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From:
WALLIS Dwight D <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 10 Jul 2009 09:53:46 -0700
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Given some of the comments/characterizations appearing lately regarding
the federal electronic medical records initiative, I did a bit of
research, as I was concerned. It appears that the reality is somewhat
more mundane, quite a bit more hopeful, yet also a bit scary. In other
words, it's a fairly typical (albeit rather huge) records conversion
process. I compiled some of those links - sort of a RAIN guided tour
with notes - to help provide some context. I tended to focus on articles
and sources that are relatively recent - generally within the past 3 - 4
months:

 

The following link may prove helpful. It is a concise explanation of the
federal governments official definition of an electronic medical record
system:

 

http://patients.about.com/od/electronicpatientrecords/a/emr.htm

 

Specifically:

"The federal government has defined a complete EMR system
<http://www.cdc.gov/nchs/pressroom/06facts/electronic.htm>  as
containing four basic functions: computerized orders for prescriptions,
computerized orders for tests, reporting of test results, and physician
notes. An individual doctor's practice, facility or insurance company's
system determines on its own which of those records will be kept, making
it more or less complete. Federal definition has not resulted in a
standard." While I was able to find some information on cloud computing,
large centralized data mining, HIPAA modification etc... I would say
that such information tends to fall into the realm of "vision" or
"punditry" and less the realm of reality. Note, however, that the
legislation regarding this effort is still being hashed out in Congress,
and much of the speculation surrounding this initiative seems related to
that lobbying.

The following is a fairly typical and detailed representation of how
this is being approached within the medical profession, in this case by
opthamologists:

http://www.osnsupersite.com/view.aspx?rid=41469

Note the time frames being discussed, and the emphasis on data
portability between medical devices/systems and within or between
entities. Note also the emphasis on standards development, and the
references to various certication authorities, including the
Certification Commission for Healthcare IT (CCHIT). Compliance with this
particular group's standards is not currently either federally supported
or required. More on this later.

Looks like some big players, such as General Electric, are already
lining up:

http://www.google.com/hostednews/ap/article/ALeqM5iRZ-b-pPFOy9xZY_gVh65P
elrQXgD98R67GO0

As noted, there is a considerable amount of lobbying going on. This next
article may explain some of the fears expressed as a federal report
"shines the light on Google's EMR lobbying efforts". I see very little
indication that this particular lobbying is being effective:

http://www.healthcareitnews.com/news/federal-report-shines-light-googles
-emr-lobbying-efforts

The proposed National Health Information Network may be the "massive
system" people are concerned about:

http://www.eweek.com/c/a/Health-Care-IT/Sun-Software-Key-to-Electronic-M
edical-Records-Network-150901/

This is not a cloud computing proposal, although it's less clear
regarding the potential for data mining (which can be both a good and a
bad thing, depending on how it is used). The NHIN is more a proposal for
a secure data network, in line with the repeated emphasis on data
portability, and, obviously, security is the key. However, let me simply
point out that secure networks are not exactly a new phenomena.
Insurance companies, our national security apparatus, and all sorts of
critical entities have been utilizing them for years.

The speed of this endeavor presents challenges, to say the least,
although most time frames tend to hover in the 5 to 10 year range. This
article from the NYT is one that captures those concerns effectively,
concerns that should be familiar to records managers:

http://www.nytimes.com/2009/03/26/business/26health.html

There are also concerns being expressed about CCHIT (remember them)?
This IT industry group has not yet been specified as the required
standards body (although it could be):

http://www.ihealthbeat.org/Articles/2009/5/21/HIMSS-Calls-for-CCHIT-To-C
ertify-EHR-Systems-Critics-Express-Concern.aspx

I hope this proves helpful in clarifying some of the issues surrounding
this effort. As I mentioned before, we just recently made the transition
to electronic medical records keeping. Our involvement centered on
policy issues such as HIPAA and medical records retention, as well as on
dealing with the legacy hard copy. Regarding the latter, I thought it
might be useful to share our experiences as a sort of "heads up" to
those on this listserv with the responsibility of storing medical
records. It gets into the implications of what these systems are trying
to do, and how they operate, and the impact that will have on your
storage situation. In a nutshell, I'm suggesting that you be prepared
for a potentially large and rapid influx of volume. 

These systems do not result in immediate paperlessness, but they do
result in high volumes of suddenly inactive case files.  Partly this is
due to their reliance more on data abstracting, less on traditional
image capture. To be blunt, this is because one of the principle
problems with current paper based systems isn't necessarily the paper
media; it's the notoriously bad handwriting of doctors. The key
transition here is not the media transition, it's the transition from
handwriting to direct data entry. If you scanned the paper, you would
simply be transmitting the problem into the new system. 

The paper files are kept during a transitional period to provide backup
to correct any errors, or fill any gaps missed in the initial
abstracting stage. This takes time, as its not necessarily practical to
abstract everything, particularly if you are in a high turnover medical
situation where a good percentage of your clientel may never show up
again, or may show up 6 years down the road (the case, for example, with
the outpatient clinics we operate in the county). Moreover, the
incentive to immediately transform low productivity file space into high
productivity medical space is overwhelming and drives this process,
largely because that medical space can generate direct revenue to a far
greater degree than more typical office space. 

In our case, that transitional period is currently set at 10 years.
During this time, the "record copy" will gradually transition from the
paper file into the electronic system - essentially an "abstract on
demand" process. Of course, the accessioning of new files stops to a
large extent (though not entirely), and we anticipate a steady drop in
record actions during this time. Again, this has been our own
experience, but given the nature of these systems, I have a feeling it
may prove to be fairly typical.

I hope this is helpful to folks.

Dwight Wallis, CRM

Multnomah County Records Management Program

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