Chief Information Officer: The Healthcare CIO— Observations from an Organizational Perspective

1. Volume 25, Number 1 / wiNter 2011 A HIMSS Publication
FOCUS Health Information Exchange:
Case Studies in Interoperability
and Integration
PLUS: n Clinical Summaries and Meaningful Use
n Implementing Front-End Speech Recognition
at an Academic Medical Center

3. Volume 25, Number 1 / wiNter 2011 A HIMSS Publication
Commentary 40 States Adopt a Patient-Centric View for Greater
Interoperability and Information Sharing: New Mexico
5 Editor’s Report: Building a Statewide Network— Prepares an HIE for Statewide Connectivity and Beyond
One HIE at a Time Dave Perry; Chad Cosper; and Penny Schlyer
Richard D. Lang, EdD In 2004, Lovelace Clinic Foundation (now DBA LCF Research) created the New Mexico
Health Information Collaborative (NMHIC). NMHIC’s goal was to establish a framework for
9 The HIT Futurist: Beyond HITECH— health information exchange (HIE) that could be extended to the rest of the state.
Can We Afford to Be Paperless? Since then, NMHIC has assembled a diverse group of stakeholders—technology partners,
Jeffrey C. Bauer, PhD healthcare organizations and state agencies—to develop a governance model that will
allow all healthcare communities to engage in HIE.
11 Technology: The Socially Responsible HIE—
Finding the Optimal Mix of Service and Sustainability 44 HIE Provider Verification:
Rick Krohn, MA, MAS The Privacy and Security Elephant in the Room
Michael L. Nelson, DPM
14 Nursing Informatics: Trends in the Delivery of Nursing The Federal Health Information Technology Strategy for Privacy and Security requires
Care—What Impact Will Technology Have? that HIEs improve privacy and security protections for health information and prevent
Judy Murphy, RN, FACMI, FHIMSS unauthorized or inappropriate access. An “identity ecosystem” places such a burden
on each stakeholder within an HIE as part of a “fabric of trust.” However, hospitals
16 Funding: Beyond Meaningful Use— and health plans only check a provider’s credentials every two to three years, and
Securing Funding for Your Health IT Project unfamiliar providers may request HIE access remotely. Trust is only reliable across small
Edna Boone communities. As HIEs expand and interconnect across regions and states, the fabric of
trust is stretched to the point of tearing. To avoid inappropriate access to PHI by a provider
18 Legislation: HIPAA/HITECH Business Associates— with questionable credentials and/or professional sanctions, an HIE should put in place
Expanded Scope of Responsibilities and Liabilities a master provider index (MPI) which crosswalks provider data across all 50 states and
which continually aggregates primary sourced provider data from state license boards,
Susan A. Miller, JD, and Gerry Blass
the DEA, SSA and the OIG as part of a consolidated provider “golden record” which is
20 Vendors: Health IT ROI— accessible in real-time through a Web service.
Protect Your Health IT Investment and Save Money 48 Factors Shaping Sustainability and Value
Bob Doe Gary W. Ozanich, PhD; Karen Chrisman, JD, MA; Rosmond Jones
22 Chief Information Officer: The Healthcare CIO— Dolen, JD; Martha Cornwell Riddell, Dr PH; and Laura Cole, MBA
Observations from an Organizational Perspective The Office of the National Coordinator for HIT provided funding for the initial development of
state HIEs. However, these grants require strategic and operational plans that must include
Jack Hueter economic sustainability. This study suggests a stakeholder segmentation, identification of
25 Meaningful Use: Transforming Healthcare Delivery— value propositions and potential value equations for stakeholder groups, and develops them
within the context of economic, regulatory, and privacy and security barriers faced by HIEs.
Meaningful Use of Technologies
Alexandra Mustafaraj
Features
FoCus: HealtH InFormatIon exCHange: 56 Technology: Speaking Clearly—Implementing Front-End
Case studIes In InteroperabIlIty Speech Recognition at an Academic Medical Center
and IntegratIon By Jason H. Pitzen, MBA, PMP; Christopher M. Grebin, BS;
Linda C. O’Connell, MBA; and W. Mark Brutinel, MD
28 Jersey Health Connect: The efficacy of front-end speech recognition technology in a healthcare setting has been
A Collaborative Framework of Community Stakeholders the subject of much debate. With early speech recognition software producing incoherent
Linda Reed, RN, MBA; Judy Comitto; and Craig Edwards and sometimes embarrassing script, the world waited for much needed breakthroughs in
As the number of HIEs grows nationwide, economic stimulus opportunities will drive reliability. With the recent economic meltdown as well as heightened public scrutiny of the
cooperation between providers. However, forging multi-stakeholder consensus to cost of healthcare, speech recognition gained attention for its potential as a significant cost-
achieve true continuity of care demands a revolution. To ensure success, providers saving device. This article will explore the implementation of front-end speech recognition
must embrace the belief that HIE is a public good and that coming together will result software with a pilot group of internal medicine providers at Mayo Clinic in Rochester, MN.
in better community care. This action compels a dramatic departure from the traditional In addition to providing experiences on managing the implementation and challenges faced,
business model of competition to a model of collaboration in which all members accede to the article will offer data on provider adoption and satisfaction as well as comments on the
transparency and put the patient first. feasibility of increased utilization of front end speech recognition in healthcare.
34 How to Hit a Moving Target 62 Clinical Documentation: Clinical Summaries and
George M. Brenckle, PhD, and Richard Cramer Meaningful Use—A Primer
Interoperability and health information exchange are areas of significant focus and growing Noam H. Arzt, PhD, FHIMSS
importance to hospitals, health systems, payers and vendors. They also are part of a This paper will provide a solid foundation of the history, nature and context of clinical
rapidly evolving problem domain where waiting for either requirements to stop changing or summaries. First, the author will discuss why clinical documents are important, including
someone else to solve the problem is only an excuse to move slowly, leaving organizations the business case for their use and the specific meaningful use requirements for clinical
lagging behind others who are willing to take a more proactive approach. Our approach summaries. Next, the author will review the current context for using clinical summaries,
has been to get started irrespective of the uncertainty and put in place a flexible platform including basic attributes of the two major clinical summary standards (CCD and CCR), as
that can meet both immediate needs, yet adapt and expand in response to the inevitable well as their roles in NHIN Exchange and NHIN Direct. Finally, the author will review barriers to
changes in requirements, data standards, business partners or technology solutions. using clinical documents effectively and will offer some steps to help overcome these barriers.

