Archive for the ‘eRx’ Category

Over a 1,000 exhibitors, some 30,000+ attendees and I come away from HIMSS, again, thinking is this all there is? Where is the innovation that the Obama administration i.e., Sec. Sebellius and Dr. Blumenthal both touted in their less than inspiring keynotes on Wednesday morn? Maybe I had my blinders on, maybe I was looking in the wrong places but honestly, outside of the expected, we now have an iPad App for that type of innovation where nearly every EHR vendor has an iPad App for the EHR, or will be realeasing such this year, I just didn’t see anything that really caught my attention. But then again, looking over my posts from previous HIMSS (this was my fourth), maybe my expectations need a serious reset and it would be wise of me to read this post next year before I get on the plane to Las Vegas and HIMSS’12.

Prior to HIMSS I participated in a webinar put on by mobihealthnews (BTW, Brian at mobi has a good article on some of those mobile apps being rolled out at HIMSS this year). My role in this webinar was to give an overview of what one might expect at HIMSS’11. Having weathered the last two HIMSS and the major hype in ’09 about Meaningful Use and ’10 when HIEs were all the rage, this year I predicted that the big hype would be around ACOs. Much to my surprise such was not the case.

The reason was quite simple and two fold.

First healthcare CIOs and their staff are going through numerous contortions to get their IT systems in order to meet Stage One Meaningful Use (MU) requirements. Looking ahead their focus is naturally myopic: What do I need to do to meet Stage Two and finally Stage Three MU requirements, requirements that have yet to be published? Then there is this little transition to ICD-10 that some pundits claim is the HIT sector’s own Y2K nightmare (not sure if that means the hype and fear is far greater than reality or what). Either way, CIOs are having a tough enough time just keeping up these demands and filling their ranks with knowledgable staff (one CIO told me he has 53 open positions he’s trying to fill) to even begin thinking about ACOs.

Secondly, there are the vendors who today are not completely sure of what exactly healthcare organizations (HCOs) will need to succeed under the new ACO model of care and bundled payments. In countless meetings I had over the course of my three days at HIMSS I did not meet one vendor that had a clear picture of what they intended to offer the market to help HCOs become successful ACOs. There was unanimous agreement among the vendors I met with that analytics/BI would play a pivotal role, but what those analytics would look like, what types of reports would be produced and for whom, were less than clear. So it looks like we may have to wait another year before the ACO banter begins in earnest at HIMSS.

Some Miscellaneous HIMSS Snippets:

Much to the chagrin of virtually every EHR vendor at HIMSS (still far too many and I just can’t even begin to figure out how they all stay in business) Chuck Friedman of ONC announced in his presentation on Sunday that they are looking into usability testing of EHRs as part of certification process. Spoke to someone from NIST who told me this is a very serious consideration and they are putting in place the necessary pieces to make it happen.

Defense contractor and beltway bandit of NHIN CONNECT fame, Harris Corp. acquired HIE/provider portal vendor Carefx (Carefx was profiled in our recent HIE Market Report) from Carlyle Grp for a relatively modest $155M. I say modest as this was some 2x sales and far less than the spectacular valuations that Axolotl and Medicity received. Could this be a reset of expectations for those other HIE vendors looking to be acquired? Reason for acquisition is likely two-fold: Carefx has a good presence in DoD and this may help Harris land some potentially very lucrative contracts as the DoD and VA look to bring their systems together. Secondly, for some bizarre, and likely highly political reason, Harris won the Florida State HIE contract and now has to go out and pull the pieces together to actually deliver a solution, which frankly they don’t have but Carefx will help them get there..

Kathleen Sebellius needs a new speech writer. David Blumenthal needs more coffee before he hits the stage.

The folks at HIStalk once again provided excellent, albeit slightly self-congratulatory coverage of HIMSS. They also threw one of the better parties that I attended. Thank you HIStalk team.

Had several people, mostly investor types contact me for my opinion of the athenahealth-Microsoft partnership that was announced. Do not see much in the way of opportunities for either party in near-term. It will take a lot of work for anything truly meaningful and profitable to come from this relationship. That being said, did think that the Microsoft-Dell announcement was quite significant and should be watched closely, especially if Microsoft can truly get Amalga down to a productized, easily deployable version for community hospitals that Dell intends to target.

