The primary focus of CHIME’s Public Policy Program is to advance the role of CIOs and other senior healthcare IT leaders by providing educational, collaborative, and advocacy programs to improve the quality of care. Through our CHIME Policy Chats, we hope to inform CIOs about advocacy efforts and learning opportunities; provide updates on legislative and regulatory issues; and educate them on what CHIME is doing to help shape the implementation of federal and state policies. The discussions feature Sharon Canner, senior director of advocacy, and Jeff Smith, assistant director of advocacy for CHIME.
- Keeping the MU 2 start date
- Embracing opposition — “Criticism can only inform.”
- Data matching & patient consent workgroups
- Need for “action-oriented best practices”
- The unique patient ID issue
- CHIME comments on Stark
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It’s important that we keep the start date. That way we maintain that momentum, and we not only compel the vendors to keep pushing out their products, but we actually give them a little bit of breathing room as well.
There is going to be some criticism of what we’re suggesting, and I think that criticism can only inform.
People cross state lines very often to get care, which poses a dilemma when you are trying to exchange health information and one state has one policy and another a different policy.
We want them to be very action-oriented and we want them to be more than just recommendations that are handed in, but recommendations that can help further the conversation and lead to the kind of change that we need to see happen.
If there’s one thing that CIOs may not have on their radar, it would be the role of various government agencies in regulating health IT and the intersection of patient safety and health information technology.
Gamble: One of the concerns mentioned by some of the CIOs we spoke to was something you touched on a little bit, and that was ensuring that vendor products are ready and are at the level they need to be. This is another facet that could be addressed by extending the deadline.
Smith: Absolutely. I think that, again, we’ll receive some pushback from various groups, but that’s why it’s important that we keep the start date. That way we maintain that momentum, and we not only compel the vendors to keep pushing out their products, but we actually give them a little bit of breathing room as well. We’re hopeful that we can all win on this, because I think we genuinely come from a position of trying to provide a constructive way to optimize program success. I think that truly is at the heart of our recommendation. I think we realize that we’re all in the same boat as far as the government, the congress, the administration, the providers, and the vendors that support the providers. I think we realize that there is a shared responsibility, and there is a need to be smart about how we can proceed.
Gamble: You talked about getting some pushback, and in some ways, that’s a good thing. It’s good to get different viewpoints and get all of that input. It really gives you a good idea of where everyone stands and shows how engaged people are in this.
Smith: Yeah. In subsequent conversations we’ve been engaged with, on both the administration side and with the six senators that put together the Reboot report, they’ve said that one of their primary goals behind releasing this report was to generate conversation. I think the report has done that, and we genuinely appreciate the effort to get the conversation going. So I think you’re right. There is going to be some criticism of what we’re suggesting, and I think that criticism can only inform. But it is up to us at this point to really try and educate both members of congress and the administration — and, quite honestly, the media and some of our partners in the association world — on exactly what it is we are proposing, and how we believe we can get there. Definitely be on the lookout for additional materials and some other things that we’re working on so we can begin that education campaign.
Gamble: I know that summer is approaching, but something tells me you guys aren’t just going to be sitting on the beach for a couple of months.
Smith: No, no matter how much I might want that to be the case, I think that my beach plans have all been cancelled.
Gamble: So switching gears a little bit, I wanted to talk about StateNet. When Sharon was talking about the symposium, she mentioned that Neal Ganguly talked about patient data matching, which is such an important issue that we’re hearing a lot about. Can you talk a little bit about what StateNet has in terms of education on this issue?
Canner: Sure. Just to back up, I think people are quite familiar now that StateNet was established by CHIME some three years ago, and it’s a national network of stakeholders who come together toward robust health information technology and health information exchange. We’re now over 700 participants, and this includes of course CIOs, but also EHR developers, HIE staff — a variety of folks, including individual providers, physicians, etc., across the country. What we decided to do was form two work groups. These work groups are, as you mentioned, patient data matching and the second is consent. And just a word about consent — the patient consent laws vary greatly across states, but healthcare obviously doesn’t stop at the state lines. People cross state lines very often to get care, which poses a dilemma when you are trying to exchange health information and one state has one policy and another a different policy.
We have put out a call for our StateNet members, and this includes everyone — both vendors and CIOs. These work groups, however, are being led by CIOs. Initially, we’re looking to do an environmental scan on what are the patient data matching best practices out there — what are different states and different hospital systems doing? That’s both on data matching and on consent, and obviously, what are the state laws, and then we’ll look at where the gaps are in policy and technology. Each group will then evaluate the existing or possible solutions and make recommendations. We now have a board within StateNet, but we hope to disseminate this in a much broader environment, and eventually, of course, we will be sharing this with other stakeholders. We’re sharing this with ONC and CMS.