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edItor’s report Richard D. Lang, EdD
The HIE Critical
Success Proposal
Building a Statewide Network—One HIE at a Time
A
ccording to Metcalfe’s law, for every node added unless states push a federated approach.
In an HIE, value starts with the pri-
to the network, the value of that network increases mary care physician (PCP). And you bet-
ter believe that these doctors know it. So
exponentially. If this axiom holds true for HIEs, if PCPs are required to pay a subscription
they should flourish with each new provider/subscriber. fee to join a statewide HIE, when they
know that they are the ones who provide
In the 1990s CHINs failed primarily due needed to get up and running on a certi- the most sought after information and the
to the lack of value (translation: low mem- fied EHR. making connecting to a statewide data they need the most in return is pro-
bership). RHIOs are currently struggling HIE low on the priority scale and more vided by the hospital and a limited group of
for the same reason. But what does it take importantly ability threshold for the next local specialists, where is the incentive for
to entice members to join an HIE Mandated three to five years. Furthermore, it remains participating in a statewide HIE? A typi-
membership may not be feasible—and cer- to be seen if fledgling REC centers will have cal response from a PCP (already using an
tainly will not be popular. enough funds and staff to help each prac- EHR and community HIE) to a statewide
The key question: How do you get pro- tice select, install and maintain an EHR in HIE representative might go like this: “So
viders to willingly connect to an HIE and the required timeframe. let me get this straight: I provide all of the
pay for all of the required integration devel- Nevertheless, states are planning to key information on my practice’s patients
opment to maintain a real-time, bi-direc- receive stimulus funds under the State that the statewide HIE needs, and in return,
tional link between their practices’ EHRs Health Information Exchange Coopera- I may get some results and medication
and the HIE? And then, turn around and tive Agreement Program to build HIEs. updates from an occasional out-of-network
charge each provider a subscription fee so The concept is sound in that some form of referral … and I get to pay a monthly fee,
that the network is financially sustainable? a statewide HIE will be necessary if we are too! Where do I sign?!”
You better offer some tangible value! Value to achieve NHIN objectives. A more practical idea may be for states to
that helps physicians provide better, safer However, a top-down approach may not support local community HIE development
care. Value that helps providers reduce cost be viable. Centralizing a statewide HIE in first. Once established, these local networks
and improve workflow, and not just ben- a hierarchical model may be unsustainable can feed regional HIEs and then connect
efits insurance companies. from a financial standpoint. Point-to-point to a central HIE/data repository backbone.
Somehow, I don’t believe statewide HIEs connections between the state network States should use a portion of the stimulus
alone can provide this type of value. Why? and individual practices, hospitals and funds to support local HIE development;
Because, like politics and economics, the other providers will be nearly impossible encouraging hospitals or physician/hos-
majority of issues that affect healthcare are to achieve in a reasonable timeframe and pital organizations (PHO) to co-sponsor a
local. A large percentage of community and expensive to establish and maintain. Most local EHR/HIE project connecting the hos-
rural healthcare providers are either elec- states will attempt to expedite the HIE roll- pital with community physicians. Now the
tronically disconnected or paper-based. In out by leveraging existing integration with value proposition becomes clearer.
addition, providers that are contemplating functional RHIOs, large health systems and First, physicians need a base set of data
EHR selection and implementation so they hospitals (see Reed, et al.). But, once the to share among themselves that is consid-
can receive meaningful use incentives are existing HIEs are connected—the incentive ered “key” in terms of clinical value. These
wondering if they’ll have the resources for more local HIE development will wane key data elements have been defined in the

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EditOr’S rEPOrt: ThE hIE CRITICAl SUCCESS PRoPoSAl
ONCE THE LOCAL HIE IS IN PLACE, the
statewide HIE can now pull it all together.
This is the beauty of a federated approach.
meaningful use final rule as problems, pro- to each specific specialty. lists—ultimately providing more available
cedures, medications, allergies, test results, In any event, PCPs will pressure special- time for patient examination and counsel.
discharge summaries, etc. There are two ists to join the EHR/HIE world quickly. Further, physicians can view all prob-
primary sources for a large percentage Once PCPs are automated, they can no lems and results that have been docu-
of these data: community physicians and longer afford to print out specialist referral mented by other local caregivers on the
hospitals. The value of a local community- packets to send with patients. They want HIE providing a complete set of informa-
based HIE starts to take form when these to gain the workflow benefits and savings tion for a more accurate and timely diagno-
two sources are connected first. that an HIE e-referral process brings, and sis. Therapeutic actions can be targeted for
To get started, redistribute grants from will have a low tolerance for specialists who focused problem resolution because physi-
existing stimulus funds down to the local continue to cling to traditional paper-based cians spend less time investigating known
level to help hospitals implement and medicine. Specialist adoption may be expe- or resolved problems. Finally, since the HIE
finance EHRs for affiliated medical staff dited further when there is more than one is designed on a community level, local sup-
to ensure that community physicians are in-network referral option for the PCP. No port teams ensure that shared HIE data ele-
actively using EHRs before the HIE is specialty practice wants to be the last one ments flow naturally to and from each indi-
introduced. Hospitals could then entice on board for fear of losing business. vidual EHR. Consequently, HIE records are
primary care practices to participate in Now value in the form of improved seamlessly integrated with other EHR data
the HIE initially by providing integration workflow and care is considerable. A local removing the need for physicians and staff
with hospital documents, results and third- healthcare data repository that enables to check a portal or other source for needed
party lab providers. Now, the HIE value is providers to exchange patient data securely information.
real. Primary care docs don’t mind entering in a community setting with other health- Once the local HIE is in place, the state-
med lists, allergies, problems, etc. because care providers is operational. Connected wide HIE can now pull it all together. This
1.) it improves their new EHR workflow; community providers and practices with is the beauty of a federated approach. It
2.) they got a great deal on the EHR with disparate systems can now share data with starts with a bottom-up philosophy where
the HITECH/hospital provided subsidy the hospital and other providers along the value is proportionate to proximity. Now
and subsequent “local” system support; care continuum. A longitudinal patient interconnectivity is simpler. The statewide
and 3.) the needed integration with clini- record begins to develop at a community HIE no longer needs to plan for thousands
cal data is provided seamlessly within the level that improves patient safety, quality of of one-off connections.
EHR via the local HIE. Workflow and care care and communication among providers, Under a federated model, a statewide
are measurably improved. while at the same time, streamlining refer- HIE connects to regional or district HIE
Next step, specialists. Some specialists rals and patient follow-through. Reduced hubs that connect the local/community
may be laggards in both EHR adoption and risk and liability are achieved through an networks already established. This model
HIE participation. For instance, specialists automatic data exchange that eliminates offers a number of advantages. First, it
take great pride in the letter that they write errors which can occur when information requires a smaller labor/resource footprint
back to the referring PCP reporting their is transferred manually or re-keyed into at the state level because most of the con-
findings, diagnosis and course of action. different systems. nectivity and HIE support and manage-
EHRs have a tendency to mechanize this For instance, a complete medication ment occurs locally.
“art form” with the point-and-click tem- list for each patient on the local HIE can Second, growth would be achieved
plate-based reconstruction of the special- contribute to a marked reduction of drug naturally since value is more apparent
ist’s examination and impression. Thus, interactions resulting in safer care, and for local, community-based practitioners.
many of the successful EHRs that are at the same time, decrease the amount of Third, security is much more manageable
adopted by specialists are designed pri- time a community physician or specialist because a majority of the record sharing
marily to provide clinical content relevant will need to spend reconciling multiple occurs locally. This makes data access,

