I'd never heard of Healwell before and took a look over their offerings. Has anyone used the products? Beyond the…
Readers Write 2/15/12
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!
iPad Fatigue: Choose Your Mobile Strategy Wisely
By Chris Joyce
I get the attraction of the iPad … your own personal device that’s sexy and lean, as opposed to the standard-issue, Windows XP desktop locked down by your hospital’s IT group or the clunky computer on wheels. The simple UI and the glossy new apps let you shed the pain of those legacy systems and, most important, you get mobility.
Given the glacial pace of innovation in healthcare, who can fault people for wanting to use these beautiful devices? We are all trying to create a sea change in healthcare IT, much like the iPhone did for telecommunications. But I’m going to say something that’s wildly unpopular: the iPad is not well suited for healthcare in its current state.
I’ve been working in tablet-based mobility for seven years (yes, there were tablets before the iPad). We’ve studied clinician data collection workflow in registration, the ED, home health, cardiology, radiology, orthopedics, and clinical trials. Trust that my opinions are carefully thought out from experience.
I will concede that the Windows-based tablet manufacturers deserved to be smacked around by Apple for their lack of vision and slow progress. Years ago, I, along with my customer (one of the largest health systems in California that had been using tablets in cardiology for years) sat down with the folks at Intel and Motion Computing to tell them that the C5 was too complicated and expensive. I shared what we needed in the ideal tablet: a bright, 12” screen with stylus support that’s ideal for documents, 8-10 hours of battery life, no external ports or other gadgets, and a sub-$1,000 price tag. Our request fell on deaf ears as they paraded out the next incremental chip set improvement in their roadmap.
When the iPad hit the market, we thought we’d finally gotten our ideal tablet. The price was right, the screen was bright, the battery life was unbelievable, it ran coolly and didn’t burn your arms, it booted in seconds, and the 1.5 pound. form factor (half the current tablets) was simple and elegant. Finally, we had the perfect complement to our mobile forms software. This wasn’t just a Windows laptop with the keyboard chopped off – it was an appliance, a tablet.
But it also has some major shortcomings that our customers are now discovering:
10” display
This is subtle because I like the more portable size, but those standard consents, ABNs and Medicare forms you’ve used for years don’t fit on a 10” display without disrupting the layout. Your app has to be “touch-aware” or you’ll interact with the screen when you rest your hand to sign or add a note. Our customers are counting clicks and don’t like the iPad because they have to scroll to use the forms that once fit on their 12” Windows tablets.
No stylus
This makes capturing signatures, annotations on diagrams, and unstructured notes impossible unless you buy a third-party stylus like Pogo. But that’s like writing with a crayon and there is no place to dock your pen. Are your patients going to be comfortable signing an informed consent with their fingers?
No handwriting recognition
The soft keyboard isn’t practical for a lot of data entry because you are still holding the tablet with one hand and pecking out everything with the other. And bouncing back and forth between numeric and alpha characters drives users absolutely mad. Handwriting recognition has its place in documentation, just like voice dictation, and it can be as fast as paper. There is nothing fast about the iPad’s soft keyboard when at the bedside.
Proprietary operating system and deployment isn’t enterprise-friendly
Obviously Apple wasn’t concerned with compatibility with “legacy” apps like Meditech or MS4, but in healthcare, that eliminates about 90% of current systems. Most hospitals have compromised for “runs on iPad” versus “optimized for iPad” using Citrix or a Web interface.
That leaves the end user with an underwhelming experience. Citrix apps don’t get the intimate integration with the display, touch, or the camera for image annotation. Not many vendors were prepared to rewrite their clinical systems in iOS or HTML5. The HTML5 standard hasn’t been published yet and isn’t consistently supported by all browsers (although it is the future). I know of several major healthcare systems that are still standardized on Internet Explorer 7, so I don’t anticipate adoption of HTML5 to be as high in healthcare as Apple would like you to believe. Again, we (healthcare) are not that nimble.
Lack of rugged form factor
Eventually your iPad will come into contact with fluids or the floor and you’ll realize it’s a consumer-grade device. These devices are often in a hostile environment, very unlike the environment in most iPad commercials.
The hype of hardware
One of our best mobile forms customers is a major health system in the Northeast. They gave each clinician an iPad, only to discover that they took them home to watch Netflix versus using them on their rounds. Hardware alone isn’t the answer. You also need software that’s mobile aware.