We really want to stimulate thinking on both of these issues, particularly on patient data matching. I think you and your audiences are aware that a unique patient identifier is basically off the table for the simple reason that HIPAA legislation — actually it was the appropriation legislation in 1999 — prohibited HHS from spending any money on promulgating a rule that would put out a unique patient identifier. However, that provision never said that HHS could not study the issue, and now, more and more attention is being focused on patient data matching, in particular because of health information exchange.
Through this Policy Chat, we very much are reaching out to folks and asking that if they are interested in either of these issues — patient consent and patient data matching — first to join StateNet (http://ciostatenet.org), just go up on the website and sign up with StateNet, and then indicate your interest in either one of those workgroups.
Gamble: Those are two such huge issues, very hot-button issues, and I can see them generating a lot of interest. It’s good to be able to find CIOs that do have best practices, but unfortunately, there are probably a whole lot more who don’t have the best practices and are looking for some kind of guidance on this.
Canner: There are lots of best practices out there. For instance, how do you write somebody’s birth date? Do you put the day before the month? There is such great variability, when indeed, if you go and order something online on a website and you try to put your basic demographic or your address in differently, they reject it. Healthcare seems a little bit more important than if I’m ordering knobs for my kitchen cabinet, actually.
Gamble: Right, certainly.
Smith: I think one of the products of what we produce — and Sharon mentioned these recommendations, but I really do think that we want them to be very action-oriented and we want them to be more than just recommendations that are handed in, but recommendations that can help further the conversation and, because of who these recommendations will be coming from, really lead to the kind of change that we need to see happen. I think that for both consent and patient data matching, there is a will in the group to develop ways that will actually help get at the issue of inefficient and error-prone data matching techniques. So it is the hope that by having stakeholders from a diverse group, and also having the voice of the CIO driving this conversation, you really are talking to the consumers of the product. And so we’re trying to make this a demand-side economic change that can move the ball forward, especially on patient data matching.
Gamble: It’s such a unique thing that in this industry, every single one of us is a consumer, so there’s that interesting dynamic there and even more of a motivation to want to come up with better practices and solutions for data matching.
Gamble: Okay, so I wanted to see if there was anything else that you felt that CIOs really need to know about, or anything that you wanted to communicate to our audience. I know we’ve gone over a bit but I just wanted to give you that opportunity.
Canner: Of course the CHIME Fall Forum will be from October 8 to 11 in Scottsdale, Arizona. We’ll be discussing some of these issues, and certainly we’ll continue to hold a monthly event for our members in terms of education. But I think the outlook is that there is a lot happening. We didn’t get into Stark and Anti-Kickback rules that we are commenting on. And there’s ICD-10 out there, so just an awful lot to chew on at this point.
Smith: I would just add to the mix something that CIOs are going to have to look at and think about at some point. There is an extreme amount of conversation chatter and activity around patient safety in health IT. There is currently a lot of work being done by a new work group under the ONC Health IT Policy Committee; they’re calling it the FDASIA workgroup, and their timelines are pretty much constrained to the summer. I do think that will be an area that will have some pretty big implications for the role of the FDA in regulating electronic health records, mobile medical apps, and another traditional medical devices. If there’s one thing that CIOs may not have on their radar, it would be the role of various government agencies in regulating health IT and the intersection of patient safety and health information technology.
Gamble: While I have you guys on, did you want to provide some comment on Stark on the Anti-kickback?
Smith: Right now we are on the final stages of submitting comments to the open NPRM, and right now we’re holding to a position that we actually took a couple of months ago. We issued our own letter to the secretary urging her to support a permanent exception to Stark and Anti-Kickback. I think we’re going to be sticking to that and we’ll be issuing a document next week because the deadline on that is going to be in June.
Gamble: Okay, so a lot going on with you guys, as always.
Gamble: All right, and anyone who wants to find more information can go to the site and click on CHIME Public Policy to keep track of everything going on.
Smith: Absolutely, we encourage it. Both Sharon and my contact information shouldn’t be too hard to track down. We always do welcome any questions or comments.
Canner: We’d be delighted to have more stakeholders and have more of your audience join StateNet and express an interest in either one of these workgroups. We very much want to hear from folks out there on what they consider to be best practices, and hopefully try to find more commonalities. Eventually, if we can all get on the same page, I think we will make health information exchange that much more successful and safer for patients.
Gamble: All right, well I really appreciate you guys taking the time to speak with us, and I think it’s great to be able to get your message out there to our readers.
Canner: Thank you very much for having us.
Smith: As always, we appreciate it.
Gamble: All right, thanks. I’ll talk to you guys soon.