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EditOr’S rEPOrt: ThE hIE CRITICAl SUCCESS PRoPoSAl
Journal of Healthcare Information Management®
(ISSN 1943-734X) is published quarterly by the
healthcare Information and Management Systems
Society (hIMSS). Subscription to this publication is
a benefit of membership in hIMSS.
Statements and opinions appearing in articles and
departments of the journal are those of the authors
and do not necessarily reflect the position of
hIMSS. Canadian Agreement #40648621.
Copyright© 2011 by the healthcare Information
and Management Systems Society.
All rights reserved. No part of this publication
may be reproduced, stored in a retrieval system,
or transmitted, in any form or by any means,
electronic, mechanical, photocopying, recording,
credentialing, consent management and Centric View For Greater Interoperability or otherwise, without prior written permission.
Please contact: hIMSS Publications, 230 E. ohio
record transfers easier to trace, audit and Information Sharing: New Mexico Pre- St. Suite 500, Chicago, Il 60611; (312) 915-9282;
and monitor for clinical appropriateness. pares an HIE for State-Wide Connectivity mschlossberg@himss.org.
Moreover, subscription metering for HIE and Beyond; Interoperability – How to Hit a “HIMSS,” “Healthcare Information and
membership fees can be easily measured Moving Target; and HIE Provider Verifica- Management Systems Society,” “Journal of
at each level, giving states more flexibility tion – The Privacy and Security Elephant Healthcare Information Management,” and the
with regard to financial remuneration to in the Room. These contributions and case hIMSS symbol are registered trademarks.
ensure sustainability. studies provide useful knowledge and NOtE: Starting with volume 16, number 1, each
Finally, this model will allow statewide strategies as we plan for HIE proliferation, volume of Journal of Healthcare Information
Management® begins with the Winter issue.
HIEs to focus on building a network that interconnectivity and a national healthcare
truly adds value for local/regional HIEs. information network. U.S. SUBSCriPtiONS cost $69.00 for individuals
and $104.00 for institutions, agencies, and
For example, the statewide HIE could In addition, special-interest columns and libraries. Standing orders are accepted. There
help local networks access common data articles provide valuable information and is no sales tax on U.S. subscriptions. Canadian
sources such as commercial labs, phar- insight on the following topics: residents, add GST and any local taxes.
macies, public health data banks and Beyond HITECH: Can We Afford to be iNtErNAtiONAL SUBSCriPtiONS cost
record-locating services. For the most Paperless?; The Healthcare CIO; Trends in $109 for individuals and $144 for institutions.
part, these data sources are centralized the Delivery of Nursing Care: What Impact SiNGLE COPiES cost $26.00 plus shipping (see
and the statewide HIE could provide the Will Technology Have?; Transforming below). Please include appropriate sales tax for
local HIEs a great service by establishing Healthcare Delivery: The Journey; Protect your state. Canadian residents, add GST and any
local taxes. Prepayment is required.
a primary link to each of these entities Your HIT Investment and Save Money; The
providing one-stop-shopping for access Socially Responsible HIE; and HIPAA / SHiPPiNG (Single Copies only): $30.00 and under,
add $5.50; to $50.00, add $6.50; to $75.00,
to these critical data sources. HITECH Business Associates: Expanded
add $8.00; to $100.00, add $10.00; to $150.00,
The antithesis of the traditional pater- Scope of Responsibilities and Liabilities. add $12.00.
nalistic government model is giving control Finally, I would like to thank the profes-
tO OrdEr subscriptions or single issues,
back to the local communities. Neverthe- sional staff at HIMSS, the peer reviewers please contact Journal of Healthcare Information
less, a monolithic and centralized statewide and the editorial review board for all the Management, P.o. Box 9369, lowell, MA 01853,
HIE is a recipe for failure. For the sake of behind-the-scenes work that goes into pro- 978/256-6490, 978/256-1703 (fax),
cs-jhim@e-circ.net.
HIE growth, proliferation and sustainabil- ducing each issue. JHIM continues to look
ity, a true value-added partnership between for new ways to provide relevant, impor- EditOriAL QUEStiONS ANd PErMiSSiON
rEQUEStS should be directed to
states and local clinical networks is an idea tant and useful information for healthcare
Matt Schlossberg, Manager, hIMSS Publications,
that has great promise. Tangible value. professionals, academicians and HIMSS 230 East ohio Street, Suite 500, Chicago, Il
Exponential growth. Metcalfe’s law proven. members. jHIm 60611, (312) 915-9282, (312) 915-9288 (fax),
mschlossberg@himss.org.
T
he winter 2011 issue of JHIM Richard D. Lang, EdD, is iNtErACtiVE AdVErtiSiNG ANd rEPriNtS
contains an assorted collection Editor of JHIM and Vice For interactive advertising opportunities, contact
Julia Caron, MedTech Media, (207) 688-6270 x237
of special-interest columns and President and CIO for
at julia.caron@media.com. For reprints, contact
articles that focus on HIEs, Doylestown (Pa.) Hospital. Beth Black, at beth.black@medtechmedia.com.
interoperability and integration. These
AddrESS CHANGES should be sent to
articles include: Factors Shaping Sustain- healthcare Information and Management
ability and Value; Jersey Health Connect: Systems Society, 230 E. ohio St., Suite 500,
A Collaborative Framework of Commu- Chicago, Il 60611.
nity Stakeholders; States Adopt a Patient- Printed in the United States of America.

