Comments for Federal Advisory Committee Blog http://healthit.hhs.gov/blog/faca Federal Advisory Committee Act Thu, 09 Feb 2012 16:20:22 +0000 http://wordpress.org/?v=2.9.2 hourly 1 Comment on Kudos to Our Federal Advisory Committees by Spencer http://healthit.hhs.gov/blog/faca/index.php/2012/02/08/kudos-to-our-federal-advisory-committees/comment-page-1/#comment-5711 Spencer Thu, 09 Feb 2012 16:20:22 +0000 http://healthit.hhs.gov/blog/faca/?p=489#comment-5711 I listen to the Implementation Workgroup, the Standards Committee, and a few others. I love the work everyone has done, and especially Judy! I listen to the Implementation Workgroup, the Standards Committee, and a few others. I love the work everyone has done, and especially Judy!

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]]> Comment on HITSC Seeks Comments on Exchange Specifications by December 15, 2011 by Jan Root http://healthit.hhs.gov/blog/faca/index.php/2011/11/09/hitsc-seeks-comments-on-exchange-specifications-by-december-15-2011/comment-page-1/#comment-5347 Jan Root Thu, 15 Dec 2011 21:16:21 +0000 http://healthit.hhs.gov/blog/faca/?p=482#comment-5347 I should condition my comments with the understanding that I am not the technical person who implemented UHIN's connection to the VA via the Exchange protocol so I am relaying their comments. We are very excited about the Nw-HIN Exchange functionality. It will solve many of UHIN's cross-country exchange challenges. We are hoping to us it to connect to Quality Health Network in Western Colorado to the Idaho Health Data Exchange, among others. However, as with most things HIT, particularly any new process, there were significant challenges in the implementation. Our HIE vendor, Axolotl chose to build a connection using the Exchange documentation. Apparently, the documentation was never tested (unfortunately, a common problem in IT) and hence contained some serious discrepancies. I believe we are still working on the last of the bugs but are nearly there. I believe there were some significant problems with the testing as well. Apparently the testers were not as familiar with the 'built from the documentation' form of the Exchange and hence, were not particularly helpful in trouble-shooting problems. From what I heard, it was quite frustrating. Our experience illustrates a common problem in HIT: poor documentation, particularly for new processes. It also illustrates another problem. IT people are very bright and hate to say "I don't know how to do that". So, they say "I can do that" even when they can't. Until that protocol becomes widespread in its use, HIT professionals will struggle with implementing it. We are also having the same problem with Direct. It is also not 'easy'. I hope this is helpful. I should condition my comments with the understanding that I am not the technical person who implemented UHIN’s connection to the VA via the Exchange protocol so I am relaying their comments.

We are very excited about the Nw-HIN Exchange functionality. It will solve many of UHIN’s cross-country exchange challenges. We are hoping to us it to connect to Quality Health Network in Western Colorado to the Idaho Health Data Exchange, among others.

However, as with most things HIT, particularly any new process, there were significant challenges in the implementation. Our HIE vendor, Axolotl chose to build a connection using the Exchange documentation. Apparently, the documentation was never tested (unfortunately, a common problem in IT) and hence contained some serious discrepancies. I believe we are still working on the last of the bugs but are nearly there.

I believe there were some significant problems with the testing as well. Apparently the testers were not as familiar with the ‘built from the documentation’ form of the Exchange and hence, were not particularly helpful in trouble-shooting problems. From what I heard, it was quite frustrating.

Our experience illustrates a common problem in HIT: poor documentation, particularly for new processes. It also illustrates another problem. IT people are very bright and hate to say “I don’t know how to do that”. So, they say “I can do that” even when they can’t. Until that protocol becomes widespread in its use, HIT professionals will struggle with implementing it.

We are also having the same problem with Direct. It is also not ‘easy’.

I hope this is helpful.

