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On the specific matter of the clinical societies' letter- It's actually mostly very good, and very thoughtful. I should have said that. Its contradictory impulses probably come from being drafted by committee (always easier to add than subtract, as critics of MU remind me). I am concerned that provider groups-- customers-- are at a disadvantage vis a vis vendors, and a strong certification program *can* help, but I do think that there is an unrealistic expectation of how much of the problems with usability, or vendor business practices on interoperability can be solved through ONC regulation or technical standards alone. And certainly little of it would be accomplished with a hobbled agency and a diminished mandate. Farzad
Toggle Commented Jan 28, 2015 on AMA's letter to ONC at Docnotes
Hi Mark! (and greetings, "meltoots") I think what Jacob and I are expressing is a sense of loyalty to an institution that we served to the best of our abilities, and to the many men and women who work very hard, very loyally, and very ably there to improve health for all Americans. Those people and that institution are rarely appreciated, and routinely pilloried by people who are well intentioned, and passionate in their own right. We have seen and heard and listened to their frustration (which is often misdirected) and their policy prescriptions (which are usually unworkable). But when you're a civil servant you don't talk back. There is, and should be sadness at a payment system that forces doctors to squeeze more and more patients into less and less time, and pays for documentation not health. There should be frustration at badly designed and poorly implemented software. There should be dismay at "compliance" officers that over-interpret regulations and enforce absurd contortions. There should be concern about extortionist business practices. Those problems weren't created by ONC, and usually can't be solved by it either. Where we might be fairly faulted is in the audacity to try to get the most out of a piece of imperfect legislation- to implement it aggressively in the face of epistemic humility. That we don't know what we don't know, and there will always be unintended consequences. But while in hindsight you can always do things differently, I don't believe that we were wrong to push as hard as possible to move healthcare into the digital age. We are in a fundamentally different place, and while all of healthcare's problems can now be cast as an EHR problem, there are now also more opportunities for innovators to help. Mark's wonderful lecture ( on four decades of informatics reminded me of how long it takes for a new technology to fully come into its own, and I have to keep reminding myself of that longer lens, even as we work impatiently, urgently to make things just a bit better, together. Farzad
Toggle Commented Jan 28, 2015 on AMA's letter to ONC at Docnotes
Thanks Jacob- What struck me was the contradictory impulses here with respect to what they want from a government regulator. It seems that they are happy to join the vendor bandwagon of "remove onerous regulations" and also slam ONC for not regulating the industry more. We used to feel that if everybody is a little unhappy on opposite sides of an issue, we're probably doing our job at balancing the tensions inherent in regulation. That barometer may be losing its reliability! They want to decouple certification from MU, but they "also feel the Administration is pushing too quickly for the use of CEHRT beyond the MU program" On the one hand, the clinical societies complain that "MU certification has become the priority in health information technology (health IT) design at the expense of meeting physician customers’ needs, patient safety, and product innovation" On the other hand, they want: -more prescriptive testing, more "in-vivo surveillance", and more oversight on ATCBs (all good, but will increase costs for certification) -rigorous testing against a larger "number of clinical scenarios, including “abnormal ones,” -enhanced security, including 2FA- which now "may help bolster vendor innovation" despite lack of consensus approach -less optionality in interoperability specifications -more prescriptive and far-reaching requirements for user-centered design and usability (despite lack of consensus approach) Look- ultimately, the role of government regulations is to protect the public, and empower the customer (doctors and hospitals). The clinical societies are entirely within their rights to ask for more protections vis a vis vendors who wield a disproportionate advantage over them. But they should then stop bashing the regulator for regulating, and support them in getting sufficient funding and authority to do their job well (which I don't recall seeing). /endrant
Toggle Commented Jan 25, 2015 on AMA's letter to ONC at Docnotes
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Jan 25, 2015