Saturday, January 30, 2010

January 2010 Has Gone So FAST!

This month has passed so quickly! The last panel meeting of HITSP was held on Monday January 25 and I felt a sense of saddness that the intense activity was drawing to a close. I will participate in a few HITSP meetings during February as I am on the HITSP Foundations Committee. For this entry I'll enter copies of a few closing emails that I've received that summarize the past and look to the future.

The first is from Dr. Walter Suarez who is the leader of the Consumer Preferences Tiger Team:

Dear Consumer Preference TT members, colleagues and friends,

On Monday of this week we delivered the final report on the status of our Consumer Preference work to the HITSP Panel, which was received quite well. While we were not seeking action on our RDSS on Consumer Preferences, and our document will not be vetted in public, given its 'draft' condition, we stronlgy believe that the body of work we built around this important topic will pave the way for any future efforts to advance the harmonization and selection of interoperable standards related to the electronic creation, execution and exchange of consumer preferences.

What's next? at the Panel we heard from HITPS Leadership on the plans for HITSP beginning next month. Several details were offered about ongoing support for HITSP's website, its listservs (they will probably become moderated lists), the comment tracking system, which will continue to capture comments on several documents, and other items. No formal meetings of the Board, Panel, TCs or TTs will be convened after February 1 (except perhaps for the Foundations Committee). A more formal announcement will be provided to all in the coming days.

Congratulations and thank you to each and everyone of you for your active involvement and participation in this Tiger Team. A very special thank you goes to our Workgroup Co-Chairs, Janie Bowman-Hayes and Terry Heam (Content Preferences), and RIchard Frank and Don Jorgenson (Privacy Preferences) for their willingness to share their time and experise in leading these groups, and to our Tiger Team Facilitators, Johnathan Coleman, Elliot Sloane and Michael Nusbaum for helping us keep on track, on time, and on point. It was our priviledge to have serve as co-chairs of this group.

Much work remains on consumer preferences and we fully expect that any future harmonization will include the continuation and conclusion of the work we started in HITSP.

Best regards,Mureen Allen, ActiveHealth Management
Walter Suarez, Kaiser Permanente

The second is from Dr. Halamka who is the Chair of HITSP:

FROM JOHN D. HALAMKA, MD, HITSP CHAIRMAN:

Folks:

Thanks for a great meeting on Monday. It was great to see you all, thank you all, and reaffirm our commitment to stay engaged as we await the ONC RFP. I've listed all the ONC grant programs on my blog and you'll notice that $64.3 million has been allocated for Standards Harmonization, Certification, and the NHIN:

http://geekdoctor.blogspot.com/2010/01/grant-programs-from-onc.html

Here's the kind of press we've received about the Panel meeting and about the continuance of HITSP:

http://www.healthdatamanagement.com/news/standards_onc_stimulus_hitsp-39683-1.html

I summarized my comments from the January 20th meeting of the HIT Standards Committee about the Interim Final Rule, Implementation Guidance and HITSP on my blog. You'll see that most of the base standards recommendations from the HIT Standards Committee (based on a foundation of HITSP work) were included in the IFR. The IFR is a regulation, which means that the details provided in it are hard to change. By providing base standards but enabling implementation guidance to be published separately from the regulation itself, ONC allowed evolution and refinement of more specific guidance. The comment period on the IFR closes March 15 and we'll see revisions of the NPRM that are directly related to comments. I think you'll see substantial work on vocabularies and implementation guidance including security/privacy over the next 6 months. The sense of the HIT Standards Committee is that ONC did a great job on a tight timeframe. The comment period will add the final polish.

See my blog for more details:

http://geekdoctor.blogspot.com/2010/01/january-meeting-of-hit-standards.html

I look forward to speaking with you during our monthly check in/education calls.

I'll see you at HIMSS10!