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]]> Comment on HITSC Seeks Comments on Exchange Specifications by December 15, 2011 by David Tao http://healthit.hhs.gov/blog/faca/index.php/2011/11/09/hitsc-seeks-comments-on-exchange-specifications-by-december-15-2011/comment-page-1/#comment-5327 David Tao Tue, 13 Dec 2011 20:35:10 +0000 http://healthit.hhs.gov/blog/faca/?p=482#comment-5327 Thanks for the opportunity to comment. We always appreciate the FACAs being open to listening to the experiences of those who are involved in implementing information exchange. We emailed our specific responses to all 14 questions (to ONC.request@hhs.gov). I've copied below our reply to question #14, "What other questions do you wish we had asked...?" 14. We wish the questions were not narrowly focused only on experiences with NwHIN Exchange specs. Maturity and usability of the Exchange specs should not be considered only in the context of cross-community exchanges. Many more vendors, including us, have much more development experience and live production experience in community-based HIEs using XDS, XDR, PIX, PDQ, etc. Those successful experiences mean that expanding to cross-community access using NwHIN Exchange is much easier because it’s just the next logical step. While many providers are not yet connected to community-based exchanges, we believe that this is the logical sequence: walk before you run, start locally and then expand to NwHIN Exchange. Thanks for the opportunity to comment. We always appreciate the FACAs being open to listening to the experiences of those who are involved in implementing information exchange. We emailed our specific responses to all 14 questions (to ONC.request@hhs.gov). I’ve copied below our reply to question #14, “What other questions do you wish we had asked…?”

14. We wish the questions were not narrowly focused only on experiences with NwHIN Exchange specs. Maturity and usability of the Exchange specs should not be considered only in the context of cross-community exchanges. Many more vendors, including us, have much more development experience and live production experience in community-based HIEs using XDS, XDR, PIX, PDQ, etc. Those successful experiences mean that expanding to cross-community access using NwHIN Exchange is much easier because it’s just the next logical step. While many providers are not yet connected to community-based exchanges, we believe that this is the logical sequence: walk before you run, start locally and then expand to NwHIN Exchange.

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]]> Comment on HITSC Seeks Comments on Exchange Specifications by December 15, 2011 by HIT Standards Committee and HIE Specifications : HITECH Answers Meaningful Use http://healthit.hhs.gov/blog/faca/index.php/2011/11/09/hitsc-seeks-comments-on-exchange-specifications-by-december-15-2011/comment-page-1/#comment-5104 HIT Standards Committee and HIE Specifications : HITECH Answers Meaningful Use Sat, 26 Nov 2011 21:24:22 +0000 http://healthit.hhs.gov/blog/faca/?p=482#comment-5104 [...] The recommendations call for further investigation of the exchange specifications along with ONC performing more assessment of industry adoption and deployment. And specifically to solicit input from exchange implementers on their implementation experiences. From this the Committee is seeking comments on the subject through December 15th. For more information on and how to comment, see the Federal Advisory Committee blog. [...] [...] The recommendations call for further investigation of the exchange specifications along with ONC performing more assessment of industry adoption and deployment. And specifically to solicit input from exchange implementers on their implementation experiences. From this the Committee is seeking comments on the subject through December 15th. For more information on and how to comment, see the Federal Advisory Committee blog. [...]

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]]> Comment on HITSC Seeks Comments on Exchange Specifications by December 15, 2011 by Thomas Lukasik http://healthit.hhs.gov/blog/faca/index.php/2011/11/09/hitsc-seeks-comments-on-exchange-specifications-by-december-15-2011/comment-page-1/#comment-5047 Thomas Lukasik Sat, 19 Nov 2011 16:04:09 +0000 http://healthit.hhs.gov/blog/faca/?p=482#comment-5047 @R C Johnson RE: "I am working to foster the idea of a single patient record in my community where all physician choose to use the same record for cost, quality and convenience reason" What is the size of your "community", how long has the work that you're doing been ongoing, do you have any early results, and have you published or are you planning to publish your experiences and findings? TJL @R C Johnson

RE: “I am working to foster the idea of a single patient record in my community where all physician choose to use the same record for cost, quality and convenience reason”

What is the size of your “community”, how long has the work that you’re doing been ongoing, do you have any early results, and have you published or are you planning to publish your experiences and findings?