HIMSS and most vendors are still giving lip-service to patient engagement. Rather than seeing a slow rise in discussing how to engage consumers via HIT, this issue is something that few vendors bother mentioning and when they do, it is still with the old message of how to market to consumers with these types of tools rather than engaging consumers/patients as part of the care team. Hell, not even part of the care team, but the damn center of the care team. Not sure when these vendors will get religion on this issue. Maybe they are just following the lead of their customers who have yet to fully realize that in the future, a future where payment will be bundled, that actively engaging consumers in managing their health will be critical. While I have not completely given up hope on this industry to address what is arguably the most challenging issue facing healthcare’s future, I do chide them for not having more vision and frankly guts to take a leadership role and help guide their customers forward.

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What are some of my favorite things?  “Raindrops on roses” and “whiskers on kittens” definitely make the list.   How about the task of combing over a large chunk of new Meaningful Use (MU) proposed requirements? … Not so much… though necessary if one wants to understand how the HIT and mHealth markets will develop.

Will MU grow the market for mHealth technologies?  Or, the other way around, will the adoption of mHealth technologies encourage physician compliance with MU?

While skeptics may note that no corner of the HIT Landscape can escape the ‘mHealth hype’ – in all seriousness, mHealth technologies represent an important toolset available to both physicians and hospitals alike as they strive to comply with Meaningful Use.  This toolset is especially useful in the hospital setting, where physicians’ compliance is absolutely critical to the hospital’s ability to earn ARRA funds (particularly in smaller hospitals that have a higher percentage of affiliated physicians).

And let’s not forget about those other stakeholders – smartphone-loving, proactive patients, who are not concerned with MU but with gaining access to and control over their own health data, on their own terms within a mobile device that is with them 24/7.

The Stage 2 & 3 Proposed Requirements:  A 10,000 Foot View

One thing I noticed while studying these new proposed requirements was that they have been significantly watered-down, as compared to when I first started following MU in 2009.  As a result we now see a ‘kinder and gentler’ path towards MU.  I won’t list out the details here – John Halamka and Robin Raiford from Allscripts have already posted very helpful summaries of how Stage 2&3 expand upon the Stage 1 final rule.

Overall, from a 10,000 foot view, the new requirements point to the following:

1.   More electronic health data capture will be required (no news here).

2.   Clinicians will be required to ‘do more’ with this data by using it in advanced clinical processes and by sharing it with other providers, an HIE, and Uncle Sam.

3.   There will be an increased emphasis on patient engagement which will involve PHRs, patient education, and stronger patient-physician partnerships.

More Data Capture

Luckily for providers, the Stage2&3 proposals have loosened inpatient and outpatient note capture requirements in an effort to get notes digitized by any means necessary.  Notes can be maintained in structured or unstructured forms (scanned-in handwritten paper notes, dictation, etc are all possibilities).   With these loosened requirements, physicians will not be driven by MU to document at the point-of-care on their mobile device.  Instead, they will have to weigh other benefits, such as the ability to face the patient while taking notes on their touch tablets.

When it comes to discrete data, the story is different. Some physicians have been capturing charge data on mobile devices for more than a decade, avoiding workflow disruption while making sure they got paid. With the current explosion of mobile devices in health care settings, along with improvements in usability, physicians are now poised to move beyond charge capture to capturing the discrete information required for MU (problem lists, demographics, vital signs, smoking status, quality metrics, eMAR data, etc).

Using the Data: Towards Advanced Clinical Processes

Capturing digital health data does no-one good unless it is put to use, and so the Stage 2&3 proposals all expand requirements for advanced clinical processes that use this data, such as: CPOE, drug-drug/drug-allergy checks, eRx, CDS (Alerts), formulary checks, medication reconciliation, and more.

While early clinician adopters are already performing eRx and formulary checks on mobile devices, we are still far away from mission critical clinical processes such as CPOE and CDS moving to mobile on a widespread scale.  (We still need to get the desktop versions going!).  Currently, few vendors are established in this space, though PatientKeeper has CDS alert functionality built into their platform and is introducing their CPOE App in 2011.

On the other hand, advanced clinical processes such as CPOE and CDS have huge roles to play at the point-of-care.  Imagine that while at the bedside, a physician could receive guidance without disrupting the physician/patient interaction – similar to how they now use Epocrates but with data that is much richer and personalized to the current interaction.

