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Friday, October 30, 2009

AstraZeneca Settles

Here is the latest in the parade of legal settlements of cases of alleged wrong-doing by health care organizations.  As reported by Duff Wilson in the New York Times,
The pharmaceutical company AstraZeneca said Thursday that it had reached a $520 million agreement to settle two federal investigations and two whistle-blower lawsuits over the sale and marketing of its blockbuster psychiatric drug Seroquel.

One of the investigations related to 'selected physicians who participated in clinical trials involving Seroquel,' AstraZeneca disclosed in a government filing. The other case related to off-label promotion of the drug.

Seroquel was the top-selling antipsychotic drug in America. It had $17 billion in sales in the United States since 2004, according to IMS Health, a research firm.

Tony Jewell, a company spokesman, declined to be more specific about the physicians or clinical trials under investigation. He said the company was in final negotiations to settle the whistle-blower suits and reach a corporate integrity agreement with the Justice Department.

The name of the whistle-blowers and other details of the suits remained sealed in federal court. Stephen A. Sheller, a lawyer in Philadelphia for the whistle-blowers, and Patricia Hartman, a spokeswoman for the United States attorney in Philadelphia, both declined to comment.

Here we go again. As the Times article noted,
AstraZeneca, based in Britain, joins a list of drug makers that have paid billions to settle inquiries initiated by complaints from former company insiders.

Earlier this year, Eli Lilly & Company paid $1.4 billion over its marketing of Zyprexa, another antipsychotic drug. And Pfizer announced it would pay $2.3 billion, including a record $1.195 billion criminal fine, mostly over its painkiller Bextra, which has been withdrawn from the market.

Does anyone really still believe that integrity agreements, and settlements assessed against huge corporations deter such profitable bad behavior? A half a billion dollar one-time settlement is just a small cost of doing business for a company that sold $17 billion worth of the offending drug in the last five years. As in the case of many other previously announced settlements, it appears that nobody who authorized, directed, or implemented the bad behavior that led to the settlement will suffer any sort of negative consequences.

We previously discussed allegations that AstraZeneca manipulated and suppressed clinical research, and organized deceptive marketing campaigns in support of Seroquel sales (here, and here).  If we do not discourage such practices, they will continue to bias the clinical evidence making expensive drugs and devices seem more effective and less dangerous than they really are.  Is it any wonder that we over-use and over-pay for these products?  Anyone seriously interested in reforming health care to improve quality and access while moderating costs ought to pay attention to behavior that leads to such over-use and over-payment. 

(However, there may be hope.  Perhaps in the future there will be more effective deterrence.  A recent indictment named not only the device company Stryker Biotech (a subsidiary of Stryker Corporation), but also its former CEO and three managers.)

An Alliance on Mental Illness or for Pharmaceutical Companies?

A recent article by Gardner Harris in the New York Times focused on the financial links among health care corporations and not-for-profit disease (or patient) advocacy groups.
A majority of the donations made to the National Alliance on Mental Illness, one of the nation�s most influential disease advocacy groups, have come from drug makers in recent years, according to Congressional investigators.

The alliance, known as NAMI, has long been criticized for coordinating some of its lobbying efforts with drug makers and for pushing legislation that also benefits industry.

Last spring, Senator Charles E. Grassley, Republican of Iowa, sent letters to the alliance and about a dozen other influential disease and patient advocacy organizations asking about their ties to drug and device makers. The request was part of his investigation into the drug industry�s influence on the practice of medicine.

The mental health alliance, which is hugely influential in many state capitols, has refused for years to disclose specifics of its fund-raising, saying the details were private.

But according to investigators in Mr. Grassley�s office and documents obtained by The New York Times, drug makers from 2006 to 2008 contributed nearly $23 million to the alliance, about three-quarters of its donations.

Even the group�s executive director, Michael Fitzpatrick, said in an interview that the drug companies� donations were excessive and that things would change.

However, he tried to downplay the influence of the pharmaceutical industry on the Alliance.
'I understand that NAMI gets painted as being in the pockets of pharmaceutical companies, and somehow that all we care about is pharmaceuticals,' Mr. Fitzpatrick said. 'It�s simply not true.'

Note the careful wording of this denial, though. He did not deny that most of what NAMI cares about is pharmaceuticals.

Moreover, the article suggested how cozy pharmaceutical companies and the Alliance's leadership have become.
The close ties between the alliance and drug makers were on stark display last week, when the organization held its annual gala at the Andrew W. Mellon Auditorium on Constitution Avenue in Washington. Tickets were $300 each. Before a dinner of roasted red bell pepper soup, beef tenderloin and tilapia, Dr. Stephen H. Feinstein, president of the alliance�s board, thanked Bristol-Myers Squibb, the pharmaceutical company.

'For the past five years, Bristol-Myers has sponsored this dinner at the highest level,' Dr. Feinstein said.

He then introduced Dr. Fred Grossman, chief of neuroscience research at Bristol-Myers, who told the audience that 'now, more than ever, our enduring relationship with NAMI must remain strong.'

Documents obtained by The New York Times show that drug makers have over the years given the mental health alliance � along with millions of dollars in donations � direct advice about how to advocate forcefully for issues that affect industry profits.

In a letter today to the NY Times, NAMI Executive Director Fitzpatrick tried again to correct "misimpressions."
First, the National Alliance on Mental Illness, or NAMI, has always disclosed corporate and foundation sources of revenue. Until this year, specific amounts remained private for competitive fund-raising reasons.

Second, your estimate that pharmaceutical companies account for three-quarters of �donations� has been misinterpreted as a share of NAMI�s total annual budget � which is actually about 50 percent.

Perusal of the 2008 NAMI Annual Report does include this impressive list of "Corporate Partners":
Abbott
Alexza Pharmaceuticals
Amazon
AstraZeneca
Blue Cross Blue Shield
Bristol-Myers Squibb
College of Psychiatric and Neurologic
Pharmacists
Corcept Therapeutics
Cyberonics
Delivery Agent, Inc.
Forest Laboratories
GEO Care
GoodSearch.com
The Health Central Network
Janssen Pharmaceutica
Eli Lilly and Company
Magellan Health Services
McNeil Pediatrics
Neuronetics
Novartis
Otsuka America Pharmaceuticals
Pfizer
PhRMA
RF Binder
Sanofi-Aventis
Shire
Solvay
Validus Pharmaceuticals
WellPoint
Wyeth
YTB Travel Network

The NAMI web-site now includes lists of specific corporate donations that individually exceeded $5000 since the beginning of 2009. So far this year, the biggest pharmaceutical corporate donors appear to be AstraZeneca ($350,000), Bristol-Myers-Squibb ($506,205), and Eli Lilly ($675,500). 

Looking at the latest Form 990 filed on behalf of NAMI with the US Internal Revenue Service (available from GuideStar here)  provides more interesting detail. (Keep in mind that the 2008 form covers July 1, 2007 to June 30, 2008.)   This form listed the organization's total revenue as $13,788,288, and expenses as $12,796,205.  These expenses included $1,785,060 (13.9%) for management and $1,520,637 (11.9% ) for fund-raising.  The form listed eight NAMI executives who made more than $100,00 a year, including Mr Fitzpatrick ($210,685 total compensation).

So, in summary, it appears that corporate donations, mainly from a few large pharmaceutical companies, supply a substantial portion, (maybe half, if I read the letter by Mr Fitzpatrick correctly) of the annual budget of NAMI. About one-quarter of that budget is spent on administration and fund-raising, including six-figure salaries for at least eight executives.  So who do you expect would more easily get access to the $200K+/year NAMI Executive Director, an executive of a pharmaceutical firm that supplies more than $500,000 a year, or a NAMI member who pays $35 dues?

Here we have another example of a respected patient advocacy organization which gets a substantial portion of its revenue from (presumably the marketing departments of) a few large pharmaceutical companies.  (See another example here.)  Its well-paid executive director can at best bring himself to deny that the only purpose of the organization is to support pharmaceutical marketing and lobbying.  It seems reasonable that for supplying half the budget, the pharmaceutical companies expect considerable help not only with marketing but also with advocacy of policies that favor their corporate goals. 

As I have said before, I do not have a problem with pharmaceutical and other health care corporations marketing their products, and expressing their views on policy. I do have a problem with corporate marketing or policy advocacy is disguised as grass-roots, not-for-profit education and advocacy.  If ostensibly not-for-profit disease (or patient) advocacy organizations like NAMI want to continue to accept corporate money, they should make it clear that they speak for their corporate donors as well as, and probably with priority over their members and patients with the diseases of interest.  Well-intentioned people who pay their dues, and/or make small contributions to NAMI to help the mentally ill might want to consider whether they are likely to have any influence compared to the individual pharmaceutical executives who oversee $500,000+ a year corporate donations.

ADDENDUM (2 November, 2009) - See also comments on the Furious Seasons blog.