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tHe H.I.t. FuturIst Jeffrey C. bauer, PhD
Beyond HITECH
Can We Afford to Be Paperless?
d
igital transformation of healthcare gets a lot of with paper patient records and Hospital B
with EHR can be substituted for Country
well-deserved attention these days. The significant A with lots of workers and Country B with
lots of capital.)
virtues of EHRs are touted in trade press articles I have observed just about every produc-
about meaningful use and in general media reports on health tion process of healthcare delivery in my
40 years as a medical economist and health
reform. Many stories also describe the benefits of CPOE and services researcher, and I am confident that
paper has a comparative advantage in some
e-prescribing. Indeed, of all the health laws enacted over the stages of production. For example, I believe
past two years, HITECH is the only one that enjoys bipar- that paper-based forms have a comparative
advantage for gathering information from
tisan support. Republicans and Democrats of all political most patients. Entering all data directly
into a medical record via keyboard or touch
persuasions still agree that electronic information systems screen is absolutely the ideal approach, but
are prerequisites for reducing costs and improving quality. comparatively, the cost of gathering some
critical data (e.g., patient background infor-
The imminent disappearance of paper meaning it is less expensive than any alter- mation collected at the front desk, history
records is implied, if not actually predicted, native. I am not aware of any health sector and physical observations recorded in the
in stories about the benefits of health IT. studies that have compared the costs of exam room) is less when an appropriate
This conclusion is likely wrong for several completely paper-based systems with 100 paper form is used.
reasons. Indeed, rushed or incomplete percent digital information systems, but I
efforts to abandon paper help explain the would not be surprised if a good study were the information problem
failure of many EHR implementations. The to suggest that all-digital processes have Most patients and caregivers can fill in a
appropriate roles of paper and electronic an absolute cost advantage over processes blank or check a box on a structured paper
records merit careful study before the digi- using only paper-based information—all form with greater speed and accuracy than
tal revolution is pushed too far or too fast other things being equal. However, we they can provide the same information via a
in healthcare. economists know that all other things are digital interface. Perhaps more importantly,
After all, the foundation of health reform almost never equal. writing on paper does not degrade the per-
ought to be efficient and effective informa- The process with an absolute cost advan- sonal interaction necessary for productive
tion systems—a goal which is not necessari- tage is not necessarily the optimal choice patient-clinician encounters. Conversely,
ly paperless. We cannot improve healthcare for all stages of production if another several studies suggest that the use of a
without a dramatic increase in the digitiza- method has lower opportunity costs, computer during patient visits tends to
tion of data and information management, meaning that the alternative is relatively reduce the quality of personal interaction
but paper still has a valuable role to play in less expensive for one or more steps in the for all but the most tech-savvy participants.
the foreseeable future. overall production process. Economists Another essential stage in the overall
since Adam Smith have shown how global process of providing consistently good
Comparative advantages of paper output can be optimized when steps in medical services—analyzing all histori-
We economists make an important distinc- the production process are selected on the cal and current information for a patient
tion between absolute and comparative basis of comparative advantage. (Don’t be in order to make the correct diagnosis
advantages in the production of goods and surprised if you learned this concept in and prescribe the best therapy—is argu-
services. One production process can be the context of international trade and The ably impossible if some data exist only on
better than all others in an absolute sense, Wealth of Nations. Analytically, Hospital A paper (e.g., those records generated at the

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tHE H.i.t. FUtUriSt: BEyoNd hITECh
THE FOuNDATION OF HEALTH REFORM
ought to be efficient and effective
information systems—a goal which is
not necessarily paperless.
front desk and in the exam room). Indeed, focus on digital records and the corre- improve quality of medical services in the
I do not believe that optimal clinical deci- sponding rush to paperless healthcare. United States. Our reform discussion will
sions can be made until all relevant data are The keys to progress in the production be enriched when MFD joins EHR, CPOE,
compiled in a secure electronic file that can of medical services are networked, multi- eMAR and other acronyms popularized by
be viewed at any time by each practitioner function devices (MFD) that scan paper all those articles on HITECH and meaning-
involved in a patient’s care. Meaningful documents and their embedded or Web- ful use. Discussions of completely paper-
health reform without health IT, including services software that extracts necessary less healthcare will be unproductive for
a state-of-the-art EHR, is impossible in my information from the captured image and the foreseeable future. The more immedi-
future view. automatically distributes it to a digital file. ate challenge is to accelerate development
MFDs do a remarkable job managing the of intelligent interfaces between paper and
the interfaCe solution interface between paper and digital data electronic information systems. jHIm
Yes, I am paradoxically arguing for paper sources, from creating searchable PDFs to
records in some work tasks and for all- differentiating handwritten clinical obser- Jeffrey C. Bauer, PhD, a
digital data systems in others. Catch 22? vations (e.g., blood pressure readings, lab nationally recognized
No. Paper records are relatively better for test results) and then entering each datum medical economist and
collecting some data, and electronic records and its relevant time stamp in a compre- health futurist, is the
are absolutely necessary for analyzing all hensive electronic record. Chicago-based Vice
data. The good news is that proven, cost- These intelligent systems are common in President, Healthcare
effective technologies already exist to trans- other industries. The technology is ready Forecasting and Strategy for
fer paper-based information to digital files. to be developed for the healthcare indus- ACS, a Xerox Company. Visit
Unfortunately, the adoption of these tech- try. Having seen it work in Europe, I am www.jeffbauerphd.com or contact him at jeff.
nologies has not been part of the HITECH excited by its potential to reduce costs and bauer@acs-inc.com.
FinD youRs in oRLanDo, FEbRuaRy 20-24 at
Including your advertising in this targeted publication ensures
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workplaces, training, education programs and recruitment services,
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re S er VAt i o NS D ue JAN uA rY 28, 2011
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ej.fechenda@medtechmedia.com regina.dexter@medtechmedia.com
207.688.6270 ext. 221 603.204.0709

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systems and leadership/management.
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To learn about eligibility, registration and exam preparation, visit www.
CPHIMS.org – or contact Julianna Kazragys, Manager, Certification, at
certification@himss.org or call +1-312-915-9216.