Sharing the Data

A health crisis knows no designated time frame, and the ability of physicians to grant access and share patient information with other physicians or with an HIE (at 1am, from their kid’s soccer game, or during hospital rounds), will become increasingly essential.  With MU requirements around provider-provider and provider-HIE data sharing, clinicians will increasingly demand access to other provider portals and HIEs via their mobile devices.  In fact, HIE vendor Axolotl will be releasing a touch tablet (iPad) app in 2011 for this very purpose.

Patient Engagement Requirements

There are also significant new requirements relating to the ‘Patient and Family Engagement’ MU goal.

These include patient reminders, patient preferences for communication channel, online secure patient-physician messaging, timely electronic access to clinical data, bidirectional electronic self-management tools, and more.

It is easy to see how these requirements can tie-in to the mHealth ecosystem.  For example:

  • Patients may prefer to be sent reminders via text message.
  • Patients may wish to communicate with their doctor through a secure mobile messaging app.
  • Patients may also want to be able to access their clinical data and educational resources through an mPHR/mEHR.

But, wait, let’s back up: do patients actually care about their health data?  Making the leap that providing an mPHR/mEHR to the consumer would nudge engagement rates upwards (and costs downwards) is just that – a leap.  However, this is a topic for the next post…

Summary: MU and mHealth

It is easy to see how many of the evolving MU requirements around data capture, advanced clinical processes, data sharing and patient engagement have a tie-in to the mHealth ecosystem, and how the mobile device will play an increasing role in MU compliance. Hospitals worried about the compliance of their non-employed physicians would do well to look into the mHealth ecosystem for tools that will encourage these physicians to comply — even though deploying HIS-integrated Apps will entail the usual governance, implementation and security costs.

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In Monday’s post, Chilmark reflected upon a piece that Peter Hudson, co-founder of Healthagen, the developers of mHealth app iTriage wrote for mobihealthnews. In that article, Peter talked about the utility of an mHealth-based PHR (iTriage recently launched such capabilities), but in our post, we countered that today, it is still far too difficult for a consumer to pull together their personal health information (PHI) to create a truly longitudinal record. This will likely stunt the efforts of companies such as Healthagen who are trying to offer consumers a PHR – the hassle factor is still far too great to overcome.

Now we will look at the red hot space of Health Information Exchanges (HIEs).

As local, regional or even statewide aggregators and distributors of health data to facilitate care coordination, HIEs have the potential to play a pivotal role in helping a consumer create and manage their PHI. Now that does not mean that the HIE has to offer the consumer a PHR per se, but what an HIE may be able to do is offer the consumer an ability to have a portal view into their PHI that resides within the context of a given HIE. Better yet, why not have as a condition of receiving some of that federal largesse of $564M for state HIE programs that these HIEs support “Blue Button” functionality allowing a consumer to readily download or export their PHI to wherever the consumer desires.

Ah, but we digress.

The purpose of this post is to extract a couple of data points from our forthcoming HIE report as they pertain to consumer engagement. Unfortunately, it is not a pretty picture.

As part of our market survey of twenty HIE vendors, we asked them a number of questions with regards to what consumer-centric capabilities did their HIE solution support. Fully eighty percent of those interviewed had either modest (15%) or weak (65%) consumer offerings.

The following table provides a brief snapshot of those HIE vendors that have what Chilmark considers strong consumer engagement tools. Two of those vendors, Kryptiq and MEDSEEK are somewhat difficult to classify as an HIE in the traditional sense, thus you will not find them running under the covers at your local RHIO. Microsoft is still new to the HIE market with one HIE live in Milwaukee and another in D.C.. While Microsoft’s platform offers these HIEs the potential for bi-directional communication with HealthVault, that capability, to the best of our knowledge has not been tested at either of these HIEs. Also, it is important to note that the Microsoft HIE solution offers little with regards to support for transactional processes (appointment scheduling, Rx refill, eVisit, etc.). RelayHealth is the remaining HIE vendor that actually has some of the more robust consumer tools in the market (they received fairly high ratings in our previous iPHR Market Report), so this is not too much of a surprise.

Now it is not necessarily the fault of laggard HIE vendors that today, their solutions offer weak consumer tools. Frankly, the market has not asked for them. Even as recently as last year when the various HIT policy committees were meeting in Washington to set policies for the HITECH Act and the funding to come, the committee on HIEs, in one of their seminal meetings, completely ignored the consumer role in an HIE. Shameful.