If you have questions or concerns, please email me at jhalamka@hms.harvard.edu


HITSP Administrative Information:

1. As reported this week, ANSI announced that the Government has granted HITSP a no-cost extension to the current contract which will continue through April 30th, 2010. Among other things, this will enable HITSP to have a presence at the upcoming HIMSS conference, and support the quality reporting activities being demonstrated in the Interoperability Showcase there. For full details of the extension please see HITSP 10 N 459 http://tinyurl.com/y8m2lgb

2. As noted, there will be HITSP informational conference calls over the next few months. These will be announced through this listserv. Please stay tuned.

3. The Foundations Harmonization Subcommittee will be wrapping up their work in early February and have the following wrap up meetings scheduled:
· Wednesday, February 3 at 10:30AM/ET
· Monday, February 8 at 2:00PM/ET
· Wednesday, February 17 at 10:30AM/ET

4. All the recordings of the HITSP webinars are posted at hitsp.org/webinars.

If you have questions about the administrative items, please email the HITSP Secretariat at mmaasdeane@ansi.org.


-----------------------------------------------
Michelle Maas DeaneHITSP SecretariatAmerican National Standards Institute25 West 43rd Street - Fourth FloorNew York, NY 10036
T: 1.212.642.4884F: 1.212.398.0023E: mmaasdeane@ansi.org

During the HITSP hiatus, I plan to participate on the HL7 Personal Healthcare Records (PHR)workgroup co-chaired by John Ritter and Gary Dickinson.

Thursday, January 7, 2010

Dr. Peel is Right!



Dr. Peel is right!

Because the proposed rule on "meaningful use" doesn't specify that consumers and patients should have control over their personal health information, billions of stimulus dollars will be wasted to purchase obsolete, unethical "clunkers" and worse. My experiences, as a former in-house data administration consultant with the Wisconsin Department of Health Services (DHS) and current member of the U.S. Health Information Technology Standards Panel (HITSP), confirm her observations and expectations of wasted money for the future.

Wisconsin's DHS is slated this year to receive over nine million dollars from ONC to plan for health information exchanges (HIEs). Wisconsin then expects to receive eighty or so million dollars for related HIE projects over the next few years. A request for information (RFI) for the DHS Long Term Care Infrastructure HIE project was released in August 2009. DHS has indicated that it will likely release a request for proposal (RFP) for the infrastructure project in 2010.

I live in the Village of McFarland, located just outside Madison, and have been a volunteer data entry clerk for McFarland's Senior Outreach Program since August 2007. My duties involve data entry of the personal health information of individuals and nutritional risk self assessments into the Social Assistance Management System (SAMS). I also enter the number of meals that they eat during a month. The information is collected from participants on paper forms. Being elderly or disabled are the basic eligibility criteria for the programs. I participate in the congregate meal program and complete the same forms as others do but I then enter my personal health information into the system, myself.

From 1998 until 2005, when the unit was disbanded due to budget constraints, I held the position of data administration consultant for DHS' Center for Uniformity, Security and Privacy (CUSP). CUSP's mission was primarily driven by two federal laws enacted in 1996. The first was the Clinger-Cohen Act having to do with the Federal Enterprise Architecture (FEA) and the second was the Health Insurance Portability and Accountability Act (HIPAA).

During that period, I participated in HIPAA standards development as a public sector representative to HL7 and as a participant in the HIPAA Metadata Registry Coalition and United States Healthcare Information Knowledgebase (USHIK). I was a beta tester of MetaPro sponsored by the EPA and the then Health Care Financing Administration (HCFA). MetaPro was a distributable metadata registry based on the ANSI X3.825 Metamodel for the Management of Sharable Data and ISO/IEC 11179 Specification and Standardization of Data Elements. I was the eForms coordinator for the Department, the primary staff person for the Department's Data Stewardship Council and development of the Common Core Data Standards that it adopted. I maintained the HIPAA Now! Website and provided consultation to IT projects on data security, privacy, and quality.

During 2002 I provided consultation to Wisconsin's Mental Health Data Infrastructure Grant (DIG) Project and developed a data quality protocol to measure the quality of mental health data in the Department's data warehouse. At that time I analyzed the data included in all mental health fields for over 139,000 individuals collected through the Human Services Reporting System (HSRS). The mental health module in HSRS and associated fields in the data warehouse organized each psychiatric diagnosis into five levels (axes) relating to different aspects of disorder or disability.