When you’re developing your mobile strategy, keep this in mind. The iPad is a beautiful device with multiple applications (just not healthcare data collection). It isn’t going to transform your hospital systems’ user experience. But don’t compromise – there are other options to consider. Look for vendors that can fill the gaps in your EMR with mobility solutions optimized for the right tablet for your environment (iPad, Android and/or Windows) and that upgrade your user experience/productivity.
Chris Joyce is director of healthcare solutions engineering for Bottomline Technologies of Portsmouth, NH.
Clinical Decision Support
By Dave Lareau
If you have achieved Stage 1 Meaningful Use requirements or are planning to attest in the future, you are likely aware of the required core measure for implementing and tracking at least one clinical decision support (CDS) rule. The goal of this measure — along with maintaining active problem and medication lists and recording vitals and smoking status — is to improve the quality, safety, and efficiency of patient care.
So what exactly is CDS and why is it important?
In simple terms, CDS gives physicians the clinical information they need for decision-making tasks. For example, during a patient exam, CDS tools can provide prompting to help a doctor determine a diagnosis or select an appropriate treatment plan. Alternatively, a provider may use CDS technology to improve documentation or identify billing codes or determine the most relevant data to forward to a specialist.
CDS technologies are particularly powerful when the engine is mapped to a wide variety of medical concepts and diverse reference and billing terminologies, such as LOINC, RxNorm, SNOMET CT, ICD, and CPT. CDS tools are more robust the wider the engine’s mapping. Strong CDS engines have the ability to identify and interpret patient information from multiple sources, whether the data comes in the form of lab and test results, previous therapies, or patient histories.
It’s important to keep in mind that CDS tools don’t make the actual clinical decisions for a physician, but support a physician’s own decision-making by sifting through existing data and presenting the most relevant information. As more clinical information becomes available online from EHRs and health information exchanges (HIEs), providers will rely more heavily on CDS technologies to identify the most pertinent information for a given situation.
Many commercial EHRs and HIEs have embedded CDS tools to help providers wade through vast amounts of clinical data. CDS technologies work behind the scenes to identify the most clinically relevant information within a practice’s EMR or from a connected reference lab or from HIE records. Search engines consider additional relevant details amongst on thousands of clinical scenarios and then interpret the cumulative data. Physicians are then presented with pertinent information at the point of care and offered details to aid with diagnosis and treatment plans, as well as critical data needed for compliance and reimbursement.
Though Stage 2 Meaningful Use is not finalized, look for the ONC to add additional CDS objectives in the core measures.
Dave Lareau is chief operating officer of Medicomp Systems of Chantilly, VA.
Super-Sized Productivity Gains from Computer-Assisted Coding?
By Akhila Skiftenes
The required migration from the ICD-9 to ICD-10 has significantly increased the demand for computer-assisted coding (CAC), moving beyond its early beginnings in outpatient specialty areas. The potential benefits from using this technology to make the transition to ICD-10 can be very compelling –improved coding productivity, accuracy, consistency, transparency, and compliance.
Yet CAC products require a substantial investment, and implementing one does not a guarantee that these benefits will be realized. Therefore, it is essential for an organization to complete a thorough analysis before investing in a CAC product.
Exceptional productivity gains have been reported by vendors. However, these are based on a number of assumptions and the specific circumstances for the organizations using the system. The following are key considerations when estimating CAC benefits for your organization.
First, estimates are often based on outpatient implementation data. As more and more hospitals move toward using a CAC in their inpatient areas as well, these productivity estimates need to be adjusted accordingly. Inpatient stays are longer and have more variability, making accurate CAC translations much more complex. Vendor products have made great strides toward accurate inpatient coding, but it takes more computing power and more time, so productivity gains will be lower.
Second, CAC works best when the documentation inputs are standardized. There are four standard formats for documentation: consultation note, history and physical, operative note, and diagnostic imaging report. The more variability in documentation formats for your organization, the longer the CAC process will take and the lower the translation accuracy.
Standard medical terminology used by the electronic medical record system also impacts the effectiveness of CAC. Many EMR systems use ICD-9 verbiage rather than SNOMED-CT for physician documentation. In these situations, the CAC application will translate to a lower level of accuracy since SNOMED-CT has a more modern standard for medical terminology and greater levels of specificity.