TJL

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]]> Comment on HITSC Seeks Comments on Exchange Specifications by December 15, 2011 by R C Johnson http://healthit.hhs.gov/blog/faca/index.php/2011/11/09/hitsc-seeks-comments-on-exchange-specifications-by-december-15-2011/comment-page-1/#comment-4982 R C Johnson Sat, 12 Nov 2011 13:05:21 +0000 http://healthit.hhs.gov/blog/faca/?p=482#comment-4982 General business moved to enterprise systems during the Y2K era for cost and error reasons. Hospitals are in this transition phase now. I makes no sense to push physicians to adapt a technology platform that is out of date for cost and date reliability and other quality reasons. As a patient it is impossible for me to determine who has a digital file on me, if it is secured properly and with whom the files were shared with. Now I see that data exchanged are setting up standards to exchange data. Having introduced pay-at-the-pump to the market place and having worked in the electronic payments industry in both Europe and the United States I can say without reservation that the health industries approach to automation is one of the largest disservices to the American public ever and should not only be stopped but recinded. On the current path costs will grow and quality will decline. The government may pass all legislation and rules to protect consumers - but it will never have the resources to enforce these rules. Automation was an opportunity to fix all the problems that impact care (fraud, waste, abuse, inappropriate treatments, quality, risk and convenience) and has failed. The data exchange strategy allows vendors to sell more hardware, software and consulting services and does nothing to protect patients from system failure and in-fact puts them at risk by allowing a system to be built that can be so easily breached. Automation should not be about automating a physician's office it should be about automating the delivery process. It should not be driven by hospitals where less than 5% of care occurs. Automation demands are causing physicians to sell their practices to hospitals - putting them under the control of a system that has the highest costs and error rates in the industry and expecting anything less than a new round of cost growth and a further decline in quality is wishful thinking. I am working to foster the idea of a single patient record in my community where all physician choose to use the same record for cost, quality and convenience reason - this is what all patient should demand. HHS has failed to come to terms with the realities of automation which is going to result in a worse health care system than we have today. I encourage the agency to stop all data exchange efforts immediately so that it may reevaluate the path it has chosen. A single patient record is the only model that makes economic and quality sense. General business moved to enterprise systems during the Y2K era for cost and error reasons. Hospitals are in this transition phase now. I makes no sense to push physicians to adapt a technology platform that is out of date for cost and date reliability and other quality reasons.

As a patient it is impossible for me to determine who has a digital file on me, if it is secured properly and with whom the files were shared with. Now I see that data exchanged are setting up standards to exchange data. Having introduced pay-at-the-pump to the market place and having worked in the electronic payments industry in both Europe and the United States I can say without reservation that the health industries approach to automation is one of the largest disservices to the American public ever and should not only be stopped but recinded. On the current path costs will grow and quality will decline. The government may pass all legislation and rules to protect consumers – but it will never have the resources to enforce these rules.

Automation was an opportunity to fix all the problems that impact care (fraud, waste, abuse, inappropriate treatments, quality, risk and convenience) and has failed. The data exchange strategy allows vendors to sell more hardware, software and consulting services and does nothing to protect patients from system failure and in-fact puts them at risk by allowing a system to be built that can be so easily breached.

Automation should not be about automating a physician’s office it should be about automating the delivery process. It should not be driven by hospitals where less than 5% of care occurs. Automation demands are causing physicians to sell their practices to hospitals – putting them under the control of a system that has the highest costs and error rates in the industry and expecting anything less than a new round of cost growth and a further decline in quality is wishful thinking.

I am working to foster the idea of a single patient record in my community where all physician choose to use the same record for cost, quality and convenience reason – this is what all patient should demand. HHS has failed to come to terms with the realities of automation which is going to result in a worse health care system than we have today.

I encourage the agency to stop all data exchange efforts immediately so that it may reevaluate the path it has chosen. A single patient record is the only model that makes economic and quality sense.

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]]> Comment on Creating a Vision for Engaging Patients and Families Through the Meaningful Use of Health IT by rachell http://healthit.hhs.gov/blog/faca/index.php/2010/04/14/creating-a-vision-for-engaging-patients-and-families-through-the-meaningful-use-of-health-it/comment-page-7/#comment-4518 rachell Wed, 28 Sep 2011 19:37:30 +0000 http://healthit.hhs.gov/blog/faca/?p=214#comment-4518 That's part of why the Health Information Technology Policy Committee (HITPC) That adviser recommended ONC patient / family engagement as one of the five health outcome Meaningful Priorities for use (MU) of EHRs. Several relevant CMS and Objectives included in the Proposed Rule MU released it in January (comments from More Than 2.000 Organizations and Individuals are Currently Being reviewed by CMS and ONC): Hopefully all of that and there is awareness of the health of people on politically challenging. That’s part of why the Health Information Technology Policy Committee (HITPC) That adviser recommended ONC patient / family engagement as one of the five health outcome Meaningful Priorities for use (MU) of EHRs. Several relevant CMS and Objectives included in the Proposed Rule MU released it in January (comments from More Than 2.000 Organizations and Individuals are Currently Being reviewed by CMS and ONC): Hopefully all of that and there is awareness of the health of people on politically challenging.

