Readers Write 1/17/11

Submit your article of up to 500 words in length, subject to editing for clarity and brevity (please note: I run only original articles that have not appeared on any Web site or in any publication and I can’t use anything that looks like a commercial pitch). I’ll use a phony name for you unless you tell me otherwise. Thanks for sharing!

Remote Access Is Not Mobile Access
By Cameron Powell, MD

Healthcare organizations are quickly learning that both remote and mobile access strategies are required. See Table 1.

Remote access lets providers work in the hospital computing environment when they are not on location. This includes accessing the EMR and clinical applications via a PC or laptop from office or home. Secure the session with something like VPN, add the necessary authentication and encryption, and clinicians can use their Windows desktop and a browser to interact with hospital applications.

Offer mobile access when you need to empower providers to perform specific tasks anytime, anywhere. This would include visual assessment of images and waveforms, checking lab values, reconciling medication lists, checking allergy status – all while on the go. Providers want the data transformed into meaningful chunks; they don’t want to navigate the medical record from their Droid in order to make timely treatment decisions. Mobile data should be provided via native applications, built to run securely on a specific device and operating system.

Some organizations have considered using Citrix to provide interpreted or emulated application access to the EHR or CIS via a mobile device. Accessing patient monitoring data via a non-native solution is discouraged, because visual distortion is almost certain when things like medical aspect ratios cannot be controlled. [1] Further, the FDA is mandated to regulate mobile devices. [2], [3]

Mobile versus Remote Access

References

[1] http://ahealthydoseofmobility.com

[2] http://www.ebglaw.com/showarticle.aspx?Show=12184

[3] http://www.law.uh.edu/healthlaw/perspectives/2010/kumar-fdamobile.pdf.

Cameron Powell, MD is president, chief medical officer, and co-founder of AirStrip Technologies of San Antonio, TX. 

Transcription Today
By Diligent Monk

Transcription is back.

As EMR adoption picks up in response to Meaningful Use, it is worth noting that lurking in the shadows is a familiar enemy to EMR companies: transcription. The age-old practice of dictating for capturing clinical observation is the most efficient, accurate, and preferred method for physicians to document a patient encounter.

Over the past few months, announcements from large organizations have signaled a return to relevancy for the transcription industry. IBM, Nuance, 3M, HealthStory Project, major universities from around the globe, and many other dominant players in the transcription service industry have made significant strides in utilizing technology to create more value from transcripts.

Enter the transcription technology revolution.

Partnering the skilled labor of transcriptionists with technology produces a rich and accurate dataset from a traditional transcript. Whether labeled natural language processing (NLP) or discrete reportable transcription (DRT), the concept is quick, simple to understand, and the value is just now being seen by the industry at large.

Using extensible mark-up language (XML), data is pulled from transcripts and provided in common transport standards (CCR, CCD, CDA) to be used in EMR systems and reports. A physician can dictate his/her notes and collect all of the data required for meeting the objectives and measures for incentive payment per the HITECH Act without purchasing an EMR.

Historically, the EMR sale was built on an ROI derived from transcription savings. Looking at a practice or hospital balance sheet, the transcription bill seemed to be the easiest to pick on, and with the point-and-click interface promoted by EMR vendors, it was a straight replacement for clinical documentation. EMR adoption would eliminate transcription costs. As an industry, the transcript was losing its relevancy in an age of electronic records, but physicians and practices weren’t thrilled with the results. And back to the revolution.

Permitting a physician to dictate in their preferred and normal manner, coupled with the ability to ‘tag’ the data elements of importance from the note, provides the best of both worlds.

Unfortunately, this does nothing to eliminate that pesky transcription charge, which is still the focal point of many EMR pitches. The transcription industry, however, counters that the prevention of productivity loss will more than cover the cost of their services and therefore be a win-win for all involved. As well, the risk of errors in reports is significantly decreased by the medical language specialists that review documents for clinical quality and integrity before submitting back for approval from the physicians.

As crazy as this sounds, and as hard to believe as it may be, transcribing may be the best way for practitioners to achieve Meaningful Use and the most cost-effective for their practice. The technology continues to improve and adoption continues to be strong, so yes, transcription doesn’t appear to be going away, and that may be a good thing.

FDA Comes to HIT… But Through the Back Door
By Frank L. Poggio

For several decades, there has been a raging debate as to whether HIT systems should be regulated by the FDA. A search of HISTalk on ‘FDA’ brings up hundreds of mentions. Some clinicians believe FDA oversight is desperately needed; others feel it would be a major detriment to new development.

Now the debate is over. It came earlier this month through a back door called ONCHIT, probably while you were sleeping.

On January 7, ONCHIT issued the Permanent Certification Program Final Rules PCPFR. These are the rules that will transfer the testing activities from the ‘temporary’ agencies to ‘permanent’ ones as of January 2012. On the surface, you would think these rules would impact only the companies like CCHIT, Drummond, InfoGard, etc. But our creative friends at CMS–ONCHIT went many steps beyond that.

Here are some highlights from a vendor perspective.

A new entity was created called the ONC-AA called the Approved Accreditor agency. The current ATCB will be changed to ACB, or Authorized Certification Body.

In a nutshell, the ACB administers the test and the AA oversees the ACB. Today under the temporary rule, the ATCB does both. What is now a one-step process will become in 2012 a two-step process for software firms seeking certification. The AA will also be the agency that selects and contracts with the ACBs for testing services (such as CCHIT, Drummond, etc.) 

The new ONC-AA is required to insure that the ACBs conduct ‘surveillance’ of certified vendor products. Surveillance is CMS’s way of saying ‘audit’.

Here’s how the surveillance will work. The AA can walk unannounced into an ACB office and review all certification documentation, or can randomly sit in on tests. More importantly, the AA or ACB can audit at will, unannounced, the MU criteria out in the field at the providers shop to ensure the certified system really does what it was certified to do.

And it doesn’t stop there. Similar to the FDA processes, any user of a certified system (provider clients or their employees) can file a complaint directly with the ONC-AA or ACB stating that the vendor’s installed certified system DOES NOT MEET the certification criteria. At that point, the AA will conduct an investigation at the site and make a determination whether the vendor’s certification should be pulled.

If so, as with the FDA, press releases to that effect will be circulated. OUCH! Better start thinking about stronger client support in the future and set up internal channels to catch the gripes before they get so bad a user wants to scream ‘ONCHIT’.

On of my friends called this the ‘HIT Whistle Blower Act’, a good description. It’s just like the FDA: if a device or drug has an unexpected adverse impact, anyone can file a complaint. I hear a train a coming …

Frank L. Poggio is president of The Kelzon Group.