Finally, there is a general belief built into benefits estimate that optimizing the CAC process is ongoing. Once CAC is implemented, it is vital for the Health Information Management (HIM) department to audit the output and identify any issues with the software’s documentation interpretation. A critical success factor is the working relationship between HIM and IT, with resources assigned on both sides for continued optimization.
When making a decision about CAC implementation and ongoing support, organizations need to incorporate all of these assumptions into the estimate of how much productivity can truly be realized.
Akhila Skiftenes is an associate consultant with Aspen Advisors of Denver, CO.
Virtual Patient Simulation: Strengthening Medical Decisions, Strengthening Outcomes
By James B. McGee, MD
Provide better patient care with fewer resources. Essentially, that is what healthcare reform is asking us all to do. Most providers agree that the only way to maintain the quality of patient care and decrease overall cost is to reduce errors, prevent duplicate or unnecessary tests, and discover more effective yet less expensive approaches to care.
As I see it, that is the simple reality we all have to work within. The real question is: what does it mean from a practical standpoint?
It means that the modern delivery of medical care is far more structured, more measured, and more reported on than I—or anyone—ever could have imagined. Even the most recently educated providers now have to learn new skills and processes in order to respond to federal and third-party payer demands. An entire generation of practicing physicians and physician extenders is being asked to change practice habits, yet still engage in complex decision making.
It is a tall order. However, virtual patients (VPs) offer a way to provide examples and feedback that can help train providers to work within the new constraints. Think about it: clinical decision making is a skill. Like any other skill, it needs to be practiced, refined, and updated regularly. Simulation in general offers a safe environment to assess specific skills and receive personalized, dynamic feedback. VPs can simulate a wide range of clinical decision-making scenarios without requiring dedicated space and time the way physical simulators do.
Simulators such as mannequins are a familiar way to practice clinical skills. VPs are a relatively new development best described as interactive web-based simulations used to develop, enhance and assess clinical decision-making for all types of learners (physicians, physician extenders, nurses, students, etc.). Branched narrative style VPs, in particular, do this by presenting a patient’s story and background information. They then challenge learners with multiple decision paths and show the impact of their decisions—without the risk of actually treating patients, of course.
Training with these realistic computer-based cases strikes a practical blend of simulation with the convenience of web-based delivery and centralized reporting. Think of them as “cognitive” task trainers.
Hospitals have long recognized that providers who pursue learning on a regular basis tend to have better patient outcomes at a lower cost of care. Educational programs like VPs provide a mechanism to make good clinicians better and—perhaps best of all—help novices improve the cognitive skills that lead to expertise.
One good example that I am aware of is Warwick Medical School in the UK, which created VPs to train new doctors to handle life-threatening acute medical emergencies. The doctors can practice over and over again. Through the VPs, they receive immediate, personalized feedback while responding to a rapidly evolving, life-threatening clinical challenge. This type of deliberate practice simply cannot be replicated in real life. In an actual emergency the doctors who practiced decision-making skills are more likely to perform successfully.
Given healthcare’s focus on accountability and other reform efforts, it is important to not lose sight of ways providers and nurses can improve the care and the safety of their patients. VPs provide a safe and objective way to identify variations in practice and decision-making; remediate using real-life examples; reassess until competency is demonstrated; and continually reinforce best practices.
In any given community hospital, providers with a wide range of prior knowledge, skills, and attitudes practice under one roof. Patients expect and deserve the highest level of expertise from all of their caregivers. Payers also expect a certain level of performance and have begun to reward superior performers.
Simulation provides an efficient way to assess clinician performance and provide feedback, whether in the form of clinical guidelines, performance metrics or formal educational programs. By strengthening medical decision making, virtual patients offer one way to reach everyone’s ultimate goal—better patient outcomes.
James B. McGee, MD is the scientific advisory board chairman and co-founder of Decision Simulation LLC, co-chair of the Virtual Patient Working Group at MedBiquitous, and assistant dean for medical education technology at the University of Pittsburgh School of Medicine. Additionally, he is an associate professor of medicine in the division of gastroenterology, hepatology, and nutrition and a practicing gastroenterologist.