The Implementation Workgroup Testimony

Yesterday I spent the day in Washington with the HIT Standards Committee's Implementation Workgroup . The online forum to comment about standards adoption and implementation is now available.

The first article was posted by Aneesh Chopra, the US CTO. The second, my summary of the standards work thus far, will be posted this morning. Additional articles will be posted by others members of the HIT Standards Committee in the next week.

Whenever I hear testimony from teams of smart people, I try to distill everything I've heard into "Gold Star Ideas" - those themes that surfaced over and over. Here are a few:

1. We've learned from other industries that starting with simple standards works well. Mastering web transport standards such as REST takes minutes. Learning RSS takes an hour. Learning HTML takes a day. In the healthcare domain, I learned the basics of HL7 2.x, X12 and NCPDP in about a day.

2. Keep the standards as minimal as possible to support the business goal. Design for the little guy so that all participants can adopt the standard and not just the best resourced. Do not try to create a one size fits all standard - it will be too heavy for the simple use cases.

3. Start immediately rather than waiting for the perfect standard. Use early implementation experiences to create great documentation. Leave aspects of the standard open for future expansion and let innovation occur after adoption.

4. Declare a long term goal for new standards implementation but in the short term map what exists to new standards at the border of the organization rather than convert all existing legacy systems.

5. In early phases of implementation, allow ambiguity in the standard (what Adam Bosworth called Hysteresis) so that implementers can start simply and improve the completeness of their interfaces over time.

These are all reasonable principles. How do we apply them to the meaningful use standards we're all working on?

I asked one group of testifiers to tell me their views about the maturity of standards for the 4 required data exchanges in 2011. Here are their answers, interpreted against the 5 criteria above

ePrescribing - we have a mature standard (NCPDP Script 8.x) that is being enhanced to support new features (NCPDP Script 10.x) on a reasonable timeframe with minimal burden. We have test harnesses, middleware and clearinghouses that will accelerate adoption. We have an ecosystem of application developers. There is work to do to encourage more transactions to flow, but we're in generally good shape.

Lab - we have a mature standard for messaging (HL7 2.x), however we have numerous versions already implemented that will require mapping to HL7 2.51, since replacing all HL7 2.x in legacy systems will be burdensome. The real problem is not the HL7 but the lack of a single national lab compendium of the minimal set of LOINC codes for the most commonly ordered tests that should be implemented by all labs (commercial and hospital). CLIA is also an issue, requiring validation of every interface even if the same interfaced is cloned over and over for the same products. HITSP has already prepared a LOINC subset (700 codes instead of 20,000). The work ahead is part policy (reform CLIA) and part standards. The HIT Standards Committee has established a new workgroup on vocabularies and one of its first charges should be to ensure the appropriate LOINC subsets are available for general use. Regulation should require use of these subsets for lab ordering in 2013.

Administrative transactions (Benefits/Eligibility, Claims etc) - we have a mature standard for messaging (X12 4010) and transport (CAQH Core II). We have new enhancements on the way (X12 5010) that provide value. We have test harnesses, middleware, and clearinghouses that will accelerate adoption. We have many companies that build applications to support administrative transaction exchange. There is work to do to encourage more transactions to flow, but we're in generally good shape.

Quality - a consistent complaint is that every stakeholder (payers, government, specialty specific registries) require different quality measures with different data elements and definitions. There was broad agreement that the work the NQF has done and is doing to select a few consistent measures, with clearly defined data types, and retooling them to be EHR-based (not paper record) is the right thing to do. The measures will likely require controlled vocabularies and we need to be sure the right SNOMED-CT, LOINC, and RXNorm vocabularies plus mapping tools are available to report data in a normalized format for quality measurement.

My synthesis of the advice we received from all the panels is:

Creating controlled vocabularies/code sets is consistent with the simple standards goal. You can imagine an implementation guide that defines an XML format and then points to a website that contains publicly available vocabulary content (such as that developed by NLM or licensed for public use such as SNOMED-CT). Engineers would have no problem downloading and implementing a publicly available vocabulary code set.

Keep transport simple. Several testifiers noted that content and transmission should be separate standards, leveraging the web when possible for transport so that implementers do not need to learn new transport standards.

Get everyone to send the basics - medications (highlighted by everyone as a high value data exchange), problem lists, and labs before focusing on the esoteric.

Security is very important but privacy policy is even more urgent. We can very significantly constrain the number of security standards if a policy framework outlines our goals. For example - do we need a standard-based audit trail for every organization or is it sufficient to create a policy that an audit trail must be available to patients showing who accessed what and when?

What action items should we take?

I would like to get the input from other HIT Standards Committee members, but action items seem to be

1. Work hard on vocabularies and try to get them open sourced for the entire community of stakeholders

2. Consider adding a simple REST-based transport method for point to point exchanges

3. Work jointly with the HIT Policy Committee to establish a privacy framework that enables us to constrain the number of security standards

4. As we continue our work, try to use the simplest, fewest standards to meet the need

5. Continue to gather feedback on the 2011 exchanges - eRx, Lab, Quality, Administrative - to determine if there are opportunities to enhance testing platforms and implementation guidance that will accelerate adoption.

I look forward to continued discussion.

Food Allergies at College

We're still years away from dealing with food allergies at college. I have heard from friends, though, that many campuses have set up food allergy policies. This article, in the Miami Hurricane, student newspaper of the University of Miami, features food allergy issues.

FAAN (Food Allergy and Anaphylaxis Network) recently started a site where parents and students can find out how food allergy friendly campuses are. You enter the name of the university and search. The FAAN College Network seems to be fairly new with limited data at this time. But, check back as more campuses provide information. This could be a great tool for families. I love the concept.

Have any of you dealt with food allergies and colleges? What's it been like?

Thursday, October 29, 2009

That 70's Show

My parents recently remodeled their 1970's home, removing the formica, shag carpeting, and textured ceilings.

Seeing their modern home made me reflect on my personal history in 1976 when their home was built.

I had just started high school at Palos Verdes High. I was a cross country runner and a geeky engineering type wearing aviator glasses, a shaggy haircut and weighing 120 pounds. This photo is of me, Will Snow (my best friend from high school), and a team of engineers from Rockwell. We had the opportunity to tour the Columbia Space shuttle and explore its engine components as they were being built in Southern California. Will and I stay in touch and he recently completed a 125 mile bicycle ride for Multiple Sclerosis in honor of his first wife and my father. He's a senior engineer at SUN (now Oracle).

To give you a real flavor of the 1970's, take a look at my Prom picture (above), now 30 years old. Hillary Stoltz and I attended the prom in Santa Monica, with me in blue velvet including a frilly 1970's tuxedo shirt. By this time, my haircut was evolving to the short and simple way I wear it today. Hillary went to Georgetown and I went to Stanford. I've not reconnected with her since 1980.

The 1970's were a simpler time - no email, no mobile devices, no global village. The competition to get into college was easier and the pace of life was slower. The economy had its ups and downs, we had gas lines, and we had the disco craze (which I ignored). The folk music was soulful, the living was casual, and the fashions were awful.

It was a generally happy time that prepared me well for the challenges to come.

If any folks from my 1970's past are readers of my blog feel free to comment! I'd welcome an update from any of my high school cohort - Phil Talbert, David Kratz, Adrienne Lee, Hillary Stoltz, Gretchen Zimmerman, or Marcia Rorty.

Wednesday, October 28, 2009

Failing to Report Adverse Effects of Treatments

We have frequently advocated the evidence-based medicine (EBM) approach to improve the care of individual patients, and to improve health care quality at a reasonable cost for populations. Evidence-based medicine is not just medicine based on some sort of evidence. As Dr David Sackett, and colleagues wrote [Sackett DL, Rosenberg WM, Muir Gray JA, Haynes RB, Richardson WS. Evidence-based medicine; what it is and what it isn't. BMJ 1996; 312: 71-72. Link here. ]


Evidence based medicine is the conscientious, explicit, and judicious use of current best evidence in making decisions about the care of individual patients. The practice of evidence based medicine means integrating individual clinical expertise with the best available external clinical evidence from systematic research.

One can find other definitions of EBM, but nearly all emphasize that the approach is designed to appropriately apply results from the best clinical research, critically reviewed, to the individual patient, taking into account that patient's clinical characteristics and personal values.

When making decisions about treatments for individual patients, the EBM approach suggests using the best available evidence about possible benefits and harms of treatment, so that the treatment chosen is most likely to maximize benefits and minimize harms for the individual patient. The better the evidence about specific benefits and harms applicable to a particular patient, the greater will be the likelihood that a particular decision based on this evidence will result in the best possible outcomes for the patient.

A new study in the Archives of Internal Medicine focused on how articles report adverse effects found by clinical trials. [Pitrou I, Boutron I, Ahmad N et al. Reporting of safety results in published reports of randomized controlled trials. Arch Intern Med 2009; 169: 1756-1761. Link here.] The results were not encouraging.