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teCHnology Rick Krohn, ma, mas
The Socially
Responsible HIE
Finding the Optimal Mix of Service and Sustainability
The aim of the socially responsible HIE
QueStioN: What is the singular property that trans- is to provision a medical home for the
“super users” and underserved who con-
forms health information exchange (HIE) from sume a disproportionate share of health-
care resources, without necessarily receiv-
a “maybe” to a “must have” industry solution? ing adequate care. Everybody wins—the
ANSwer: A compelling mission whose clinical and hospital (which faces a lower burden of
uncompensated ER visits), the provider
economic value is widely acknowledged and mea- (who has a complete patient record to work
with) the patient (who receives consistent,
surably demonstrated. coordinated care) and the taxpayer (whose
tax burden for the services delivered to the
As a relatively immature industry, HIE is is defined by a formal charter of social uninsured is eased).
experimenting with a number of business responsibility to the community. The In every respect other than its client base,
and technology architectures in an effort “socially responsible” HIE is a healthcare the socially responsible HIE is structured
to find the optimal mix of service and sus- coalition that includes hospitals, federal- and behaves like any other HIE. It employs
tainability. ly qualified health centers, public health, the same tools—the EHR, the data reposi-
There is no single solution set, no secret social services, clinics, medical practices tory, the record locator service, and offers
sauce of sustainability. HIE is driven by and civic organizations. It’s a community the same functionality—clinical messaging,
environmental factors that are variable and of providers and advocates that extends test results, e-prescribing and CDS. Those
contain many moving parts. the reach of the HIE to entire populations technology tools are being provided by
There is, however, a problem set that of patients. HIE vendors with a commitment to social
HIE is uniquely positioned to address in But what does social responsibility mean responsibility.
any environment: the healthcare needs of in the context of HIE? First, it’s about intro- Unlike a typical HIE construct, the
the underserved and the uninsured. The ducing equal access to care, for those least mandate of the socially responsible HIE
problem: the underserved, including the likely to receive it—the poor, the shut-in, extends beyond clinical data sharing. For
homeless and the poor often have complex the homeless and the rural patient. It’s the underserved, it acts a clearinghouse
medical and social needs that the health- about care coordination, focused on the for services, such as mental health, social
care industry is poorly equipped to address medical home, the chronically ill, and services, correctional health, elderly care,
in a comprehensive way. population health. It’s about serving the and patient education. Its distribution net-
This highly mobile group of patients greatest good, by establishing earlier, more work is eclectic and includes social service
truly need a community approach to their effective, holistic interventions in the health agencies, neighborhood associations, cor-
healthcare needs, but providers are mainly issues of vulnerable patients. Finally, it’s rectional facilities, volunteer clinics and
focused on individual episodes of care. This about economic rationality—channeling churches. This inclusiveness at the com-
population, more than any other, can truly routine, often unreimbursed medical care munity level represents the truest applica-
benefit from the care coordination and from its most expensive venue, i.e., the tion of what HIE is meant to be.
medical home characteristics of HIE. emergency room, to more accessible, less So if the socially responsible HIE is a
The HIE that targets the underserved costly locations. win for the entire community, why isn’t

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tECHNOLOGy: ThE SoCIAlly RESPoNSIBlE hIE
every HIE structured in this way? First,
the volume of dissimilar stakeholders— AS A RELATIVELy IMMATuRE INDuSTRy,
among them public and private health,
the business community, local govern-
ment and social services—make the plan-
HIE is experimenting with a number of
ning and governance aspects a multi-year
prospect.
business and technology architectures
in an effort to find the optimal mix of
Second, the out-of-whack reimburse-
ment methodologies for both Medicare
and Medicaid make this, at most, a break-
even proposition for providers. Third, this
is a challenging patient population to man-
service and sustainability.
age—often mobile or distant, unwired,
without transportation and dispropor-
tionately unhealthy. Fourth, there isn’t firmly rooted in community. We‘ve estab- ChathamHealthLink intends to broaden
much incentive for commercial payers and lished a public/private partnership that is its base of users, in step with its fundamen-
their physician panels to climb on board, targeted directly to meet the healthcare tal mission—to serve the community. That’s
since their patients aren’t the primary needs of the underserved. Our immedi- going to require an incremental, measured
beneficiaries. Finally, the economics of ate aim is to create a medical home for our growth strategy, according to Paula Reyn-
the socially responsible HIE rest heavily lower income residents, and to move rou- olds, Executive Director of the HIE, “We’ve
upon grant funding. tine care from the emergency room into the learned that for ChathamHealthLink to be
Despite these obstacles HIEs tasked to exam room.” socially responsible, we must stay focused
impact vulnerable patient populations – Business leaders have also played a on the patient and the community, and not
the poor, the chronically ill, the uninsured pivotal role in promoting HIE. Gary Rost, be distracted by technology for technol-
and the homeless are growing organically Executive Director of the Savannah Busi- ogy’s sake. Building a healthcare coalition
around the country in cities like Camden, ness Group, explains. “The business com- takes a lot of time and a deep commitment—
Austin, Los Angeles, Memphis and Kan- munity [and particularly, self-insured it demands diligent self-assessment, an
sas City. One such story is unfolding in employers] view HIE from a population open mind and a clear vision.”
Savannah, GA where the newly launched health perspective. We recognize that the HIEs like ChathamHealthLink provide
ChathamHealthLink is addressing the benefits of HIE extend to better manage- a glimpse of where health information
related issues of cost, access and coordina- ment of chronic conditions, improved out- exchange should ultimately be headed,
tion of care for the underserved. Like so comes, the creation of accountable health growing beyond a limited circle of pro-
many other metropolitan areas in the U.S., organizations and the move to value based viders to include the larger universe of
Savannah’s healthcare system is straining payment for services.” services linked to population and com-
under the weight of caring for the poor in Operationally, the non-profit Savannah munity health. The socially responsible
its communities. HIE acts as a hybrid model that integrates HIE demonstrates that in spite of the
To address this need, in 2004 the Cha- with EHRs: fragmentation, the parochialism, and the
tham County Safety Net Planning Council For Patients. A longitudinal summary inefficiencies that plague our healthcare
(CCSNPC), a county-wide planning body medical record in the ChathamHealthLink system, HIE can be a force multiplier that
tasked with improving healthcare for the database, a reduction of paperwork, testing, yields a higher order of care to those who
uninsured and underinsured was formed. delays in appropriate care and a reduction need it—meaning all of us. jHIm
CCSNPC stakeholders included two hos- in medical errors.
pitals, MedBank, The Community Car- For Providers. Complete, secure, easily Rick Krohn is President of
diolovascular Council, The United Way, accessible electronic records, and commu- HealthSense, Inc., a
Step UP Step Savannah, three volunteer nication among providers through secure, consultancy specializing in
clinics and two Federally Qualified Health safe protected electronic portals with infor- healthcare strategic
Centers (FQHC). mation updates in real time. marketing, communications,
In 2005 the Council determined that For the Community. Unduplicated business development and
health information technology was key records and accurate counts of patients technology application. He can
to addressing gaps in care. Patty Lavely, served, the ability to follow trends in access be reached at 912-220-6563.
CIO of Savannah’s Memorial Hospital and and health outcomes, and a secure reposi-
Chair of the HIE IT Consortium, describes tory of patient records in case of emergency
the HIE decision. “Our approach to HIE is evacuation.