Mr. Joyce, great observations on what I think are the early stages of mobile device adoption in hospitals. I have some comments on your points:
1. 10 inch display. No one thinks it’s a good idea to replicate a Medicaid form on an iPad. And ‘standard consent?’ Why would you use a standard consent on an entirely new form factor? This is not a problem with the iPad, this is a problem with software.
2. No stylus. The Pogo does a great job. Signature collection apps allow the sig box to be big, then shrink it to size for a pdf. Check out DocuSign Ink for a beautiful and secure implementation of this concept.
3. No handwriting recognition. First of all this isn’t true, but second of all no one cares. There are several handwriting recognition apps, and a foolish EMR could certainly embed the feature into their software. However, handwriting recognition is considerably clumsier and more error-prone than speech recognition, which Siri has proven can easily be accomplished on mobile devices. (And Nuance Medical Mobile has proven works great.)
4. Proprietary OS not enterprise friendly. I would suggest searching “Apple in Enterprise” to see why this is no longer true. In addition, any iPad-based EMR would use client-server architecture to interface with Meditech if they needed to. Why would you interface directly with Meditech from iOS? It makes no sense.
5. Lack of rugged form factor. I haven’t dropped mine yet, so can’t say about that. It handles hospital grade disinfectant with no problem. It is also considerably less risky than sharing a keyboard.
6. The hype of hardware. Not sure what you mean here. The hardware is not the problem. Everything you have mentioned (except for durability) can be solved by well-designed native iPad software. It will come. Point-and-click didn’t destroy our workflow in a day, and native iPad software won’t restore it overnight.
I was about to rebut Mr.. Joyce’s statements of fact as I just couldn’t bring myself to “trust” his “opinions are carefully thought out from experience”. Brian got their first though.
Its not even the factual inaccuracies, its also the clear lack of any vision. Replicating paper workflows on a tablet is somewhat missing the point.
Mr. Joyce, thank you for taking the time to contribute to the Readers Write. The following is just a simple expression of my humble opinions.
I think your review of the iPad in healthcare was interesting and well-written, but not necessarily fair.
The iPad was never intended to be the “ideal tablet” for healthcare and it’s adoption in this market speaks more about it’s strengths as a usable and accessible device for people across the spectrum of demographic segments and use cases. With that said, you’re right that the shortcomings for its use in healthcare are undeniable (albeit, not the same in every care setting), but even with these drawbacks it has proven to be the best and most desirable option.
“the iPad is not well suited for healthcare in its current state.” I think this statement is dead wrong and has been proven wrong by its brilliant success and adoption rate in healthcare settings, not to mention the plethora of thriving healthcare apps and the scrambling of HIT vendors to bring an iPad native or friendly version of their software to market. I’m venturing to guess that you made this statement in comparison to the “ideal tablet” for healthcare you imagined it to be, which I think is an unfair and impossible comparison.
“…sat down with the folks at Intel and Motion Computing to tell them that the C5 was too complicated and expensive.” This, on the other hand, is the correct comparison to make. Set the iPad next to a C5 or whatever tablet that has been “designed” specifically for healthcare and see which one the practitioner will pick. My money is on the iPad. We can analyze the reasons behind their choice, but that would be another lengthy conversation. What matters is that they have been and are choosing the iPad, and Apple has the sales figures and media coverage to prove it.
“Our request fell on deaf ears as they paraded out the next incremental chip set improvement in their roadmap.” With this statement you’ve identified what’s at the heart of many of the problems we face in HIT, vendors that either don’t know how to listen or just don’t care to. If Intel and Motion Computing had applied themselves to meet the needs of the healthcare market the way that Apple applies itself to meet the needs of the consumer market, the iPad would never have entered the conversation.
What makes the iPad a disruptive force is that it wasn’t designed to meet the needs of healthcare or any specific market. It was designed to meet the needs of the individual using it. Sure, it’s not the perfect fit for every setting, but new apps and accessories are appearing daily to make it fit in multiple environments. This is happening not because the iPad is the swiss army knife of tablet computers, but simply because it works in fundamental ways that matter most to the people using them.
Again, just my humble opinion.
Huh, I guess I would ponder where Brian, and “Well Put Brian” work. Maybe for Apple and not in actual Health Care Facilities where there is a range of technical apptitudes that need to be met while continuing to support a wide range of data capture requirements.