The investigators assessed 133 articles reporting the results of randomized controlled trials published in 2006 in six English language journals with high impact factors, that is, the most prestigious journals, including the New England Journal of Medicine, Lancet, JAMA, British Medical Journal, and Annals of Internal Medicine. They excluded trials with less common designs, such as randomized cross-over trials. The majority of trials (54.9%) had private, or private mixed with public funding.

The major results were:
15/133 (11.3%) did not report anything about adverse events
36/133 (27.1%) did not report information about the severity of adverse events
63/133 (47.4%) did not report how many patients had to withdraw from the trial due to adverse events
43/133 (32.3%) had major limitations in how they reported adverse events, e.g., reporting only the most common events (even though most trials do not enroll enough patients to detect important but uncommon events).

The authors concluded, "the reporting of harm remains inadequate."

An accompanying editorial [Ioannidis JP. Adverse events in randomized controlled trials: neglected, distorted, and silenced. Arch Intern Med 2009; 169: 1737-1739. Link here] raised concerns about why the reporting of adverse events is so shoddy:
Perhaps conflicts of interest and marketing rather than science have shaped even the often accepted standard that randomized trials study primarily effectiveness, whereas information on harms from medical interventions can wait for case reports and nonrandomized studies. Nonrandomized data are very helpful, but they have limitations, and many harms will remain long undetected if we just wait for spontaneous reporting and other nonrandomized research to reveal them. In an environment where effectiveness benefits are small and shrinking, the randomized trials agenda may need to reprogram its whole mission, including its reporting, toward better understanding of harms.

Pitrou and colleagues have added to our knowledge about the drawbacks of the evidence about treatments that is publicly available to physicians and patients when making decisions about treatment. Even reports of studies with the best designs (randomized controlled trials) in the best journals seem to omit important information about the harms of the treatments they test.

It appears that the majority of the reports that Pitrou and colleagues studied received "private" funding, presumably meaning most were funded by drug, biotechnology, or device companies and were likely meant to evaluate the sponsoring companies' products. However, note that this article did not analyze the relationship of funding source to the completeness of information about adverse effects.

Nonetheless, on Health Care Renewal we have discussed many cases in which research has been manipulated in favor of the vested interests of research sponsors (funders), or in which research unfavorable to their interests has been suppressed. Therefore, it seems plausible that sponsors' influence over how clinical trials are designed, implemented, analyzed and reported may reduce information about the adverse effects of their products reported in journal articles. Trials may be designed not to gather information about adverse events. Analyses of some adverse events, or some aspects of these events may not be performed, or if performed, not reported. The evidence from clinical research available to make treatment decisions consequently may exaggerate the ratios of certain drugs' and devices' benefits to their harms.

Patients may thus receive treatments which are more likely to hurt than to help them, and populations of patients may be overtreated. Impressions that treatments are safer than they actually are may allow their manufacturers to overprice them, so health care costs may rise.

The article by Pitrou and colleagues adds to concerns that we physicians may too often really be practicing pseudo-evidence based medicine when we think we are practicing evidence-based medicine. We cannot judiciously balance benefits and harms of treatments to make the best decisions for patients when evidence about harms is hidden. Clearly, as Ioannidis wrote, we need to "reprogram." However, what we need to reprogram is our current dependence on drug and device manufacturers to pay for (and hence de facto run) evaluations of their own products. If health care reformers really want to improve quality while controlling costs, this is the sort of reform they need to start considering.

NB - See also the comments by Merrill Goozner in the GoozNews blog.

Implementation and Adoption Hearings

Tomorrow from 9am to 4pm at the Omni Shoreham Hotel in Washington DC, the Implementation Workgroup of the HIT Standards Committee will hold hearings to identify enablers and barriers to the adoption and implementation and standards.

We've assembled a great group from non-healthcare industries, providers, vendors and quality measurement organizations. Testimony will include

Non-Healthcare Industries Panel
Skip Best and Davis Miller, Covisint
Adam Bosworth, XML and SQL
Clarence So, Salesforce.com

Providers Panel
Andy Wiesenthal, MD, Kaiser Permanente (IDN)
Dick Taylor, MD, CMIO, Providence Health, Portland, OR (IDN)
Rick Warren, VP/CIO, Allegiance Health, MI (Community Hospital)
Lisa Bewley, RN, VP/CIO, Regional West Medical Center, Scotts Bluff, NE (Community Hospital)
Louis Spikol, MD, Allentown, PA (Small Practice)
Floyd "Tripp" Bradd, MD, Front Royal, VA (Small Practice)

Vendors Panel
Rick Ratliff, SureScripts
Arien Malec, Relay Health
Sean Nolan, MicroSoft
Girish Kuman, eClinicalWorks
Chris Stevens, Orion Health

Quality Measures Panel
Ralph Brindis, American College of Cardiology
Richard Gliklich, CEO, Outcome Sciences
Jesse Singer, NYC Health
Barbara Rabson, Massachusetts Health Quality Partners
Jack Bowhan, Wisconsin Collaborative for Healthcare Quality

What kind of testimony can you expect?

In non-healthcare industries, standards have been used to coordinate the supply chain. What tools and techniques were used to encourage the entire manufacturing ecosystem to participate?

Do we need better educational materials such as implementation guides that include all the base standards so that there is no "indirection" - jumping between implementation guide websites and standards development organization websites?

Are there gaps in standards that need to be filled to encourage adoption in different healthcare environments?

The real purpose to the meeting is to encourage transparency and build a feedback loop that connects real world users of standards with the organizations that govern and create standards development.

During the meeting we'll kick off a new website that will enable the public to post comments about standards, privacy, and implementation experiences, including the ability to rank ideas via social networking tools. I'll post the URL to the new website tomorrow.

To participate in the meeting, join by audio conference or webcast.

I look forward to hearing your feedback!

Getting Enough Vitamin D

A recent study out of Harvard reveals that one in five children between the ages of one and eleven, are not getting enough Vitamin D. We need vitamin D to help maintain calcium levels to keep our bones strong. It also turns out that this vitamin might help prevent serious diseases, including infections, osteoporosis, diabetes and even some cancers.

It's important.

For people with food allergies, getting enough vitamin D may be challenging. In the U.S., milk is fortified with Vitamin D. For the dairy allergic, getting vitamin D by drinking milk is not an option. Turns out, milk alone (even 8 glasses a day!) is not an adequate source. A glass of milk typically contains 50-100 IU. We may need between 1,000 to 2,000 IU per day of vitamin D. Research is ongoing to pinpoint the daily requirement of Vitamin D.

Good natural sources of Vitamin D can be found in fatty fish such as salmon, tuna and sardines. Sunlight is a source of the vitamin as well. Of course excessive sun exposure can cause other problems, so be sensible.

If you're concerned about Vitamin D, talk to your doctor and see if a supplement might be beneficial.

Tuesday, October 27, 2009

"Project" and "Product" Certification

Last Friday night I testified to the President's Council on Science and Technology (PCAST). Many issues were discussed, but one of the most interesting was the idea of "project" verses "product" certification.

Here's the significance.

In Massachusetts, Partners Healthcare and Beth Israel Deaconess use home built EHR solutions based on Intersystems Cache. We both use Sun's eGate (now Oracle) and Intersystems Ensemble as middleware. We both use datamarts/data warehouses based on extracts from our clinical systems to support quality reporting, performance measurement and research. We both use NEHEN as our healthcare information exchange.

We'll achieve meaningful use via this combination of applications with many moving parts. Its totality provides the tools our stakeholders need. We need to certify the sum of the "project" and not the individual "products".

"Project" certification can be empowering in other ways.

Imagine that innovative products such as Microsoft Healthvault/Amalga or Google Health offer services to aggregate data from multiple data sources as part of quality reporting. They can become accelerators of meaningful use.

Imagine that a Modular EHR (such as Quest's Care360) plus a Healthcare Information Exchange can store the lab and medication data needed to coordinate care. Quest and iPhone app innovators can accelerate meaningful use.

My experience is that federated authorship - harnessing the talents of many companies and individuals - leads to the most rapid innovation.

Of course, some of the most advanced aspects of meaningful use, such as comprehensive decision support, may require larger, fully integrated EHRs. But other aspects such as the data exchanges required for 2011 - eRx, Lab, Quality reporting, and administrative transactions - can be empowered by assembling multiple products and services.

Since the theme of the work of the HIT Standards Committee for the next few months will be accelerating standards adoption and implementation (more on this in my blog tomorrow), encouraging all stakeholders to innovate by creating reusable components in support of meaningful use seems timely.

As the Notice of Proposed Rulemaking (NPRM) is written to define the certification process, I encourage policymakers to certify "projects" in addition to "products", encouraging innovation. I have no direct influence on this work, but I am hopeful that industry and clinician stakeholders will provide this input to those writing the policies.

Monday, October 26, 2009

Who Should Sponsor Comparative Effectiveness Research?