But this will change in due time. MEDecision and Carefx are building out their consumer-facing capabilities and we are sure others will add consumer functionality in time, most likely via partnerships or an occassional acquisition as market is moving too fast for an internal build-out. in the meantime, those vendors that have this capability bring to market competitive differentiation.

While this is all well and good, another development is also taking place, NHIN Direct – something that Microsoft’s chief architect, Sean Nolan mentioned in his comment to our Monday post. What role might a secure, lightweight communication system play within the broader context of HIEs, aggregated PHI, consumer access and potentially control of their PHI? A lot of questions to ponder that we will be looking into further over the next few days

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Since the beginning of 2010 there has been a series of acquisitions in healthcare IT (HIT) market, which recently culminated in one of the largest, IBM’s acquisition of Initiate.  Triggering this activity is the massive amount of federal spending on HIT, (stimulus funding via ARRA which depending on how you count it, adds up to some $40B) that will be spent over the next several years to finally get the healthcare sector up to some semblance of the 21st century in its use of IT.  But one of the key issues with ARRA is that this money needs to be spent within a given time frame, thus requiring software vendors to quickly build out their solution portfolio, partner with others or simply acquire another firm.

And it is not just traditional HIT vendors doing the acquiring (AdvancedMD, Emdeon, Healthcare Mgmt Systems, MediConnect, etc.).  As the table below shows, many of these acquisitions are being driven by those who wish to get into this market (Thoma Bravo, Wound Mgmt Technologies, etc.) and capitalize upon future investments that will be made by those in the healthcare sector.

We are only at the beginning of the sea change in the HIT market and one can expect far more acquisitions over the next 12-18 months as stronger players expand their portfolios and new companies enter the HIT market.  If you are currently assessing an HIT solution for your organization, be sure to assess a vendor’s product road map and how they will meet your future needs (government mandates – e.g., meaningful use, interoperability, etc.) for if their answers are not absolutely clear, compelling and logical, you’ll better off looking elsewhere.

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As required by legislation in the American Reinvestment and Recovery Act (ARRA), HHS/CMS released rules for the meaningful use of certified EHRs before the end of 2009 (late the afternoon of Dec. 30th).  Others have already written plenty on what is actually stated in these rules, therefore, let’s take a look at the potential winners and losers of these new rules as well as those where it is still too early to tell.  This analysis will be laid out over the next few posts starting with Winners below.


Consultants: At 556 pages, very few physicians and hospitals will take the time to read the complete meaningful use rules, rather hiring consultants to guide them in mapping out a strategy to adopt and implement a certified EHR to meet these requirements in the tight time-frame allowed.  Hospitals and large private practices will have the resources to hire such consultants, small practices will not, instead relying on the yet to be formed statewide extension centers.

Payers: Demonstrating meaningful use will require electronic eligibility checking and claims submission for 80% of all patient visits.  This will greatly simplify payers cost burden for payers who must currently contend with eligibility checking by phone and mountains of paper claims submissions from providers.

Large, Established EHR/EMR Vendors: These vendors have the resources and political clout to insure their apps will meet certification requirements.  They will meet such requirements either through internal development or acquisitions.  In some cases, partnerships will also be used to meet smaller, niche requirements of meaningful use.  Big boys with an established presence include: AllScripts, Cerner, Eclipsys, Epic, GE, McKesson, NextGen, Siemens, etc.

Revenue Cycle Management (RCM) Vendors: Core to most RCM vendors solutions is the ability to perform electronic eligibility checking and e-claims submission.  As this is now a core requirement for incentive payment, these vendors will see a boom in business. Smaller, independent vendors such as MedAssets and SSI will likely be acquired.  Large vendors, such as Emdeon, may expand their offerings into core EMR functionality similar to what athenahealth has done with the introduction of athenaclinicals.  Companies such as RelayHealth should also see a bump up in business as providers look to address this requirement.