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nursIng InFormatICs Judy murphy, Rn, FaCmi, FHimss
Trends in the
Delivery of
Nursing Care
What Impact Will Technology Have?
A
few months ago, there was a posting on the HIMSS within their own organization, given on-
the-job training, and assigned to help with
Nursing Informatics listserv by Michael Kurliand, clinical IT projects. The result is nurses
leaving bedside nursing to work on IT
an NI specialist from the Children’s Hospital of projects within their own organization,
Philadelphia, asking for the NI community to identify key or to take on other careers with vendors
or consultant groups, as the demand for
trends they are experiencing or anticipate encountering in clinical informatics staff that understand
clinical workflow and are IT savvy is high
how the delivery of nursing care will change with technology
and the salaries are competitive.
and systems in the next two to three years. He planned to use interdisciplinary Collaboration. A sec-
ond area is a shift toward improved inter-
the ideas as a discussion tool to help inform the direction for disciplinary collaboration. In general, the
IT and nursing strategic planning at his organization. perception is that practitioners, educators,
researchers and IT are partnering more
A couple dozen people responded to teChnology impaCt on people than before, recognizing that a cross-
his post over the next week, with varied informatics Workforce. The huge focus on functional and inter-discipline perspective
and creative ideas as to how technology health IT—due to the HITECH incentives will increase efficient and effective imple-
will change nursing practice. Of course and the deadline to meet the new govern- mentation and use of the technology.
there is no disagreement to the fact that ment regulations to implement electronic Nurses at all levels, members of other
technology has, and will continue to health records for all Americans by 2014— disciplines, managers and administrators
have, an impact on healthcare and the has created a workforce shortage of nursing are more comfortable partnering with
practice of nursing. But, I was inspired informatics specialists. This has generated developers/vendors; informing develop-
by the specificity of the online dialogue the concern that there will be an increasing ers/vendors what is really needed for
and thought that others might be inter- number of bedside nurses taking opportu- practice, quality improvement and out-
ested in a summary of the responses, so nities in health IT that have been created comes management.
I decided to make this the focus of my by the demand. Online Education. A third focus is the
column for this issue. Included are those who pursue for- changes occurring in nursing education.
The ideas have been summarized into mal informatics education through one Online education has become ubiquitous
three groupings based on the targeted of the many new health IT training pro- and used successfully in many different
impact of the technology—on people (nurs- grams fueled by federal subsidies under ways for traditional nursing undergradu-
es), on process (nursing practice) and on ARRA. Also included are those who are ate education, as well as for continuing
technology use (by nurses). furloughed away from direct patient care education, specialty/certificate education

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15
NUrSiNG iNFOrMAtiCS: TRENdS IN ThE dElIvERy oF NURSING CARE
and graduate education. There is a related
issue—changes in technology are occur-
ring so rapidly today that nursing educa-
MOVING COMPuTER DEVICES
to the point-of-care has
tion departments need to find new ways to
help staff stay current with health IT appli-
cations and new equipment technologies.
teChnology impaCt on proCess
Workflow. With new technologies come
had an impact on the delivery
of nursing care.
new operations. Understanding the work-
flow and outputs of the practitioner is para-
mount when creating/changing workflows
that include new technology or systems.
This cannot be understated on health IT
projects involving clinicians. It is not about
what the technology/application is … it is functionality and screen layouts support it can get in the way of the patient-nurse
about how the technology/application is the workflow and data required is one way relationship if too much time is spent on
used in the context of patient care delivery. to do that. Another way is to incorporate the computer device in the room instead of
Social networking is a trend that may decision support. interacting with the patient.
have an impact on nursing workflow in Lastly, ensuring that quality measure So, this is our challenge in all three
the future. Used within an organization data reporting is a by-product of care doc- areas … balancing the positive and nega-
or across organizations, it might increase umentation, rather than creating separate tive impact of technology on nursing
communication among practitioners and forms and data fields ensures that nursing practice, and making sure we not only
could be used for patient care or staffing. time is not wasted on redundant activities. understand the impact, but orchestrate it
For example, nurses from different units Another area of optimization is in staff- to ensure that we achieve the impact we
within the hospital could post about an ing. Nursing is moving toward evidence- are looking for. jHIm
increase in infections, help diagnose a sys- based staffing decisions customized to the
tem error, or collaborate on projects. Nurse specialty and based on acuity, and mov- A special thank you goes out to Michael Kurliand
managers could use the networking to sup- ing away from staffing decisions based on and the HIMSS Nursing Informatics Community
port one another with on-demand staffing, census. Patient classification or nursing for their help in identifying many of the ideas in
requesting assistance for a particular pro- acuity systems validate the patients’ acu- this column. The NI Community has always been
cedure, or staff education. ity and account for the differences in each selfless in sharing and helping each other; here is
Standardization. Standardizing nurs- patients care, providing a “severity of ill- just one more example of that. I truly appreciate
ing terminology, documentation of prob- ness” score that can be used to determine being part of this group – JM.
lems, assessment, goals and interventions nursing intensity of care and resource con-
is gaining support and attention. Nursing sumption. Judy Murphy, RN, FACMI,
has more than three decades of experience FHIMSS, is Vice President,
in development of nursing vocabularies. teChnology use Information Services, at
Today, there is a shift from development There is no question that moving computer Aurora Health Care in
of vocabularies to interoperability of data devices to the point-of-care (bedside) has Milwaukee, WI., and
across the spectrum of healthcare settings had an impact on the delivery of nursing integrated delivery network
for continuity of patient care. In addition care, both positive and negative. These with 14 hospitals, 100
to providing information regarding a spe- include mobile and handheld devices, as ambulatory centers, home
cific patient, standardized information well as fixed devices in the patient rooms. health agencies and 26,000 employees.
will help organizations share and com- In some cases, the technology allows us to
pare data; influencing research, outcomes do things we would no t have been able to
and workload. do before; such as positive patient ID using
Optimization. The delivery of nursing barcoding, barcoded medication adminis-
care needs to be consistently evaluated for tration and taking photos as part of the
changes that would optimize the process, patient record, as well as quick and easy
by impacting the effectiveness and efficien- access to orders, care plans, results and
cy of how the nurse works. Ensuring that telehealth applications. In other cases, the
IT applications are streamlined so that the technology can have a negative impact, as