We have tried to argue why comparative effectiveness research is a good idea. To cut and paste what I wrote in a previous post,

Physicians spend a lot of time trying to figure out the best treatments for particular patients' problems. Doing so is often hard. In many situations, there are many plausible treatments, but the trick is picking the one most likely to do the most good and least harm for a particular patient. Ideally, this is where evidence based medicine comes in. But the biggest problem with using the EBM approach is that often the best available evidence does not help much. In particular, for many clinical problems, and for many sorts of patients, no one has ever done a good quality study that compares the plausible treatments for those problems and those patients. When the only studies done compared individual treatments to placebos, and when even those were restricted to narrow patient populations unlike those patient usually seen in daily practice, physicians are left juggling oranges, tomatoes, and carburetors.
Comparative effectiveness studies are simply studies that compare plausible treatments that could be used for patients with particular problems, and which are designed to be generalizable to the sorts of patients usually seen in practice. As a physician, I welcome such studies, because they may provide very useful information that could help me select the optimal treatments for individual patients.

Because I believe that comparative effectiveness studies could be very useful to improve patient care, it upsets me to see this particular kind of clinical study get caught in political, ideological, and economic battles.

In particular, we have discussed a number of high profile attacks on comparative effectiveness research, which often have featured arguments based on logical fallacies. While some of the people making the attacks have assumed a conservative or libertarian ideological mantle, one wonders whether the attacks were more driven by personal financial interests. For example, see our blog posts here, here, here, and here. On the other hand, we discussed a clear-headed defense of comparative effectiveness research by a well-known economist most would regard as libertarian here.

Comparative effectiveness research has been discussed as an element of health care reform in the US. It turns out that the current version of the health care reform bill in the US Senate has a provision to create a Patient Centered Outcome Research Institute, which presumably would become the major organization which could sponsor comparative effectiveness research.

This institute, however, would not be a government agency (despite the name that makes it sound like it would be part of the National Institutes of Health). Moreover, here is a description of the Board of Governors who would run the institute from the current version of the bill :

BOARD OF GOVERNORS.�
(1) IN GENERAL.�The Institute shall have a Board of Governors, which shall consist of 15 members appointed by the Comptroller General of the United States not later than 6 months after the date of enactment of this section, as follows:
(A) 3 members representing patients and health care consumers.
(B) 3 members representing practicing physicians, including surgeons.
(C) 3 members representing private payers, of whom at least 1 member shall represent health insurance issuers and at least 1 member shall represent employers who self-insure employee benefits.
(D) 3 members representing pharmaceutical, device, and diagnostic manufacturers or developers.
(E) 1 member representing nonprofit organizations involved in health services research.
(F) 1 member representing organizations that focus on quality measurement and improvement or decision support.
(G) 1 member representing independent health services researchers.


Thus, only 3/15 members of the governing board would represent the patients who ultimately reap the benefits or suffer the harms produced by medical diagnosis and treatment. Further, 6/15 members represent for-profit corporations which stand to make more or less money depending on how particular comparative effectiveness studies come out. Also, 3/15 members would be physicians, some of who may get paid more to deliver particular treatments (e.g., procedures) than others (e.g., providing advice about diet and exercise).

We often discuss how clinical research sponsored by organizations with vested interest in the research turning out to favor their products or services may be manipulated to favor these interests, and sometimes suppressed if it does not. In the US, there are few unconflicted sources of sparse funds to support comparative effectiveness research. (The most significant current source is the Agency for Healthcare Research and Quality, AHRQ. For full disclosure, I have been an ad hoc reviewer of grants for that agency.)

The current draft of legislation would create the largest potential sponsor for comparative effectiveness research, but would make that organization report to representatives of for-profit companies whose profits may be affected by the results of such research. In my humble opinion, this is not much of an advance. Comparative effectiveness research controlled by corporations that stand to profit or lose depending on its results will forever be suspect.

If the government is going to support comparative effectiveness research, it ought to make sure such research is not run by people with vested interests in the outcomes coming out a certain way. I may be biased myself, but why not let the research be sponsored by AHRQ, an agency with relevant experience and no axe to grind vis a vis any particular product or service?

Miss Roben's, The Allergy Grocer, is Back

Oh, how I've missed you, Miss Roben's...

For those of us who have been buying allergy friendly foods for awhile, Miss Roben's was a one-stop shop. Only available through mail order, Miss Roben's and The Allergy Grocer, offered a wide variety of foods and helpful telephone advice.

Then came news that Miss Roben's was out of business. Many of us struggled to find substitutes for our favorite mixes and ingredients. Shopping several companies meant increased shipping and handling costs. It was a big loss to the food allergy community.

Then, finally a few months ago, brought news that Miss Roben's and The Allergy Grocer would be back- bigger and better.

Well, they're here. I just got off the phone with Seth. They've got an updated website and will offer live chat as well as online and telephone orders. The website will be involved in testing over the next few days, so it may go down from time to time. For this week, call in your orders (New Number: 1-888-476-3350) while they get the last few kinks ironed out. You can also sign up for their newsletter to receive special offers.

Go ahead, check it out.

Welcome back Miss Robens and The Allergy Grocer. You're looking good!

Accelerating Implementation of Laboratory Standards

On October 20, the Information Exchange Workgroup of the HIT Policy Committee heard testimony from laboratory information exchange experts and stakeholders.

The agenda and testifiers included:

Business Issues related to the Electronic Exchange of Laboratory Data
? Mike Nolte, GE Health Systems
? Vasu Manjrekar, eClinicalWorks
? Phil Marshall, WebMD
? Tim Ryan, Quest Diagnostics
? Susan Neill, Texas Department of State Health Services

Business Issues related to the Electronic Exchange of Laboratory Data
? Laura Rosas, New York City Primary Care Information Project
? Sarah Chouinard, Primary Care Systems, Inc. and Community Health Network
? Raymond Scott, Axolotl Corporation
? Areg Boyamyan and Jim Timmons, Foundation Library

Regulatory and Policy Issues
? Joy Pritts, Georgetown University Health Policy Institute
? Don Horton, LabCorp
? Jonah Frohlich, California Health and Human Service Agency
? Walter Sujansky, Sujansky & Associates

You'll find an unofficial transcript here. (Thanks Brian!)

The major themes of the day were

1) Labs are complicated - there is great variation in the standards used, vocabularies adopted, and the way labs are ordered (there is no universal ordering compendium, but this is a project that HITSP and the HIT Standards Committee are working on)

2) CLIA is considering allowing �simultaneous delivery� of results to a Health Information Exchange instead of just to the ordering clinician

3) State laws are highly heterogeneous, as is enforcement

4) We need adoption and implementation of robust messaging and vocabulary standards. We should focus on the 300-400 tests that make up the vast majority of ambulatory lab transactions, and create a national mapping for those.

5) Lab results/ordering according to a well-defined national standard should be part of EHR certification

6) Meaningful use payments to hospitals should be contingent on their delivering outpatient labs according to the same standards recommended for EHR vendor certification. (I agree with this - BIDMC has committed that all its lab delivery to external organizations will use HITSP and HIT Standards Committee recommended standards in time for 2011 Meaningful Use payments.)

7) EHRs need to be conformance tested against specific standards to reduce the cost of interfaces.

A great day of testimony. I know that change is difficult but universal adoption of the HITSP Lab Result Capabilities, which provide significant implementation guidance for HL7 2.51 messaging, LOINC, UCUM, and SNOMED-CT will reduce the cost of lab interfacing. This, combined with the HITSP Lab ordering Capabilities to be completed by January, will accelerate adoption and implementation.

I support universal conformance testing of products for certification and a requirement for all stakeholders to use these standards as part of meaningful use criteria to claim stimulus funds.

Since 2011 data exchanges for meaningful use require Laboratory result exchange, there is urgency to do this. Over the next few months, the HIT Standards Committee will be spending a great deal of time discussing the ways to reduce barriers and enhance adoption so that we achieve the interoperability we need.

Sunday, October 25, 2009

Clinic's medical files vanish

At "Data Malpractice on T-Mobile Sidekick: But Don't Worry, Your Medical Data is Safe", on Oct. 16 I wrote:

One of the promises made about healthcare IT is that your medical data is "safer" in electronic form than in paper form. The Hurricane Katrina example of paper records being destroyed is often used as a poster example of the dangers of paper records.

However, the risk of electronic storage of information, especially the talk of national EMR's stored on the "cloud" (an amorphous term meaning distributed storage "out there" whose physical sites and boundaries are supposedly irrelevant from the user's perspective) has also been under-reported.

Personal customer data had been "lost" from many of T-Mobile USA's Sidekick devices due to a computer malfunction, although the data was apparently recovered eventually, apparently through luck rather than good engineering.

I expressed concern that such mishaps could affect clinical IT. I did not have to wait long for such a case to appear. Less than one week.