Medication Checking Reconciliation & eRx Apps: A significant amount of attention is being paid to addressing medication errors and e-Prescribing (eRx) in Stage 1 of the meaningful use rules.  The HITECH Act legislation specifically calls out eRx as part of meaningful use and CMS has been promoting/encouraging adoption as well so this is a no-brainer.  The big winner here is SureScripts.  Medication/formulary reconciliation is also called for in Stage 1, something that the Joint Commission has been advocating since 2005.  Several eRx and EMR apps have embedded this functionality in their solutions.  Lastly, physicians and hospitals will be required to do drug-drug, drug-allergy and drug-formulary checking.  Companies such as First Data and Thompson as well as Cerner’s Multum solution should do well in addressing this requirement.  There are also a plethora of smaller companies, such as enhancedMD, Epocrates, Medscape, etc. that may benefit, through partnerships with or acquisitions by larger HIT firms.

M&A Firms and Small, Innovative Software Companies:: Stage 1 is asking for a lot of functionality that simply does not exist in many EHR/EMR solutions.  Larger, more established EHR/EMR companies will not have enough time to build out all the functionality required and will either seek partnerships or acquire smaller, niche vendors such as those mentioned previously (our bet is we’ll see more acquisitions than partnerships).  Due to the strong demand for niche applications to fill gaps in their solution portfolios to meet Stage 1 requirements, these EHR/EMR vendors will likely pay premium dollars for the best-in-class apps.  Small, innovative software vendors and the M&A firms that represent them will do well over the next few years.

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Late yesterday afternoon, the Center for Medicare and Medicaid Services (CMS) who holds the big bucket of ARRA incentive funds for EHR adoption, released two major documents for public review and comment that will basically define healthcare IT for the next decade.

The first document, at 136 pgs, titled: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology is targeted at EHR vendors and those who wish to develop their own EHR platform.  This document lays out what a “certified EHR” will be as the original legislation of ARRA’s HITECH Act specifically states that incentives payments will go to those providers and hospitals who “meaningfully use certified EHR technology.”  This document does not specify any single organization (e.g. CCHIT) that will be responsible for certifying EHRs, but does provide some provisions for grandfathering those EHRs/EMRs that have previously received certification from CCHIT.

The second document at 556 pgs titled: Medicare and Medicaid Programs; Electronic Health Record Incentive Program addresses the meaningful use criteria that providers and hospitals will be required to meet to receive reimbursement for EHR adoption and use.  Hint, if you wish to begin reviewing this document, start on pg 103, Table 2.  Table 2 provides a fairly clear picture of exactly what CMS will be seeking in the meaningful use of EHRs.  In a quick cursory review CMS is keeping the bar fairly high for how physicians will use an EHR within their practice or hospital with a focus on quality reporting, CPOE, e-Prescribing and the like.  They have also maintained the right of citizens to obtain a digital copy of their medical records.  An area where they pulled back significantly is on information exchange for care coordination.  Somewhat surprising in that this was one of the key requirements written into the original ARRA legislation.  But then again not so surprising as frankly, the infrastructure (health information exchanges, HIEs) is simply not there to support such exchange of information.  A long road ahead on that front.

In Closing…

As I am on vacation and today is a powder day here in the Rockies, I will come back to this at a later date after I have had some time to review and digest these two documents.  First thought though that comes to mind is that the only initial winners here will be the consultants as few doctors have the time or inclination to pour over the 556pgs of the incentive program.  Heck, in my own brief encounters with many doctors, most have only the most cursory knowledge of the HITECH Act and that knowledge is most often full of inaccuracies.  Hopefully, those regional extension centers that HHS will be funding will go live in the very near future as there is a tremendous amount of education that needs to occur to insure this program’s future success.

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CBR002836Just about anything you hear coming out of HHS’s ONC office is with regards to digitizing the doctor’s office.  This is somewhat understandable as there is some $36B in ARRA funding just waiting for the rules on “meaningful use” (MU) to come out of CMS sometime in December. Until those rules are released, the EMR market will continue to be in stasis.

Unfortunately, this nearly myopic focus of the physician and their adoption of a “certified EHR” has completely left the consumer/citizen out of the equation. We fear that this could come back to haunt ONC as our back of the envelop calculations show that ARRA funding comes up about $80K short of reimbursing a physician for adoption of an EHR.  Another forcing function is needed to bring these doctors into the 21st century.  Citizens can be that forcing function, but to date, HHS/ONC has completely ignored them.

We will give credit to the HIT Policy Committee MU workgroup and their MU matrix which states that physicians will provide citizens a PHR by 2013.  Question is, what will that PHR be?  Just an electronic file cabinet (nothing but records) bolted to the floor (not portable)?  If that did occur it would be an unmitigated disaster, with extremely low adoption and use.