If you had really read Mr Joyce’s article you would recognize that through experience…some that I have had as well working both inside a Hospital and on the Vendor side of the isle…Mr Joyce is simply pointing out that at this time, for across the board ease of use in a health care setting, the iPad isn’t all that and a bag of chips.
Dose it function for some things? Sure. Should it function for more things? Yes. Are there other options that could be considered? Yes. And should be.
What I didn’t hear in any of either of your comments is how many times you have sat down with an 83 year old elderly patient, had them read something on the iPad, maybe use the stylus to mark a check box or a radio button, and have them sign something on the iPad. Try that one day and let me know how it goes for you.
Or maybe you feel paper is still the way to go.
@ Brian – thanks for the candid response. I’d love to have a better forum to discuss this in more detail because my space in the article was limited by word count. But I’ll try to address each of your counter points thoughtfully:
1. Paper has been THE interface for hospitals for decades. That’s from a patient perspective as well as a care-giver. If the iPad is going to be a tool to help us move away from paper, it will have to be “document friendly”. That’s just a fact and EMR vendors suffering from low adoption for 15 years realize how strong a competitor paper can be. We build paper-like user experiences on the iPad and other tablets today so we have customers that would disagree with your claim (and @Well Put Brian) that forms-based workflow is ill-fitted for tablets. ECM solutions, which ARE the EHR for most hospitals/patients, still have a document-centric view of the world. It’s our reality.
2. DocuSign is a great product. No arguments there. But without integration (prefill via HL7 or automatic indexing into the ECM), it is simply a toolkit. There are a dozen of them out there. I could do the same with MS Word on a tablet, but that doesn’t make it ideal for healthcare. The point is the iPad’s capacitive display is intended for touch, not pen input. That tip on your Pogo isn’t well suited for fine point, handwriting reco and I’d have to wonder what hazardous material gets stuck in that fuzzy tip. Maybe there’s a benefit to not having a dock for your pen so you lose it.
3. I respectfully disagree on handwriting. Handwriting reco has its place, as does speech dictation. I’d be happy to show you some examples where it is faster than speech – just not on an iPad. 🙂 Any good EMR would support multiple modalities. I do question patient privacy if a doctor is only using speech to enter data into their iPad. I love what Dragon is doing in our space – we integrated it for narratives. I can’t comment on Siri for iPad or healthcare because it isn’t available today. I love it on the iPhone but that’s because it has context-awareness of my calendar and contacts. I can see great potential for that technology in healthcare though.
4. Not sure what your counterpoint is here. I stated that a majority of our existing healthcare systems today will not run on iPad natively, making adoption painful for hospitals. They have to compromise on user experience by using Citrix technology.
5. You haven’t dropped yours yet.
6. “It will come” Of course, my point was iPad is not ready today because of all the reasons I stated.
@Vicente, thanks for the response. We probably agree more than you think. We have a lot of customers that want us to make the iPad the ideal tablet for them. We are in the document automation space and fill in the gaps left behind by EMRs. They want to use tablets for this purpose, which we believe to be a perfect form factor. They want to use this device because of peer pressure, brilliant marketing and all the reasons I’ve stated. Its not because it has been proven as a clinical device. I’m not dismissing Apple’s success at selling their product. But Apple isn’t really engaged in the healthcare community as a solution provider so vendors like us are left to enable that change.
You stated. “What makes the iPad a disruptive force is that it wasn’t designed to meet the needs of healthcare or any specific market. It was designed to meet the needs of the individual using it.”
That’s an excellent point and I agree. Apple gets a pass and an entire industry has to adapt, change their healthcare systems’ underlying technology and clinical workflow? That’s not an easy sell.
Thanks for sharing guys. I expected some vigorous responses. Look me up on LinkedIn if you want to continue the healthy debate!
@ From Experience, it’s true I’m an Apple fanboy. But I’m also in the trenches as a doctor in a couple different emergency departments. I’ve used Cerner, Meditech, Soarian, Epic, T-System, Medhost, paper charts and everything in between.
And, amazingly enough, I used my iPad for something very much like what you mentioned. I reviewed images of a broken hip with a delightful elderly patient, and showed her lab tests which indicated the reasons we would be delaying surgery. She wrote a letter of gratitude, even mentioning the iPad.