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]]> Comment on HIT Policy Committee’s Information Exchange Workgroup Seeks Comments by Robert Sherman http://healthit.hhs.gov/blog/faca/index.php/2010/09/21/hit-policy-committee%e2%80%99s-information-exchange-workgroup-seeks-comments/comment-page-3/#comment-4513 Robert Sherman Tue, 27 Sep 2011 20:07:55 +0000 http://healthit.hhs.gov/blog/faca/?p=326#comment-4513 This proposal is a complete invasion of privacy. It gives HHS yet again information that spouses are not afforded each other. 1. Thanks to HIPPA, spouses do not have access to each other's records without filling out government required forms year after year. And if you forget to fill out the form, your spouse does not have a right to the information. Senator Schumer's office, Steve, was requested to correct this really horrendous shortcoming. If spouses do not want each other to have access, they can fill out paperwork as an exception. 2. None of the proposed regulations available on HHS web site or the release on HHS web site explains in plain simple English that patient records will be electronically sent to HHS. All regulations should be suspended until HHS figures out how to do this. I also asked Senator Schumer's office to contact HHS to correct this. Whatever regulation is suggesting that HHS compile all records should be reissued. 3. I asked that Senator Schumer change the law to stop this centralized repository of information about people. 20th and 21st History has too many examples of abuses against religious, ethnic and racial groups using central information. 4. Senator Schumer's office was unaware of any possible benefit to the information other than having it all in one place. Doctors who do not fill out electronic forms would not have to participate, unless they law provides that they go to jail and his rep was not sure that would occur. He had no answer to the problem of hacking and agreed that hacking has been a problem in the past. I asked that the regulation, whatever it is, be stopped and the law be changed. It is an invasion of privacy to provide information without consent to the government in this case. Hacker's would then have access to steal identity from virtually everyone in the country. 5. Senator Schumer's office indicated a private company would handle the database. A private company in Iowa processes medicare claims for New York. Are the employees bonded and finger printed and are they checked against FBI data bases to ensure that they who they say they are and have no criminal background? And are these the requirements of anyone in or out of the government that will have access to people's records? If so where is it in a regulation and and is it written in plain simple English? 6. What penalty will the government or its private contrator pay individuals for use of their information or identity theft? What disciplinary actions are spelled out for government or contractor employees who access information that patients did not specifically authorize? Is there a record being maintained of each employee who accessed a patient's record, the date, time, computer and location of it? Will government and contractor employees be able to remove the information from government offices, download it to a computer, access it from a non-government office location, etc.? What is the penalty for the employee or the IT tech support personnel if that happens? 7. Insurance companies are regulated by state commissioners. There rates are set by them and they have the ability to audit the companies. This seems to be an attempt to overlay state regulation with an additional federal bureaucracy that has not regulatory authority. It is a waste of taxpayer dollars. 8. If a patient gets sick in another state, doctors are all to willing to exchange information with the treating physician in a very quick period of time. That's what they are trained to do. Government workers are not interested in the well being of patients. An excellent example of that is the lack of clear intent about centralizing records with HHS, no plain English explanation of regulations, regulations that are not complete without cross referenced to other regulations and not written in plain English or not providing spouses or parents and children with access to each other's records and limiting it only on exception. 9. There isn't even a method of contacting Secretary Sebilus on the HHS web site indicating that even she isn't concerned about patients. This proposal is a complete invasion of privacy. It gives HHS yet again information that spouses are not afforded each other.
1. Thanks to HIPPA, spouses do not have access to each other’s records without filling out government required forms year after year. And if you forget to fill out the form, your spouse does not have a right to the information. Senator Schumer’s office, Steve, was requested to correct this really horrendous shortcoming. If spouses do not want each other to have access, they can fill out paperwork as an exception.
2. None of the proposed regulations available on HHS web site or the release on HHS web site explains in plain simple English that patient records will be electronically sent to HHS. All regulations should be suspended until HHS figures out how to do this. I also asked Senator Schumer’s office to contact HHS to correct this. Whatever regulation is suggesting that HHS compile all records should be reissued.
3. I asked that Senator Schumer change the law to stop this centralized repository of information about people. 20th and 21st History has too many examples of abuses against religious, ethnic and racial groups using central information.
4. Senator Schumer’s office was unaware of any possible benefit to the information other than having it all in one place. Doctors who do not fill out electronic forms would not have to participate, unless they law provides that they go to jail and his rep was not sure that would occur. He had no answer to the problem of hacking and agreed that hacking has been a problem in the past. I asked that the regulation, whatever it is, be stopped and the law be changed. It is an invasion of privacy to provide information without consent to the government in this case. Hacker’s would then have access to steal identity from virtually everyone in the country.
5. Senator Schumer’s office indicated a private company would handle the database. A private company in Iowa processes medicare claims for New York. Are the employees bonded and finger printed and are they checked against FBI data bases to ensure that they who they say they are and have no criminal background? And are these the requirements of anyone in or out of the government that will have access to people’s records? If so where is it in a regulation and and is it written in plain simple English?
6. What penalty will the government or its private contrator pay individuals for use of their information or identity theft? What disciplinary actions are spelled out for government or contractor employees who access information that patients did not specifically authorize? Is there a record being maintained of each employee who accessed a patient’s record, the date, time, computer and location of it? Will government and contractor employees be able to remove the information from government offices, download it to a computer, access it from a non-government office location, etc.? What is the penalty for the employee or the IT tech support personnel if that happens?
7. Insurance companies are regulated by state commissioners. There rates are set by them and they have the ability to audit the companies. This seems to be an attempt to overlay state regulation with an additional federal bureaucracy that has not regulatory authority. It is a waste of taxpayer dollars.
8. If a patient gets sick in another state, doctors are all to willing to exchange information with the treating physician in a very quick period of time. That’s what they are trained to do. Government workers are not interested in the well being of patients. An excellent example of that is the lack of clear intent about centralizing records with HHS, no plain English explanation of regulations, regulations that are not complete without cross referenced to other regulations and not written in plain English or not providing spouses or parents and children with access to each other’s records and limiting it only on exception.
9. There isn’t even a method of contacting Secretary Sebilus on the HHS web site indicating that even she isn’t concerned about patients.