Below is a story of a Canadian clinic that lost two years of electronic health records:

Clinic's medical files vanish

By Ryan Cormier, Edmonton Journal

October 21, 2009

During a recent investigation into whether a patient's confidentiality had been breached at the Fairview Medical Clinic, an investigator asked for a log of who had accessed the complainant's file. When the clinic responded that it had automated his records in 2004 but only had files from 2006 on, alarm bells rang.

"That raised a lot of questions," said Leahann McElveen, an investigator with the office of the information and privacy commissioner.

The clinic had permanently lost two years worth of health files that include patient information on visits, prescriptions, lab reports, doctor's notes and other information. The loss happened when the clinic switched from one electronic medical records system to another.

"They were two similar systems intended to do the same thing," McElveen said. "However, they weren't coded the same way behind the scenes. It's not that the records fall into the wrong hands, they just don't exist anymore."


*POOF*.

Deinstallation of one system in favor of another is not uncommon. EHR data may become unavailable due to lack of data portability and the expense of data migration, or in this case apparently due to preventable technical problems.

It is essential for clinical IT users to have robust disaster recovery and business continuity solutions, and take great care when performing actions that can lose large amounts of data very fast. This adds to clinical IT cost, and a concern is that some users might skimp on these capabilities.

This must be discouraged.

(To the reader: do you back up your own PC or Mac reliably?)

-- SS

Washington Post Article: Electronic medical records not seen as a cure-all

Regarding the very well done Sunday Oct. 25, 2009 story in the Washington Post "Electronic medical records not seen as a cure-all" by staff writer Alexi Mostrous - signup may be required for access - I have several observations.

(Not including the observation that Mr. Mostrous probably deserves an award for being the first major newspaper reporter to broach this topic in a serious and balanced manner.)

First, I believe healthcare IT can live up to all the predictions made about its benefits - but only if done well. There is massive complexity behind those two words "done well", and that is HIT's key stumbling block in 2009. I believe we are only in the adolescent stage of knowing how to "do health IT well."

Second, I should point out that the intended consequences of health IT include, among many other things, the following "hiding in plain sight" (i.e., not often verbalized) intended consequences:

  • The improvement of medicine ... in the context of protection of patient rights established over centuries of development of modern medicine.
  • The improvement of IT itself through cross disciplinary collaboration between IT and medicine, of the science of IT (computer science), the social aspects of computerization ("sociotechnical issues"), and improvement of the our understanding of the intersection of medicine and computers.

Instead, we largely have the opposite. Patients' rights are trampled, and hostility and territoriality has arisen between clinicians (including medical informaticists) and IT, groups that rarely if ever interacted in hospitals ten or twenty years ago.

Of concern, when scientific study sections evaluate NIH grant proposals calling for testing of new IT that involves patients, patient protections and informed consent processes are a paramount concern since such activities are considered research. Yet, in implementing large clinical IT system in a hospital with new features, there are no formal regulations, and I'm not sure there's even IRB involvement in most cases. Patients do not get the chance to give informed consent to the use of these IT devices mediating their care. Why the difference?

The unintended results of computerization efforts have also included suppression of research on sociotechnical issues and on informatics, which must include study of the downsides of HIT, and of the failures in addition to the study of the successes. That is scientific fact - there is no room for debate, no room for spin on the need for careful study of the downsides of any mission critical domain. One would think there to be a vibrant literature on these issues, Yet searches on massive biomedical databases such as PubMed on, say, "cerner electronic health record" (or other vendors as well) are disappointing to say the least. Further, my own website on HIT difficulties remains nearly unique (PPT) after ten years online. That is not bragging; it is a disturbing finding to me - symptomatic of an industry that somehow has managed to avoid serious scrutiny.

In a field with downsides, there are:

1) those who know about the problems but fail to speak,
2) those who see the problems but fail to act, and
3) those who see, know and speak/write/research the problems.

That said, now on to the Washington Post article:

... bipartisan enthusiasm has obscured questions about the effectiveness of health information technology products, critics say. Interviews with more than two dozen doctors, academics, patients and computer programmers suggest that computer systems can increase errors, add hours to doctors' workloads and compromise patient care.

I would include the bipartisan enthusiasm under the subject header of "irrational exuberance", which itself falls under the header of "lack of domain knowledge." That itself is a consequence of both failure to study the issues, and suppression of those issues by those with an interest in doing so.

health IT's effectiveness is unclear.

The literature is indeed conflicting, and the need for rigorous scientific study has never been more essential considering the commitment of tens of billions of dollars towards health IT. The time for story telling, marketing based on opinion, name calling, leap-of-faith extrapolations of light year dimensions, and other forms of pseudoscience and non-science are over. The time for objective study is now.

The Senate Finance Committee has amassed a thick file of testimony alleging serious computer flaws from doctors, patients and engineers unhappy with current systems.

Being the ranking member of that committee, Sen. Grassley has a fiduciary responsibility to protect Medicare and Medicaid patients (and one might argue, to protect all patients since those programs often serve as models for private insurers). In that regard, the investigation he has initiated is part of his responsibility as a ranking member of Congress. Politics aside (and there are those who will resort to ad hominem "political witch hunt" arguments), he would have been negligent if he had not initiated an inquiry.

Sen. Grassley has taken on the pharma industry and the government's Food and Drug Administration itself, such as in this recent article "FDA fails to follow up on unproven drugs" where he concluded from a GAO study he ordered that "FDA has fallen far short of where it should be for patient safety." He seems quite serious about medical safety.

If only others in Congress had done their job similarly regarding national finance, we might now not be in the worst economic crisis since '29 with many major industries failing.

David Blumenthal, the head of health technology at the Department of Health and Human Services, acknowledged that the systems had flaws. "But the critical question is whether, on balance, care is better than before," he said. "I think the answer is yes."

This sounds uncomfortably like how a pharmaceutical company might respond to doubts about drug effectiveness and safety. In reality it's really irrelevant what he "thinks." Where's the data? Is this a political statement, a personal belief, or a statement backed up by scientific fact that is not cast into doubt by other research results? Our own National Research Council, Joint Commission, and other international organizations have written about their doubts and concerns about HIT [as that IT is designed and implemented in 2009]. If there is rigorous, systematic research weighing pro's and con's to back this assertion, I wish it would be published.

For his statement is really saying "we don't really know how many systems have flaws, we know some do, and we don't really know the full extent of the impact of those flaws, but because there can be some benefits, let's spend $50+ billion before we know the extent of the problems and fix them." I point out research from Harvard forty years ago, when Harvard informatics pioneer Dr. Octo Barnett published the "Ten Commandments of HIT." Two of those commandments were:

... 8. Thou shall be concerned with realities of the cost and projected benefit of the computer system [i.e., ROI - ed.]

10. Be optimistic about the future, supportive of good work that is being done, passionate in your commitment, but always guided by a fundamental skepticism.

The full set is in this post. Somewhere in the past 40 years, the rigorous ROI evaluations (which also must include systematic evaluations of risk, as any businessperson knows) and the fundamental skepticism seem to have gotten lost.

Over the next two months, Blumenthal will finalize the definition of "meaningful use," the standard that hospitals and physicians will have to reach before qualifying for health IT stimulus funds.

This is an example of putting the cart before the horse, and is a semantically-based, self contained logical fallacy of sorts. If a health IT system is harmful, the term "meaningful use" is itself Orwellian. If we don't know if HIT is beneficial, or have doubts, then such as term presupposes that health IT is inherently beneficial. A better term would have been "good faith use" - use based on the faith or hope that health IT will have an overall positive effect. The term "meaningful use" jumps the gun and is more a political slogan than a "meaningful term."

"If you look at other high-risk industries, like drug regulation or aviation, there's a requirement to report problems," said David C. Classen, an associate professor of medicine at the University of Utah who recently completed a study on health IT installations.

This is obvious, the reasons for it are obvious, and the reasons why health IT needs a requirement for problems reporting (one aspect of post-marketing surveillance, the "Phase IV" study as it is known in pharma) is obvious. Yet in 2009, no such requirement exists (see my post "Our Policy Is To Always Have Unabashed Faith In The Computer" for more on why we need reporting requirements.) Why do these requirements simply not exist in HIT?

"It's been a complete nightmare," said Steve Chabala, an emergency room physician at St. Mary Mercy Hospital in Livonia, Mich., which switched to electronic records three years ago. "I can't see my patients because I'm at a screen entering data." Last year, his department found that physicians spent nearly five of every 10 hours on a computer, he said. "I sit down and log on to a computer 60 times every shift. Physician productivity and satisfaction have fallen off a cliff."

The industry in the past has called such physicians "luddites", "resistant to change", "stubborn" etc. However, argumentum ad hominem is a fallacious mode of argument that has no place in a scientific field such as biomedicine. There also seems to be quite a lot of such concerns expressed by a large number of physicians, nurses, etc., and dismissing their concerns with a wave of the hand is cavalier in the extreme - again, these are first principles, without room for argument or debate. Let's study the issues rigorously and scientifically before resorting to ad hominem.