But I didn’t try to have her click a radio button because, as I mentioned, that would be reproducing desktop software on an iPad. And that would be not good.
But next time you’re reading HIStalk on your iPad, check out the Setting app. It’s full of structured data of the type clinical informatics folk seem to like. And yet no radio buttons, no drop-down lists, no check boxes. The path to a good iPad experience in hospitals is well laid out right there if any vendors want to take a look.
Look, point-and-click is a huge problem for us. Now there is a glimmer of hope that we can go back to working the way we were meant to: looking patients in the eye, engaging them while we review their meds and history and order treatments. It’s safer and more personal and keeps us at the bedside longer. Why on earth is this controversial?
Over 70% of emergency doctors have iPads in their homes. Right now. Don’t you think they are on to something?
@ Chris Joyce, I’m a doctor, so I don’t know what ECM Solutions are. If it’s some kind of tablet-based paper-looking form, then I think I understand your point-of-view. An elegant native iPad interface to collect all that structured data could mean competition. Have you thought of reorganizing the data in a more iOS fashion and releasing an iPad app?
You nailed it with DocuSign, though! Without integration it is simply a toolkit. So why not integrate it? You enter some structured data in a ‘Settings’ like interface, patient signs a la DocuSign, and whammo! A beautiful patient-specific form.
Regarding handwriting, I guess I still have flashbacks from the Palm days. What I’ve tried on the iPad for handwriting has been dismal, but this is probably more related to my handwriting than to the technology.
And regarding healthcare systems not running on iPads, this was actually my point. They shouldn’t. The iPad with native software should be the interface to a server that integrates to the EMR. I wasn’t clear enough on that. Believe me, I really don’t want to see a desktop EMR on an iPad. I’m really surprised anyone thought that might work.
@Brian
Look, point-and-click is a huge problem for us. Now there is a glimmer of hope that we can go back to working the way we were meant to: looking patients in the eye, engaging them while we review their meds and history and order treatments. It’s safer and more personal and keeps us at the bedside longer. Why on earth is this controversial?
I’m advocating the EXACT user experience you are advocating so we’re on the same page. In fact, we provide these types of user experiences (today, on tablets/iPad) for doctors/patients that are counter to the point-and-click experience you get with most EMRs.
Over 70% of emergency doctors have iPads in their homes. Right now. Don’t you think they are on to something?
Absolutely, every doc that’s ever approached or consulted us had a Mac at home. That’s frankly why they come to us. Their hospitals aren’t ready to help them use these devices in a meaningful way without better software, which I’m advocating here if you read my article.
If it’s some kind of tablet-based paper-looking form, then I think I understand your point-of-view. An elegant native iPad interface to collect all that structured data could mean competition. Have you thought of reorganizing the data in a more iOS fashion and releasing an iPad app?
This isn’t a reaction to competition. We are simply responding to our users, which come from some of the largest providers in the country. We have doctors that are still very much interested in the simplicity of a paper-like experience that doesn’t change their workflow, slow them down or interfere with patient care. You mentioned T-Systems so I’m sure you know they use digital pen technology for the same reasons – surely they know their ED physician audience well. Capturing that much information in a native iPad app would be many more clicks on that small screen. There is elegance/simplicity to an ePaper on tablet solution too, if implemented correctly. But we also allow them to choose whether to keep it like ePaper or switch to a native iPad data entry screen (which is easier to develop). That’s where we fill the gap today. Some don’t want to change or can’t afford the lost productivity. Some are just adverse to change, as you know. The industry is very fragmented and heterogeneous. It will take some time to shed ourselves of old habits and legacy systems that hospitals rely on.
BTW, DocuSign could work for signatures, but we both know that most healthcare forms are capturing more than just signatures. So it is a single purpose tool, thus ill-fitted. This solution falls apart in an enterprise settings pretty quickly.
My offer still stands on the handwriting/voice integration. Bring your iPad to the duel. 🙂
Cheers,
Chris
Some really good discussion, but the bottom line is that none of this should “go live” in actual healthcare environments without some serious validation testing for “use error”.
Using an iPad to access and interact with (iPad) native and non-native apps could have some real unintended consequences / risk…that probably should be understood and mitigated by someone other than the hospital’s risk management department.
QA