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]]> Comment on HIT Policy Committee’s Information Exchange Workgroup Seeks Comments by Rassan Williams http://healthit.hhs.gov/blog/faca/index.php/2010/09/21/hit-policy-committee%e2%80%99s-information-exchange-workgroup-seeks-comments/comment-page-3/#comment-4507 Rassan Williams Mon, 26 Sep 2011 22:38:00 +0000 http://healthit.hhs.gov/blog/faca/?p=326#comment-4507 Great read. I would definitely agree with Lynne. The capability to electronically move clinical information among disparate health care information systems while maintaining the meaning of the information being exchange is essential. I'm always very aware of the amount of double triple work that is being done in the medical field. I had to explain to a new Dr. the test I already had performed on me. If I was not astute I would have been paying again for the same test again. Wondering if having some kind of standard file that could be easily transferred and billed would be easy. I mean the whole country using the same standard? I know, I know red tape, but its worth a try. Thanks for the article Great read. I would definitely agree with Lynne. The capability to electronically move clinical information among disparate health care information systems while maintaining the meaning of the information being exchange is essential.

I’m always very aware of the amount of double triple work that is being done in the medical field. I had to explain to a new Dr. the test I already had performed on me. If I was not astute I would have been paying again for the same test again.

Wondering if having some kind of standard file that could be easily transferred and billed would be easy. I mean the whole country using the same standard? I know, I know red tape, but its worth a try.

Thanks for the article

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]]> Comment on HIT Policy Committee’s Information Exchange Workgroup Seeks Comments by Electronic Prescribing http://healthit.hhs.gov/blog/faca/index.php/2010/09/21/hit-policy-committee%e2%80%99s-information-exchange-workgroup-seeks-comments/comment-page-3/#comment-4119 Electronic Prescribing Fri, 12 Aug 2011 19:11:06 +0000 http://healthit.hhs.gov/blog/faca/?p=326#comment-4119 Simplifying billing, as Lynne said, would alleviate many problems in and of itself. I don't have very many opinions on the technical requirements, as this is all still very foreign to me, however, I would like to commend those who have the courage to step forward and offer their comments. It is a very heated issue that needs to be discussed. Simplifying billing, as Lynne said, would alleviate many problems in and of itself. I don’t have very many opinions on the technical requirements, as this is all still very foreign to me, however, I would like to commend those who have the courage to step forward and offer their comments. It is a very heated issue that needs to be discussed.

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