Interoperability and the ‘HITECH Act’’
How can a word or acronym be overused before it’s even known? We all know what interoperability is, but does it exist? In Hawaii? In short, no. Don’t believe me? Do a Google search on “interoperability Hawaii”. Go ahead, I’ll wait. Nada, zip, zilch. As of today, there is nothing related to health information technology, or health information exchange in the top 20 spots. Why? Because it does not exist. I don’t know if there were ever 200 manufacturers (estimates vary wildly) of anything besides electronic health records, so I will use automobiles as an analogy. Take a Fiat Spider, pull off the bumper. Put it on a Chevelle, or Chevy Camaro Rally Sport.
2009 Chevrolet Camaro EHR (Extra Hot Rod)
Please use a new one, don’t ruin a classic. How does it look? Probably pretty darned strange considering the 2009 Camaro has no bumper – until you bolted that thing on it. My point? EHR interoperability is just a concept, not reality. There are several local organizations that claim to be “experts” in interoperability. As of now, there are none. When you can order a lab test, upload it to the laboratory, download it to the EHR, then transfer the results to another EHR across town, THEN we can talk about expertise.
Enter SOA, or service oriented architecture. “IBM’s healthcare strategy is based on the adoption of an SOA approach and the use of open standards and standards-based electronic health records to provide secure and private exchanges of records between authorized healthcare provider and healthcare payer organizations.” Well said. Getting the 300+ various systems to talk to each other will be the challenge. Think UN. Many companies are working on health information exchange, but in a different way. Before we can be interoperable, we must be functional. You have to put the data in, first. Implementation of these systems will be the single greatest initial challenge, by far.
Which takes me to HITECH. Interoperability is only mentioned 3 times in the entire 220 page document. Not an accident I think. Standards is mentioned well over 100 times, however. So, what is HITECH? What’s in this bill? Unfortunately, there is no easy way to explain it intelligently, so you should read it, or at least do a speed read on it. I know it’s painful, but fortunately, it’s double spaced and only half the normal width of a regular document, it’s a lot like my high school essays, except with useful content. Here’s a quick, plagiarized summary:
‘‘Sec. 3001. Office of the National Coordinator for Health InformationTechnology.
‘‘Sec. 3002. HIT Policy Committee.
‘‘Sec. 3003. HIT Standards Committee.
‘‘Sec. 3004. Process for adoption of endorsed recommendations; adoption of initial set of standards, implementation specifications, and certification criteria.
‘‘Sec. 3005. Application and use of adopted standards and implementation specifications by Federal agencies.
‘‘Sec. 3006. Voluntary application and use of adopted standards and implementation specifications by private entities.
‘‘Sec. 3007. Federal health information technology.
‘‘Sec. 3008. Transitions.
‘‘Sec. 3009. Miscellaneous provisions.
Sec. 13102. Technical amendment.
PART 2—APPLICATION AND USE OF ADOPTED HEALTH INFORMATION TECHNOLOGY STANDARDS; REPORTS
Sec. 13111. Coordination of Federal activities with adopted standards and implementation specifications.
Sec. 13112. Application to private entities.
Sec. 13113. Study and reports.
Subtitle B—Testing of Health Information Technology
Sec. 13201. National Institute for Standards and Technology testing.
Sec. 13202. Research and development programs.
Subtitle C—Grants and Loans Funding
Sec. 13301. Grant, loan, and demonstration programs.
‘‘Subtitle B—Incentives for the Use of Health Information Technology
‘‘Sec. 3011. Immediate funding to strengthen the health information technology infrastructure.
‘‘Sec. 3012. Health information technology implementation assistance.
‘‘Sec. 3013. State grants to promote health information technology.
‘‘Sec. 3014. Competitive grants to States and Indian tribes for the development of loan programs to facilitate the widespread adoption of certified EHR technology.
‘‘Sec. 3015. Demonstration program to integrate information technology into clinical education.
‘‘Sec. 3016. Information technology professionals in health care.
‘‘Sec. 3017. General grant and loan provisions.
‘‘Sec. 3018. Authorization for appropriations.
Subtitle D—Privacy
Sec. 13400. Definitions.
PART 1—IMPROVED PRIVACY PROVISIONS AND SECURITY PROVISIONS
Sec. 13401. Application of security provisions and penalties to business associates of covered entities; annual guidance on security provisions.
Sec. 13402. Notification in the case of breach.
Sec. 13403. Education on health information privacy.
Sec. 13404. Application of privacy provisions and penalties to business associates of covered entities.
Sec. 13405. Restrictions on certain disclosures and sales of health information; accounting of certain protected health information disclosures; access to certain information in electronic format.
Sec. 13406. Conditions on certain contacts as part of health care operations.
Sec. 13407. Temporary breach notification requirement for vendors of personal health records and other non-HIPAA covered entities.
Sec. 13408. Business associate contracts required for certain entities.
Sec. 13409. Clarification of application of wrongful disclosures criminal penalties.
Sec. 13410. Improved enforcement.
Sec. 13411. Audits.
PART 2—RELATIONSHIP TO OTHER LAWS; REGULATORY REFERENCES;
EFFECTIVE DATE; REPORTS
Sec. 13421. Relationship to other laws.
Sec. 13422. Regulatory references.
Sec. 13423. Effective date.
Sec. 13424. Studies, reports, guidance.
See, that wasn’t so bad. I feel and look smarter already. OK, now you can relax and take that test drive. We have a long way to go. Once you wade through the HITECH Act, I’ll post the ARRA, all 407 pages of it.
Bumblebee Camaro EHR
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