Other doctors spoke of cluttered screens, unresponsive vendors and illogical displays. "It's a huge safety issue," said Christine Sinsky, an internist in Dubuque, Iowa, whose practice implemented electronic records six years ago.

See my eight part series on mission hostile clinical IT here for examples of what Dr. Sinsky is referring to.

She emphasized that electronic records have improved her practice. "We wouldn't want to go back," she said. "But EHRs are still in need of significant improvement."

Yes, not cancellation, but improvement. And, quite importantly, before tens of billions of dollars are spent. Hospitals and physician offices are not an IT development laboratory, since the users of these facilities (patients) have very special rights and the clinicians, very special obligations and responsibilities.

Legal experts say it is impossible to know how often health IT mishaps occur. Electronic medical records are not classified as medical devices, so hospitals are not required to report problems.

That after decades of HIT development, sales and implementation we cannot know with certainty how often mishaps occur is, quite simply, a scandal of major proportions. Quoting an old House of God law, #10: "if you don't take a temperature, you can't find a fever." Another applicable aphorism seen on another discussion board: "you can only be so negligent or craven before the only remaining rationale is that you intended the result."

"Doctors who report problems can lose their jobs," Hoffman said.

I've taken risks with my own career in criticizing health IT, as have my colleagues. Hoffman is not exaggerating.

"Hospitals don't have any incentive to do so [speak out about problems with HIT] and may be in breach of contract if they do."

Imagine the outcry if the same prevailed regarding drugs or medical devices. The cemeteries would be lined with people whose epitaph could read "we bury our mistakes."

While orange-shirted vendor employees "ran around with no idea how to work their own equipment," the internist said, doctors struggled to keep chronically ill patients alive. "I didn't go through all my training to have my ability to take care of patients destroyed by devices that are an impediment to medical care."

This gets to issues I first raised in my website on HIT difficulties: who are these IT personnel, and what are their qualifications, exactly, to be working in mission critical medical environments? How is their competence evaluated?

I think these are questions that need to be answered.

-- SS

Saturday, October 24, 2009

Washington Post: EMR's No Cure-All; Sen. Grassley Sends Letter of Inquiry to health IT vendors

Senator Grassley has sent a letter out to ten major health IT vendors seeking information on health IT problems and flaws. The letter can be retrieved from this link (PDF) at the Washington Post. Read the whole thing.

It is linked via a Washington Post story "Electronic medical records not a cure-all", Sunday Oct. 25, 2009, by staff writer Alexi Mostrous. The WaPo article itself seems to require registration. I will comment on the article in future posts.

Addendum 10/25: I have now commented on the article here.

-- SS

Friday, October 23, 2009

"Organisational Ethics Policies; A Primer"

I regret that it took me so long to find an essay on "Organisational Ethics Policies" by Howard Whitton, available from the European U4 Anti-Corruption Resource Center. While it was written with international non-governmental organisations (NGOs) who "administer aid programs" in mind, it seems applicable to all kinds of NGOs and not-for-profit organizations, including those in health care. In the US, most medical schools and their parent universities, most hospitals and academic medical centers, essentially all medical societies and disease advocacy groups, and some insurance companies and managed care organizations are not-for-profit.

The main points of the paper are its summaries of the basic elements of "effective ethics policies."

First, such a policy

- must first have unequivocal authority and the endorsement of boards and senior management, and must be:
o founded on the organisation�s core values, mandate, and ethical principle
o developed in consultation with those affected by it
o realistically achievable
o written in plain language, coherent with other policies, and easily available
o clearly understood by staff, and by other stakeholders
o consistent with the organisation�s policies on rewards and sanctions
o regularly reviewed and evaluated with all stakeholders
o universally applied, and transparently enforced.


The main content areas might include such "major areas of ethical risk" as:
o financial management and accountability standards
o internal and external audit processes
o professional ethics, conduct, and conflict of interest standards
o fair treatment rules for staff and clients
o processes for the prevention of fraud and other abuse of trust
o integrity mechanisms governing proper decision-making
o provision of transparent information to stakeholders
o complaints and whistleblower disclosure processes
o principled policy dispute processes
o transparent and objective evaluation mechanisms.

So, specific policies should include the following functional elements:

o a code of conduct/ethics based on the organisation�s core values
o professional practice standards interpreting the code�s principles
o procedures for managing conflict of interest situations (including the registration of relevant interests and assets of decision makers)
o procedures for offering and accepting gifts and business courtesies
o criteria for the proper use of organisational assets and authority
o prohibition of harassment and discrimination in the workplace
o criteria for protected reporting of unethical or illegal behaviour
o rights of clients to obtain service, including complaint procedures for failure to meet standards
o obligations for accountability and transparency,and information provision
o standards for dealing with confidential and privileged information
o constraints on ancillary and post-separation employment
o standards for providing reasons for administrative decisions.


Also the policies should include:

� A commitment to training staff in the full range of ethics-related activities. Training will improve personal awareness and strengthen the ability to define and manage improper conduct, whether by co-workers, managers, or external stakeholders.
The range of training themes should include the organisation�s integrity system, specific anticorruption measures, harassment-free workplaces, non-discrimination principles, financial management and audit, integrity in procurement practices, donor relations, personal and institutional conflict of interest, accountability, responsibility, procedural fairness, and strategic problem-solving.

� Policies and procedures for regular management reporting to boards and executives, in particular to enable monitoring of matters which may be of particular concern from time to time.

� Independent, external scrutiny of policies provide an important resource for boards and executives for ensuring that espoused core values and actual behaviours are aligned, and to identify areas of policy and management practice requiring
improvement.

� Policies and procedures for protected reporting of improper conduct, both to enhance worker and stakeholder confidence in the integrity of an organisation, and to provide avenues for early detection of inappropriate behaviour. Genuine
whistleblowing must be effectively endorsed, and effectively protected, to ensure the organisation�s credibility.

� Procedures for the sanctioning of improper conduct and failure to meet relevant standards by staff, structured so as to enhance management�s capacity to deal effectively with ethical issues in the workplace.

Such policies cannot be considered ethical panaceas, but in my humble opinion (and based, I believe, on at least a little cognitive psychology), visible, reasonable, clear ethics policies could reduce the sort of bad behavior that Health Care Renewal often discusses on the part of leaders of major health care not-for-profit organizations and NGOs.

So, those of you who work for or are otherwise affiliated with a not-for-profit university, medical school, hospital, academic medical center, medical organization, disease advocacy organization, or insurance company/ managed care organization might want to go through the exercise of answering these questions:
1 - Does your organization have anything that resembles an ethics policy?
2 - If so, which of the characteristics listed above does it have?
3 - Which of the content areas listed above does it include?
4 - Which of the functional and additional elements listed above does it include?

If much is missing, is there an obvious reason for what was omitted? If the policy seems poorly characterized or incomplete, why should it not be improved? Would you feel comfortable suggesting improvements? If not, why not, and what does that say about the organization?

Cool Technology of the Week

I'm sitting at Logan Airport awaiting a plane to Washington to testify at a meeting of the President's Council of Advisors on Science and Technology at the National Academic of Sciences.

A few minutes ago, I noticed that the tarmac was empty of planes and numerous black SUVs appeared. Then I noticed a few military folks running around the roof of Terminal C. I looked to the north and saw a large 747 approaching - Air Force One.

Realizing that today is Friday and its time for my Cool Technology blog, I'd like to declare Air Force One the cool technology of the week. I've always wondered what electronics are on board. Here's an overview from HowStuffWorks

"The most remarkable feature on the plane is it's extensive electronics. It has 85 onboard telephones, a collection of two-way radios, fax machines and computer connections. It also has 19 televisions and assorted office equipment. The phone system is set up for normal air to ground connections and secure lines. The president and his staff can reach just about anybody in the world while cruising tens of thousands of feet in the air.

The onboard electronics include about 238 miles of wiring (twice the amount you'd find in a normal 747). Heavy shielding is tough enough to protect the wiring and crucial electronics from the electromagnetic pulse associated with a nuclear blast.

Some of the most interesting parts of the plane -- it's advanced avionics and defenses -- are classified. But the Air Force asserts the two planes are definitely military aircraft, designed to withstand an air attack. Among other things, the plane is outfitted with electronic counter measures (ECM) to jam enemy radar. The plane can also eject flares to throw heat-seeking missiles off course."

And where did all those black SUVs and support equipment come from? In advance of every Air Force One flight, the Air Force crew sends C141 Starlifter cargo carrier planes, carrying the president's motorcade to the destination. This collection of bulletproof limousines and vans, loaded with weaponry, keeps the president safe on the ground.

Air Force One is effectively a secure, mobile data center - that's cool!