Stepping into this fray is Rep. Patrick Kennedy of Rhode Island who’s office is now creating a Bill (caution PDF of draft Bill) likely to be introduced int he near future, entitled the Personal Health Information Act, to amend the ARRA/HITECH Act by establishing clearly defined guidelines (at least clearer that what has been defined to date) for “Personal Health Record systems.”  We won’t quibble that Kennedy’s office does not use the term Personal Health Platforms, but take satisfaction in seeing the term “systems.”

This 8pg draft Bill is a quick read, but below is out outline of it with commentary.

The Bill defines a PHR System (PHRS) as one which:

  • Provides a medical history that includes all major diagnosis and procedures with updates.  This is a no-brainer.
  • Provides recent lab results if available in electronic form.  Not sure why they state that this is limited to electronic lab results only.  Don’t most doctor’s offices have scanners? Concern here is that it may become a loophole.  Also, are all lab results to be fed into PHRS?  If yes, this could create some challenges as their is a significantly wide range of views in the medical community as to what labs should be shared with their customers via a PHR.  And if those labs are provided, they are basically useless to your average consumer if they are not provided in context.
  • List medications and prescriptions, both current and historical.  Again, a no brainer on providing the lists, but what about providing the capability to request prescription refills?
  • Online secure communication with provider practices.  Many a provider is not too keen on this if there is no corresponding reimbursement model. CMS, why don’t you take the lead here, the rest of the payers will follow.
  • Automated appointment and care reminders as well as educational and self management tools.  Now appointment reminders, heck even scheduling an appointment online is pretty straight forward and it does facilitate front-office operations, but what do they mean by self management tools?  What about educational tools?  Will a simply link-out to some website suffice or are these tools to be embedded within the PHRS itself.  This could get tricky and expensive.
  • Provide privacy, security and consent tools.  While it does not mention it in the Bill, assume such will be HIPAA compliant.  Not really sure why they do not mention HIPAA in the Bill itself.  Also, consent may prove challenging, especially for parents of teenagers as the laws vary from state to state.
  • Provide CCD & related CDA documents as well as clinical and administrative messages necessary to exchange information between providers.  Please, do we really want to force CCD/CDA onto the PHRS market where CCR is perfectly adequate and by the way, generally viewed by most IT folks as a far superior standard to work with for exchanging information.  Bad move here by Rep. Kennedy and hope this will be modified as this Bill makes its way through the House.
  • Support full portability between providers.  Good to see portability supported, but should this not be portability between systems/other PHPS or PHRS in this case?
  • PHRS delivers the functionality to serve the intake process and thereby minimize use of or eliminate the ubiquitous clipboard.  Great to see this in the Bill and any physician worth his or her salt will support this capability as it again reduces front office workloads.
  • Access to the PHRS is controlled by the patient or an authorized representative of the patient.  WHOA, expect big time push-back on this one from the physician community.  The Bill asks them to support some pretty rich functionality within the PHRS and then goes and states that the physician can be completely shut out of the PHRS a the whim of the patient?  While we do support citizen control of their health records, believe this provision is a political mistake that could completely sink the whole Bill.  This may be a bridge too far for the medical community to cross.

What’s Missing?

While this Bill is a good first step, we did find a couple of areas where the Bill is lacking.

  • First off is the whole concept of Provenance. By this we mean who create a given record entry, who has seen the record, has the record been altered in any way.  Basically, an audit trail for one’s PHI within the PHRS.  Which leads to the next omission:
  • Providing the citizen the ability to annotate the notes to provide feedback to the provider/care team.  Which leads to another omission:
  • Provide journal capabilities within the PHRS that allows the citizen to record their health/health events that occur outside of the practice.
  • Another area we were surprised to not see addressed was the ability to incorporate biometric data into the PHRS.  Biometric data will become increasingly important in the years to come to support care outside the confines of the doctor’s office or hospital.  Ability to import biometric data needs to be a fundamental capability of a PHRS.
  • One other key attribute that is missing from the PHRS is the ability for the citizen to selectively tag and share data elements within their PHRS account.  For example, one may want their primary care physician to know that they had an STD in college, but not necessarily their dermatologist.


This draft Bill shows promise and may finally get ONC to start talking about the value taxpayers will receive from the HITECH Act, rather than what they have done to date, simply messaging to physicians.

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