I went to visit my Doctor this week for the usual check-up. I am happy to say all is fine with me but the visit did spark something of a discussion in his office about regulatory compliance and how it is managed. When I checked in for my appointment, I was presented with a form to complete, as always and as always it was in paper form. (Not sure why it was paper since he told me has spent nearly $200k so far to go digital as mandated by the government.) That will be the topic for another day, now back to the form.
At the top of the form was the statement, “Required for Meaningful Use”. Knowing what this was referring to and letting my curiosity take over, I asked the simple question, what is meaningful use? The response was simply, it is information we have to put in the system because if we do not, the software will not let us move to the next screen. I then asked, “Why do the questions reflect demographic information like race, and so on”? The reply was the same. This caused me to reflect on the discussion while waiting for my turn in the exam room which in turn, caused me to ask my Doctor his view of what had transpired. So, as he examined me, I cross examined him so to speak. I told him of my encounter and discussion with the young lady in reception. He smiled, knowing that I know a little about this topic, and indicated that this is a tough and vague term to explain to his patients who mostly accept that the software program requires it.
We continued our conversation and he shared with me that though he has spent a sizeable amount of money to “go digital”, he can and does still get pinged for others who are not. For example, if he does not capture that information for reporting purposes, or if he sends a prescription to a location that has fax only, he is considered non-compliant. Now I know it is a bit more complex than that and there are other components that play into it like percentages, but the point is that this is still a very vague term and area for many folks including those in the medical profession, not to mention the challenge of being considered non-compliant if you conduct business with someone not as prepared as you.
Another point he mentioned is the lack of interoperability between systems and he cited me as an example where I had brought in a CD with radiological images and diagnostics from an Emergency Room visit. He could read them on the CD using the embedded viewer but could not import them to his system and my digital file due to incompatibility between the two software applications and the way the files were stored on the CD. The CD was read only.
In my view, this is typical of most industries when legislative mandates appear. While there has been a lot of work going on to establish standards and guidelines, there is still a lot of work ahead to inform those practicing in this field on how to define meaningful use in a way it makes sense to patients and even the workers in the medical profession. Another element that still appears to be out of sync is interoperability between applications. Just because the idea is to standardize information practices and formats, that does not mean it will happen. There must be a set of interoperability standards established that dictates how it will happen and to what degree. Standardizing formats is a good step forward but until one system passes information to the next, seamlessly, you do not have interoperability.
Finally, if there is to be monitoring of compliance and one party has met the operational requirements, how can they be pinged for the fact that another facility, which is beyond their control is not? If Practice A has made the investment and is functioning as required and Practice B who they interact with but is not under their control is not in compliance, how can Practice A be held accountable for Practice B? This indicates that Practice A, in order to maintain compliance, would only be able to do business with others who are in compliance rather than choose the best option for their patient based on specialization and expertise. I am not sure exactly how this is monitored but it apparently is and does have an impact on the practice and whether compliance is met.
I think that the concept of digital patient records is sound and look to a day when I can simply walk into any facility around the country, knowing that they will be able to access my patient files when and if authorized to do so. I also think there are many lessons learned in the content and records management industry that could readily be applied to meet the growing demands faced by medical practitioners in establishing and maintaining compliance. I see these as complimentary in nature. The ECM community teamed with the Electronic Health Records (EHR) application providers is a combination that would certainly help in addressing compliance and interoperability if standards like the Content Management Interoperability Services (CMIS) standard were applied. EHR would be another part of the ECM environment, using the ECM repositories for storage and the interoperability of the ECM systems to meet the demand of standardized information exchange. It may not be perfect, but it is a good beginning.
If as an organization, you are ready to move forward or are struggling with meeting compliance requirements and are not sure where to begin or what to do next, seek professional assistance and/or training to get you started.
What say you? Do you have a story to tell? What are your thoughts on this topic? Do you have a topic of interest you would like discussed in this forum? Let me know.
Bob Larrivee, Director and Industry Advisor – AIIM
Email me: firstname.lastname@example.org
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Look for my session on Mobile Devices in the upcoming AIIM sbcon11 event this September.
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