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FundIng Edna boone
Beyond
Meaningful Use
Securing Funding for Your Health IT Project
S
ince the passage of ARRA in 2009, health systems epidemiology, laboratory and health infor-
mation systems capacity.
and providers have focused on aligning their health Two major priorities that are being
addressed with this particular funding
IT strategies to meet meaningful use requirements stream: increasing the number of well-
equipped public health laboratories using
to secure incentive funding from the Centers for Medicare
electronic systems to manage and exchange
and Medicaid Services (CMS). This attention to automation information between labs and public health
departments, and developing capacity for
to increase quality and efficiency is unprecedented in the public health departments to participate in
meaningful use of electronic health records
history of the healthcare industry. through implementation of electronic lab-
The funding provided by ARRA through may also want to consider pharmaceuti- oratory-based reporting. If your organi-
CMS is intended to assist providers and cal partnerships, employer partnerships, zation is currently engaged with a public
hospitals in implementing meaningful use, malpractice carriers, vendors, banks with health entity, you may be eligible for future
not compensate them in full for the cost of trust departments, corporate grant-making funding.
automating. programs, insurance company founda- About $21.6 million was awarded as part
Budgets are tight in this economy, and tions, direct legislative allocation (gover- of the National HIV/AIDS Strategy. Half of
many healthcare providers struggle to nor’s budget or congressional earmark), the money was designated for demonstra-
adequately staff and fund their health IT and in-house planned giving and endow- tion projects in the 12 areas around the
projects, knowing that cutting corners on ment development programs when seeking country where the HIV/AIDS epidemic
appropriate staffing and funding can be funding of their health IT projects. has hit hardest. The remaining portion
detrimental to a project’s success. was distributed to state and local public
Adequate resources for staffing, tech- examples of reCently health departments to increase HIV test-
nology and process redesign are essential released federal funds: ing and improve surveillance data report-
to ensure an effective transition from a the U.S. department of Health & Hu­ ing. If your organization is in one of the 12
paper-based silo environment to an elec- man Services. HHS announced $100 regions, you may be eligible for funding to
tronic-based team environment that places million in grant awards to address public automate your reportin g.
patient safety, quality and efficiency of care health and prevention priorities across the Agency for Healthcare research
front and center. the United States made available through and Quality. AHRQ awarded $473 mil-
Beyond the high-visibility meaningful the Prevention and Public Health Fund lion in grants and contracts for research
use incentive funds, many health providers (established by the Patient Protection projects that use health IT to compare the
may not be aware that hundreds of funding and Affordable Care Act). A major objec- effectiveness of medical treatments and
opportunities and partnerships exist from tive for the distribution of these funds is processes.
a host of organizations, including federal, improving public health infrastructure Health reform legislation committed $15
state and local governments, private foun- and reporting capabilities. Another $26.4 billion to the Prevention and Public Health
dations, research organizations and qual- million was distributed to public health Fund over the next decade. ARRA commit-
ity improvement organizations. Providers departments in all 50 states to strengthen ted $1.1 billion for comparative effectiveness

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17
FUNdiNG: BEyoNd MEANINGFUl USE
EditOr­iN­CHiEF
richard D. lang, edD
ViCE PrESidENt, COMMUNiCAtiONS
Fran perveiler
BEyOND THE HIGH-VISIBILITy MEANINGFuL MANAGEr, PUBLiCAtiONS
matt Schlossberg
uSE INCENTIVE FuNDS, many health EditOriAL rEViEW BOArd
providers may not be aware that hundreds
mary Alice Annecharico, rN, FHimSS
Chief Information officer
University hospitals
of funding opportunities and partnerships Shaker heights, oh
marion J. ball, edD, FHimSS
exist from a host of organizations, including
Fellow, IBM Global leadership Initiative
Center for healthcare Management
Professor, Johns hopkins School of Nursing
federal, state and local governments, eta S. berner, edD
Professor health Services Administration
University of Alabama at Birmingham
private foundations, research organizations Birmingham, Al
william F. bria, mD
and quality improvement organizations. Chief Medical Information officer
Shriners hospital for Children
Tampa, Fl
John p. Glaser, FcHime, FHimSS
CEo, health Services
Siemens healthcare
research. If your organization is engaged in strengths, previous successes and future Malvern, PA
research or is affiliated with an academic vision with your potential funder. Orga-
margaret m. Hassett, mS, rN, c, FHimSS
institution that is engaged you may be eli- nizations that may not consider funding director of Clinical Informatics
gible for funding. Look at the key disease technology may be amenable to awarding Berkshire health Systems
management states in which your organi- smaller grants to offset training and work- Pittsfield, MA
zation has expertise, along with current flow redesign costs. Directing your energies James langabeer ii, FHimSS
health factors and concerns in your county into applications for funding takes time and Associate Professor,
or state. Are there funding and research patience, but the rewards can be great and Management & Policy Sciences
The University of Texas School of Public health
opportunities for automating the manage- can ensure your project receives the neces-
houston, TX
ment of these disease states, such as obesity sary funding for success. jHIm
or diabetes?
In order to navigate the sea of oppor- Edna Boone is the Senior
tunity, HIMSS has teamed up with the Director of Health
Grants Office to offer Grants Advantage, Information Systems at
a subscriber program designed to assist HIMSS and has extensive
HIMSS members in securing funding for experience in grants and
health IT initiatives. The program provides contract funding for health
subscribers with access to a grants database IT projects.
and grants management system to track
grant opportunities and applications. The
program also provides users with individ-
ually-researched funding reports, grants
management education and discounts on
grant writing services.
Be sure your funding request ties to
your strategic goals. Share your history,