Food Allergies: A YouTube Sensation

Do you know there are over 2,000 YouTube videos devoted to food allergy? You can find everything from a mom conversation with Disney chefs about food allergies to recipes to back to school tips.

The ones I like the best are devoted to teaching children about food allergies. Look through the list and see if you can find a few that help your family deal with food allergy.

Thursday, October 22, 2009

The Books on My Nightstand

A year ago I wrote about the books on my nightstand. Here's an update of what I'm currently reading:

The Deadly Dinner Party by Jonathan Edlow - a great collection of medical mysteries written by my colleague in the BIDMC emergency department. You'll find hard to solve cases with diagnoses such as botulism, typhoid, and bath water infected with tropical organisms from pira�a. House meets Sherlock Holmes.

The Lady and the Monk by Pico Iyer - The story of world traveler Pico Iyer's year in Kyoto and his immersion into Japanese culture. As a fan of Japan, I can certainly relate to the rich experiences he describes in his travels. Some folks have suggested that my disciplined life, black attire, and continual pursuit of a simpler existence gives me a monk-like character.

The China Study by T. Colin Campbell - A great overview of the relationship between nutrition and health, including the consequences of eating an animal-based diet.

Food for Life by Neal Barnard - I've been chatting with a few policymakers about the importance of nutrition and recently exchange emails with Dr. Barnard. In the book, he suggests his own food groups (grains, vegetables, fruits, and legumes), then discusses the positive impact of a vegan diet on health.

Blue Book of Bike Repair by Calvin Jones - Having recently replaced my hybrid mountain bike drive train , I found this book by the Park Tool Company to be an invaluable guide to modern bicycle components and repair.

Mushrooms Demystified by David Aurora - This book is the mycologists bible and is what I use for the hundreds of mushroom consults I do every year. I recently worked with the ICU team at BIDMC on an Amanita ingestion and this book was a great guide for me.

Dogs and Demons by Alex Kerr - Alex is a great observer of Japanese culture and he explains how the Japanese economy is built on public works projects that are destroying the natural beauty of the country.

Anthology of Japanese Literature by Donald Keene - Donald Keene is the finest editor of Japanese traditional literature for English Language readers. This book contains selections of just about every genre of Japanese literature from No plays to novels.

A self published book of sonnets - 30 years ago when I was 17 I wrote sonnets in memory while cycling up and down the California coast one summer. My 16 year old daughter is writing sonnets in her AP English class, so I pulled my collection from my archives. Here's a sample (I was 17 at the time, so be kind)

An Ageless Plea

If old age brings the wisdom new lives seek,
Then why am I here writing all alone?
With well earned trophies of triumphs to speak,
An withered hands that built your cornerstone.
For pity I won't grovel or request,
Remember - what I've done you'll later do.
And if you somehow think your youth is best,
Remember - what I am will soon be you.
Through years of angst and conflict I have run,
Though now in worthless solace I'm confined.
Replaced as some machine whose task is done,
An obsolescent prisoner of time.
I stare through frozen windows in self doubt,
Wondering if it's colder in or out.

The books I wrote a little later in college were actually published and you'll find them on Amazon.

Other than my own works, I can highly recommend these books as great reads.

Wednesday, October 21, 2009

National eHealth Collaborative Forums

I'm posting this on behalf of the National eHealth Collaborative.

Please join the National eHealth Collaborative (NeHC) Board of Directors as it hosts a series of interactive discussions with experts and stakeholders on important and timely topics in health information technology.

Bedside to Bench: How Health IT Can Power Better Clinical Research
NeHC Board Member Stephen Ruberg, PhD will talk with a panel of experts about how interoperable electronic health records and other technology tools can significantly improve the quality and efficiency of clinical research. The discussion will cover a number of perspectives in this area, from clinical trials and drug surveillance to government-funded research to cure chronic disease.

The Backbone of the Healthcare System: Nurses� Critical Role in Health IT Implementation
NeHC Federal Liaison Linda Fischetti, RN will lead a discussion among national nurse leaders about how including nurses in health IT implementation projects can mean the difference between success and failure. Panelists will bring a wide variety of perspectives gleaned from years of experience in improving the quality of patient-centered care through the use of health IT.

WHERE: Sheraton Crystal City
1800 Jefferson Davis Highway
Arlington, VA 22202
Metro Stop: Crystal City

WHEN: Wednesday, October 21, 2009
9:00 am � 12:30 pm ET

9:10 � 10:40 am: Bedside to Bench: How Health IT Can Power Better Clinical Research

10:50 am � 12:20 pm: The Backbone of the Healthcare System: Nurses� Critical Role in Health IT Implementation

WHO: National eHealth Collaborative Board of Directors
Chair: John Tooker, MD, MBA � Executive Vice President and Chief Executive Officer, American College of Physicians

Bedside to Bench: How Health IT Can Power Better Clinical Research
Moderator: Stephen Ruberg, PhD � NeHC Board Member and Senior Research Fellow, Eli Lilly & Company
Panelists:
� Gregory Downing, DO, PhD � Director, Personalized Health Care Initiative, U.S. Department of Health and Human Services
� Daniel Ford, MD, MPH � Vice Dean of Clinical Investigation, Johns Hopkins University
� Stephen Ruberg, PhD � NeHC Board Member and Senior Research Fellow, Eli Lilly & Company
� Steve Schwartz � Senior Vice President, Corporate Business Development, Allscripts

The Backbone of the Healthcare System: Nurses� Critical Role in Health IT Implementation
Moderator: Linda Fischetti, RN, MS � NeHC Federal Liaison and Chief Health Informatics Officer, U.S. Department of Veterans Affairs
Panelists:
� Victoria Bradley, DNP, RN � Chief Nursing Informatics Officer, Eclipsys Corporation (Representing American Nursing Informatics Association and CARING)
� Curtis Dikes, RN, MSN, ACNP-BC � National Director, Clinical Informatics Technology Integration, Kaiser Permanente Foundation Hospitals
� Rosemary Kennedy, RN, MBA, FAAN � Senior Director, Nursing and Healthcare Informatics, National Quality Forum
� Joyce Sensmeier, MS, RN-BC � Vice President, Informatics, HIMSS (Representing Alliance for Nursing Informatics)

VISUALS: Recorded video, webinar and presentation slides will be available live and on the NeHC website (www.nationalehealth.org) following the event.

Webinar: https://nationalehealthevents.webex.com/nationalehealthevents/onstage/g.php?d=669279178&t=a

Audioconference: (866) 699-3239 or (408) 792-6300
(Please join the event with a computer system first and follow the audio instructions on the screen.)
Access/Event Code: 669 279 178
Attendee ID: You will receive this number when you join the event first with a computer connection.

Streaming Video: http://www.freedocast.com/nationalehealth

My conflicts of interest - FY10 edition

Every year I publish my conflicts of interest publicly, such 2008 and 2009

It's that time again.

My salary is paid by Beth Israel Deaconess Medical Center for my duties as CIO.

BIDMC invoices Harvard Medical School for the time I spend there.

In 2009, NEHEN and MA-Share merged, so my only position in state-level healthcare IT is Chair of NEHEN, an unpaid position with no benefits/authority/special treatment of any kind.

I will serve as the chair of HITSP until January 31, 2010 when my term expires. For the past 4 years of HITSP service, I have not received any compensation or benefits. My plane flights to Washington have been reimbursed at cost.

I will serve at the vice-chair of the HIT Standards Committee for as long as it suits ONC and the Committee. I will not receive any compensation or benefits.

In the past I have served on many Boards and advisory panels. Knowing that ARRA would completely consume my free time at BIDMC, NEHEN, and the Federal standards committees, I resigned from all Boards and advisory panels except one - AnvitaHealth, a decision support service provider. The only reason I continue to serve on this Board is because I so strongly believe in their work which normalizes disparate data streams from clinical and administrative sources then provides real time decision support to clinicians at the point of care and to administrative decision makers. All this is done via a web-services architecture. I wish more companies provided Software as a Service decision support via web services that could be easily plugged into existing applications without significant IT effort. I have received a grant of options, none of which I have executed. Thus, I receive no compensation and have no stock ownership in the company.

With regard to other stocks I own, I established a family trust in 1993 and all my investments are managed by a third party. I do not directly control these investments, nor track their day to day variation. I do not make any business decisions in any of my professional roles based on stocks held by the trust. On a day to day basis I do not even know what stocks are in the trust, although I have suggested that healthcare IT stocks be avoided to eliminate even the appearance of a conflict of interest. I checked this morning and the trust has no healthcare IT holdings.

That's it - in 2010, I will receive a BIDMC W2 and a series of travel reimbursements at cost - nothing more. Should there be any other income that I cannot yet forecast, I will donate it to BIDMC/Harvard for the benefit of my employees as I have done in the past.

Flu Vaccine for Egg Allergic?

