments:
1.  Define &quot;complete&quot; medical record.  I think that is a bad word as it is difficult to define and involves many parties.  I think a more reasonable goal by 2011 would be to have some interaction between PHR and EMR products.  Our practice is 13 years ahead of most, but is only rolling out some of this within the next 12 months.  There will also be significant physician resistance to &quot;complete.&quot;  If the goal is to get physician adoption, this may stand in the way.
2.  Who is to &quot;provide&quot; the PHR?  I think integration with some of the bigger platforms will allow interaction between physician and patient records.  If the onus is on the physician again, it will make adoption more difficult.
3. My approach would be to make &quot;meaningful use&quot; as broad as possible.  The real goal is to get all physicians using an EMR in a meaningful way (not as a note-taking device).  Once docs are all on EHR, then being more aggressive for connectivity and patient communication will be possible.  I think you put the horse before the cart if you push too quickly for radical change.  This will probably just drive more primary care physicians out of business.  The goal of HITECH is to get docs on quality EMR products.  Once this is in place, much more meaningful and substantial changes can be made.

Truthfully, this seems daunting to me.  If that is the case, it probably would seem impossible for the average doc.

I personally think the debate over ownership of the record could be extremely divisive.  It&#039;s going to be a hard transition for doctors to EMR.  If the perceive that loss of control of their records will be at the end of this road, many if not most will quit.  I am a strongly patient-oriented doc, and I feel the patient advocates don&#039;t really try to understand the doctors&#039; position here.]]></description>
		<content:encoded><![CDATA[<p>Comments:<br />
1.  Define &#8220;complete&#8221; medical record.  I think that is a bad word as it is difficult to define and involves many parties.  I think a more reasonable goal by 2011 would be to have some interaction between PHR and EMR products.  Our practice is 13 years ahead of most, but is only rolling out some of this within the next 12 months.  There will also be significant physician resistance to &#8220;complete.&#8221;  If the goal is to get physician adoption, this may stand in the way.<br />
2.  Who is to &#8220;provide&#8221; the PHR?  I think integration with some of the bigger platforms will allow interaction between physician and patient records.  If the onus is on the physician again, it will make adoption more difficult.<br />
3. My approach would be to make &#8220;meaningful use&#8221; as broad as possible.  The real goal is to get all physicians using an EMR in a meaningful way (not as a note-taking device).  Once docs are all on EHR, then being more aggressive for connectivity and patient communication will be possible.  I think you put the horse before the cart if you push too quickly for radical change.  This will probably just drive more primary care physicians out of business.  The goal of HITECH is to get docs on quality EMR products.  Once this is in place, much more meaningful and substantial changes can be made.</p>
<p>Truthfully, this seems daunting to me.  If that is the case, it probably would seem impossible for the average doc.</p>
<p>I personally think the debate over ownership of the record could be extremely divisive.  It&#8217;s going to be a hard transition for doctors to EMR.  If the perceive that loss of control of their records will be at the end of this road, many if not most will quit.  I am a strongly patient-oriented doc, and I feel the patient advocates don&#8217;t really try to understand the doctors&#8217; position here.</p>
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