Wisconsin is the only state to configure SAMS so as to display individuals' most sensitive information in “user fields” on the summary screen (copy attached). Information can be directly entered and edited from the summary screen and since “user fields” are not regular data base fields, no audit trail is created or maintained. Entries in the “user fields” can be made by any person with access to an individual’s record and information from other databases or data warehouses can be entered without a person’s knowledge or approval.

Among the most sensitive “user fields” available for entry are those related to mental health diagnoses. Although the data entries that I make are limited to demographic information and assessments of nutritional health, ADLs and IADLs, others with access to the system can make entries with regard to the most sensitive personal information.

The group of five diagnostic fields, shown on the attached summary screen likely relate to the multi axial system of the Diagnostic and Statistical Manual of Mental Disorders (DSM). The mental health module in the Human Services Reporting System (HSRS) and associated fields in the MEDS data warehouse organizes each psychiatric diagnosis into five levels (axes) relating to different aspects of disorder or disability. A definition can be found at: http://tiny.cc/x3JZ5

As I mentioned above, I recognize the five diagnostic fields being included in the MEDS data warehouse from my work on data quality related to the Data Infrastructure Grant (DIG) in 2002. Concern during that period was expressed by counties as shown in minutes from a 2003 meeting of the Wisconsin Council on Mental Health: http://tiny.cc/nbP7T . Additional “user fields” provide drop downs for various diagnoses including the one for depression that I’ve shown on the attached summary screen. The linkages between physical and mental health is explored in the Behavioral Risk Factor Survey: http://tiny.cc/nyo9J

When a data entry operator enters information for a new participant, the SAMS application executes a broad search that brings back a listing of all participants, from communities across the state, having similar sounding names. The summary screens from all matching records, with the most sensitive information plainly visible, can be viewed without actually opening records by any one with access rights to the SAMS system. There does not appear to be an audit trail relating to who views records. Concerns expressed in 2003 by the Wisconsin Council on Mental Health appear to have been well founded

Currently the State Data Infrastructure Coordinating Center (SDICC) is discussing participation of states’ mental health units in health information exchanges (HIEs) being developed by states under the Health Information Technology for Economic and Clinical Health (HITECH) Act. HITECH was enacted as part of the American Recovery and Reinvestment Act (ARRA) of 2009 commonly referred to as the Stimulus Bill. A summary of the October 2009 SDICC regional calls can be found at: http://tiny.cc/k8nRV .
Because the RFI for the Long Term Care Infrastructure HIE Project involves connecting all systems including the DHS data warehouse, the privacy of many of Wisconsin's elderly and disabled will be systemically breached by technology "wrongfully used".
Dr. Peel is right!






Friday, January 1, 2010

2010 - It's A New Year!

My time since my last blog entry in October has been filled with Health Information Technology Standards (HITSP) meetings. January 2010 will be filled with wrap-up meetings as the HITSP contract with the Department of Health and Human Services (HHS) comes to its conclusion. The contract was for four years running from September 2005 through September 2009 with an extension granted through January 2010.

Of particular importance, are the final meetings for the Consumer Preferences Tiger Team (CP-TT) which provided comments, at the request of the Office of the National Coordinator for Health Information (ONC), relating to the draft specifications for Consumer Preferences. The draft specifications can be found at: http://tiny.cc/9Sk51 .

On December 30, 2009, CMS announced a notice of proposed rulemaking (NPRM) to implement provisions of the Recovery Act that provide incentive payments for the meaningful use of certified EHR technology. In a related announcement, ONC has issued an Interim Final Rule (IFR) that specifies the Secretary’s adoption of an initial set of standards, implementation specifications, and certification criteria for electronic health record (EHR) technology.

Dr. John Halamka's summary of how both documents should be used together provides an excellent overview of "meaningful use" for consumers.