The Food Allergy Asssistant received many comments on the post related to HINI vaccine and egg allergy. There is much confusion and alarm for our children with egg allergies who are affected by the egg-based method for making flu vaccine. I've done more research and this is what I found:

There is much interest in a cell-based flu vaccine that would be safe for those with egg allergy.The technology currently used to make our chicken egg-based flu vaccine is over 50 years old.The new technology is animal cell based, rather than egg based. This process could save weeks in manufacture time and is less likely to become contaminated.

One company, Novartis, is close. They are building a plant in Holly Springs, NC with hopes of completion in 2010 or 2011. Novartis clinical trials of a cell based flu vaccine in the U.K. have been successful. The Wall Street Journal reports possible U.S. shipment of cell-based swine flu vaccine in December or January.

Let's keep in touch. We may be able to get cell-based flu vaccine this season. My hope would be that it goes to allergist offices first...

Check out this NY Times article regarding cell-based flu vaccine.

Tuesday, October 20, 2009

Gisborne Fimmaker Finalist In Los Angeles film festival


From http://www.infonews.co.nz/news.cfm?l=1&t=72&id=43589
FILM 20 October 2009, 1:18PM
Gisborne Filmmaker Finalist In Los Angeles Film Festival
By Adage Business & Media Services


GISBORNE

Gisborne Filmmaker, Polly Green�s latest film Soft Power Health, a short documentary film about professional kayaker Dr. Jessie Stone�s humanitarian aid efforts in Uganda, has just been announced as a finalist in the My Hero Short Film Festival in Los Angeles, and is up for the Dan Eldon Activist Award.

Three years after the debut of her first short film, Nomads, filmmaker Polly Green returned to Uganda to follow the progress of Soft Power Health, the non-profit organization started by kayaker/doctor Jessie Stone. While Nomads profiled three women kayakers each with a different passion to help others, Green�s new film, aptly called Soft Power Health, explores in depth what Soft Power Health does today.

Green has cleverly integrated paddling shots and Nile river views throughout the film, but the focus is on the organizations work on land. Picking up where Nomads left off, Green shows the Soft Power Health clinic and several health outreach programs, including the incredible progress of the first one that Dr. Stone started, the malaria education and prevention program. With the rapid construction of the Silverback Dam on the Nile river, Green captures beautiful shots of what will soon be gone, something that all of us will be grateful to have forever.

Polly completed the film in June and is �ecstatic to be a finalist in The My Hero Festival�.

�My passion is telling stories about people doing positive things � says Polly, and The My Hero festival is the perfect platform to showcase films that honor heroes from around the world.

Polly is passionate about making inspiring films that leave the viewer feeling empowered, and telling stories about people who are doing positive things in the world.

Polly, a permanent New Zealand Resident, moved to Gisborne in 2007, because � I love it here, Gisborne is a beautiful and inspiring place that feeds my soul.�

Her next film is about Maori carvers of the East Coast.

She plans on attending the Los Angeles festival and has her fingers crossed that the film wins.

What keeps me up at night - FY10 edition

Life as a CIO is never boring.

In Sunday's Boston Globe, Microsoft CEO Steve Ballmer said �What�s the old movie line from �Annie Hall�? Relationships are like sharks; they move forward, or they die. Well, technology companies either move forward, too, or they die. They become less relevant.�

No matter what an IT organization has accomplished in the past, what matters is daily infrastructure performance and the ability to constantly improve applications. I call this problem "changing the wings on 747 while its flying". Rapid change and complete stability must be achieved at the same time.

Here are the change management issues keeping me up at night in my various organizations.

BIDMC

Intranet - we're introducing a new intranet organized around social media concepts : tag clouds, blogs, and new media. Creating the security infrastructure to provide data confidentiality while at the same time encouraging use of social media anywhere on any browser is a delicate balance. We're looking at several new security appliances to help with this effort and I'll share the details in a future blog. Also, changing an intranet is one of the hardest projects that an institution can do, since so many people use it for their work every day. Even if the change is for the better, it's still a change. Balancing new functionality with ease of use and rapid adoption is challenging.

Enterprise Image Management - as storage needs increase and image exchange becomes a requirement throughout the organization and with our business associates, IT is becoming the focal point for image storage and life cycle management of all modalities. The days of local DVDs and departmental storage are gone. Using a combination of EMC products, IT is hosting short term cache, long term archiving, backup, and disaster recovery. Our projects over the next year will serve radiology, cardiology, and likely several other ologies that are seeking assistance. The challenge is building an infrastructure that is scalable, affordable and maintainable. We're using cutting edge products and technologies. There is always risk in implementing a new service based on highly innovative products.

EHR rollouts for meaningful use - I've described our EHR rollout efforts in several previous blogs, which are summarized in this document. We've solved the technology issues, but motivating clinicians to rapidly adopt EHRs is hard. Stimulus dollars help, but sometimes they are not enough, such as for specialists or "concierge medicine" PCPs. As a leadership team, the EHR steering committee needs to provide carrots and sticks to stimulate change.

Business Intelligence - I've written about the need to look beyond data and find information, knowledge and wisdom. We need to provide our stakeholders with innovative access to knowledge in our clinical and administrative systems using tools that are self service and do not require programming/IT expertise. The challenge is how to enable tools that anyone can use without requiring expert knowledge of the data itself - how it was gathered, who entered it, how accurate it is etc.

Interoperability - BIDMC strives to be one of the most interconnected healthcare organizations in the country. We have new projects that ensure we achieve meaningful use data exchanges in 2011 and beyond such as a exchanging quality metrics with the Massachusetts eHealth Collaborative Quality Data Center, exchanging clinical summaries with community EHRs, and enhancing our public health reporting using HITSP standards, all with the NEHEN gateway. This effort requires that we adopt new standards, enforce controlled vocabularies as the data is entered and appropriately address privacy/security concerns for data moving between organizations.


Harvard Medical School

High Performance Computing - The demand for computing is increasing exponentially and our challenge is not real estate but power/cooling. Over the next year, we need to substantially increase our electrical capacity and we're considering many options including a data center near hydroelectric power.

Storage - the research community at Harvard Medical School demands high performance, highly reliable storage at a low price. We've been able to offer high quality NAS with replication, attached to our high performance computing cluster for .67/gigabyte per year. Our challenge is to keep up with demand, always ensuring we have enough storage, but not over provisioning.

Content Management - Last year, I worked with BIDMC Corporate Communications to move BIDMC's web content to a commercial content management system with delegated content management. In FY10, we'll need to do the same with Harvard medical school including administrative websites, research websites, and departmental content. The stakeholders at Harvard Medical School are very diverse so the challenge will be selecting an information architecture and navigation approach that works for everyone.

Social Networking for research - Over the past year, we've worked as part of the Clinical and Translational Science Awards (CTSA) to build transparent access to researchers with active and passive social networking techniques. Expanding this work requires that we build trust among all our collaborating institutions and encourage transparency with the sharing of personal intellectual property. The more you share about your thinking, the better the social networking.

Governance - I'm a strong believer in IT governance. At HMS, I've always had good input from research, administrative, and educational stakeholders but this year I've worked with the Administrative Dean to launch an overall IT Governance Committee to ensure the needs of all stakeholders are balanced. Governance takes a great deal of time and energy, but it does mitigate surprises such as delayed projects, budget variances, and misaligned priorities.


NEHEN/State activities - The Office of the National Coordinator is distributing $600 million in Federal funds for health information exchange. In my role as chair of NEHEN, I want to be sure our state has a good strategic plan and stakeholder alignment to create health information exchange in support of meaningful use goals. As with many of my other projects, this work requires a huge commitment to governance and working with highly innovative technologies and emerging standards. It's all high risk.


HITSP/HITSC/Federal activities - The Standards Harmonization work at HITSP and the Implementation/Adoption work at the Healthcare IT Standards Committee requires constant communication, balancing of stakeholder interests, and embracing innovation. Like any Washington task, achieving consensus among all the various points of view requires patience, an open mind, and a steady hand. I'm learning every day how best to serve the country as a facilitator and communicator. The task is never easy.


Personal - On the personal side, my daughter is 16 and we've begun college planning. Applying to college these days is much different than in my youth. I'm convinced that if I applied now to the schools I attended (Stanford, UCSF, UC Berkeley, UCLA, Harvard, and MIT), I would not be admitted!

My parents recently retired and we helped move them to a new house where the living is easy and maintenance free. My wife and I have begun to think about our retirement 20 years from now.

My 2009 work schedule has reduced my outdoor activities a bit, so I've had less climbing and hiking opportunities. This winter, I'm committed to getting back on trail in the 4000 footers of New Hampshire

My flute playing has taken a backseat to Washington travel. This winter I'm committed to playing the Japanese flute at least 3 times per week.


Thus, overall my challenges are keeping customers happy, managing the risks of change, embracing innovation, and keeping my family/personal life balanced with a worklife that has no downtime.

That's what keeps me awake a night. It's a lifestyle, not a job, and I enjoy every minute.

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