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legIslatIon Gerry blass and susan a. miller, JD
HIPAA/HITECH
Business Associates
Expanded Scope of Responsibilities and Liabilities
t
he privacy and security updates of the HITECH Act entities have routine access to PHI on
behalf of the upstream entity (BA or other
have been called HIPAA on steroids, and there are subcontractors).
Excluded from this new collection of
good reasons for that. There are several additions BAs are:
and clean-up measures in the statute and the matching regu- n■ Common carriers, such Fed Ex and
UPS. They are considered mere conduits
lations. One of the best additions has been to expand the for transport of PHI that do not access PHI
other than on a random or infrequent basis.
scope of responsibilities and liabilities for business associ- n■ PHR vendors that offer PHR directly
ates (BA). BAs are now basically the same as covered enti- to consumers, and not on behalf of a CE.
FTC Breach Rules still apply to these PHRs.
ties (CE) when it comes to compliance with HIPAA and
only the beginning
HITECH. While contracts between CEs, who share their
While the expansion of the scope of respon-
personal health information (PHI) with BAs, still need to be sibilities and liabilities for BAs is a good
addition to the HIPAA rule, there are some
in place for use and sharing of PHI, the lines of responsibili- issues. It will take a while for the industry
ties are clearer. BAs and CEs are now responsible for—and to know just what and how much of the
HIPAA privacy, security and enforcement
totally in control of—their actions and mistakes. requirements directly apply to BAs. After
all, the new Notice of Proposed Rule Mak-
additional ba entity types to more ePHI than ever before, gathered ing (NPRM) was only released in July 2010.
Additional types of entities are now con- from multiple places, such as a hospital What it does state is that HIPAA Securi-
sidered business associates, health infor- lab, national labs, other physicians, MRI ty Rule is directly enforceable against BAs.
mation exchanges (HIE). Ten years ago, centers and more. The potential locations It also states that several Privacy Rule pro-
when HIPAA was new, most electronic and vulnerabilities of ePHI has increased, visions are now directly enforceable against
sharing of PHI was point-to-point, from and with it the risk of unauthorized access. BAs, including:
physician or hospital to health insurer and Additional types of BAs now include, for n■ BAs may not use or disclose PHI in
back. There are now many-to-many points example: violation of the Privacy Rule.
of electronic data exchange. We have gone n■ Patient safety organizations (PSO). n■ BAs are subject to compliance reviews,
from a linear electronic environment to a n■ HIEs and e-prescribing gateways. investigations and audits by the Office of
hub-and-spoke electronic environment. n■ PHR vendors that offer PHR to indi- Civil Rights (OCR).
For example, a physician, through his or viduals on behalf of a CE. One way to think about how much of
her EHR system can access a local HIE n■ Subcontractors of BAs that have rou- HIPAA a BA must live up to on its own
for clinical labs and radiology work for a tine access to PHI on behalf of a BA. might be to currently use the Ivory Snow
patient before the next visit. n■ Subcontractors of subcontractors measure of 99 44/100 percent. This is
A physician can potentially have access (down the line)—to the extent downstream undoubtedly the belt and suspenders

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19
LEGiSLAtiON: hIPAA/hITECh BUSINESS ASSoCIATES
HiMSS BOArd OF dirECtOrS
chair
c. martin Harris, mD, mbA, FHimSS,
Chief Information officer and Chairman,
Information Technology division,
Executive director, eCleveland Clinic
The Cleveland Clinic Foundation
approach, but the healthcare industry is ments it will take time for the rule become Vice chair
at the front end of implementation and final. Despite the timeframe it is now time charlene underwood, mbA, FHimSS
enforcement. It might be better, for start- for BAs to begin to create and / or update director, Government and Industry Affairs
Siemens Medical Solutions
ers, to have too much protection than not policies and procedures, plans, and overall
enough. evidence of due diligent compliance activi- Vice chair elect
ties. It is now time to begin to conduct and/ Holly D. miller, mD, mbA, FHimSS
down the line or update assessments and tests. And, it is Chief Medical officer
MedAllies
Another new requirement of the ACT for now time to train the workforce and pro-
both CEs and BAs are the BAs’ subcontrac- vide frequent ongoing security reminders David S. Finn, ciSA, ciSm
health Information Technology officer
tors, or sub-business associates that use or knowing that the biggest threat for unau-
Symantec Corporation
disclose the CE’s PHI. BAs are now respon- thorized access and breach is from internal
r. Scott Holbrook, mS, FHimSS
sible for their sub-BAs actions and events. sources. BAs should being a process now to
Executive vice President
So, BAs must enter into BA Agreements assess, audit and monitor their applicable Medicity
(BAA) with downstream entities that have sub-contractors. And, CEs should begin a
Judy murphy, rN, FAcmi, FHimSS
routine access to PHI that require: process now to assess, audit and monitor
vice President, Information Services
n■ Subcontractors that have routine their BAs as part of their expanded scope Aurora health Care
access to PHI to comply with applicable of due diligence activities for compliance
Jenifer Jarriel, mbA
HIPAA Rules. with HIPAA and HITECH. jHIm
vice President of Information Technology
n■ Report to CE (or BA) any security and Chief Information officer
incident of which it becomes aware, includ- Gerry Blass has over 34 Baylor College of Medicine
ing any breach of PHI for purposes of the years of experience in miriam paramore, FHimSS
breach notification rule. healthcare IT and Senior vice President,
The privacy, security, and enforcement compliance. Gerry provides Corporate Strategy and Public Relations
equation now has one more interlocking IT and compliance Emdeon
connection and looks like this: CEs ßà BAs consulting services and carol r. Selvey, mHSA, FHimSS
ßà Sub-BAs. software that automates the Associate vice President,
Business development
management and
expanded liabilities documentation of healthcare compliance activities.
Iatric Systems, Inc.
BAs are now directly subject to civil and Gerry is the President & CEO of Blass Affiliates LLC. carol Steltenkamp, mD, mbA, FAAp, FHimSS
Chief Medical Information officer
criminal enforcement penalties plus retain
University of Kentucky healthCare
their contractual liability as well to their Susan A Miller, JD, has 35
CEs. Under the HITECH Act and its regu- years of professional willa Fields, DNSc, rN, FHimSS
Professor, San diego State University
lations the HIPAA fines have also been leadership experience
substantially increased. This is one area spanning teaching, Steven Arnold, mD, mS, mbA, cpe, FHimSS
Chief Medical officer
where HIPAA is truly on steroids! The biochemistry research and
virginia Commonwealth University
former HIPAA fines are now the fine floor, law. Since 2002, Susan has health System in Richmond.
and the top amount under all enforcement provided independent
Scott t. maclean, mbA, cpHimS, FHimSS
4 tiers can be as much as $1.5 million. One consultation and legal
Chief Information officer
thing this mega change points out is that services to numerous healthcare entities ncluding Newton-Wellesley hospital
HIPAA enforcement is about to get serious, DHHS/CMS. Blass and Miller are co-founders of
very serious. HIPAA 411. AdViSOry BOArd MEMBErS
Debra bremer
summary Harry Greenspun, mD
Remember, the industry is still talking Keith m. Kerman, mD, mbA
Howard A. burde, esquire, FHimSS
about the new privacy and security imple-
mentation implications. While we can begin
to seriously think about these new require-