November 20, 2009
So Much For Comparative Effectiveness
The Obama administration's commitment to cost control in health care can now be summed up in four words: Not on our watch.
Health and Human Services Secretary Kathleen Sebelius told American women this week that they have nothing to learn from the science that led to the U.S. Preventive Services Task Force guidelines on mammography.Insurance companies won't change their payment policies, andthe independent doctors and scientists who made up the USPSTF task force "do not set federal policy" or determine what services are covered by the federal government."
What a golden opportunity has been missed to educate Americans about the implications of their health care choices. Otis W. Brawley, the chief medical officer of the American Cancer Society, in an op-ed in today's Washington Post condemning the USPSTF guidelines, confirms that mass screening would only save at a maximum 600 out of the 4,000 women under 50 who die of breast cancer annually. What he failed to point out is that 1.14 million American women would have to be screened annually for ten years to achieve that goal. To cover the entire cohort (all women between 40 and 49) to replicate that benefit every year would require screening 11.4 million women annually. The cost, at $200 per mammogram (my initial estimate was accurate, according to this New York Times business section article), would come to $2.24 billion annually for the health care system.
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Comparative Effectiveness Research, Merrill Goozner | Permalink
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So will the public option hurt hospitals? Not in the Ozarks
I've had this sitting in my inbox a while, but I thought that with the Senate bill out it was time to have a bit of weekend fun with it. The topic is the fear that a public option/government-run health plan/Hitler-ization of America (delete where applicable) will of necessity put all those worthy private health plans out of business. And worse because it will impose government's lower pay rates on providers, it'll also put them out of business, or at least into a position equivalent to that of Ukrainian peasants working on a collectivized farm.
Everywhere you go in the hospital world you hear complaints that Medicare pays less than private payers, and that the private insurance business is the only thing keeping providers alive.
Everywhere but Orark mountains of southwest Missouri and Northeast Arkansas.
Paul Taylor is the CEO of a tiny hospital system there called Ozarks Community Hospital. It's basically a safety net hospital and it only gets about 5% of its business from the leading commercial insurer, Blues of Missouri--part of Wellpoint. And does Wellpoint pay more for its patients than Medicare?
Err...no
In fact this chart shows that it pays less than half in many cases. I thoroughly recommend you read Pauls blog piece on the topic from which I lifted that chart. It's an entertaining, detailed and sensible read.
But what he's saying is that a public option will be better for hospitals serving lower-income populations than a simple expansion of private insurance.
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This Just In
Yesterday, but the U.S. Treatment Services Task Force announced that leeches aren't a particularly good treatment for most ailments. While noting that leeches might still be useful for certain specific circulation disorders, the USTSTF recommended against their use in other situations, like treating fever and abdominal pains.
Although the Task Force has no power to make anyone do anything, Rep. Dave Camp (R-Mich) was heard on NPR's Morning Edition saying, "Some people discounted the idea that the government would actually put people to death ... this actually is really showing how the insidious encroachment of government between the patient and their doctor plays out." Camp neglected to address the facts: (1) overuse of leeches is expensive, and science-based recommendations about appropriate use would save the government money without harming patients, and (2) bloodletting can lead to negative side effects, such as upsetting the body's natural humoral balance.
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Harvard Study Gets it Wrong on EHRs and Quality
America’s hospitals are a triumph of modernity, stocked as they are with PET scanners, ECMO machines, and ICUs bedecked in eye-popping gadgetry.
They are also the most complex organizations ever created by man. The seemingly simple process of delivering a drug from the pharmacy to the bedside for example, typically involves a 30-step process executed by a half-dozen people on 3 floors. There are hundreds of ways it can fail.
It often does, and that’s just half the story. Each hospitalized patient requires a unique combination of services including lab tests, physical therapy, a discharge plan and so forth. Since a complex process must be executed to produce each service, the hospital becomes a job shop.
By contrast, the processes used to produce cars and silicon chips are relatively unfettered. That is why piston rods can be produced in batches with every item meeting specs to the micron, while hospital processes often feature error rates of 10-20%.
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November 19, 2009
Sell Patients like Baseball Players - Seriously
Here's a health care reform strategy
that I have not heard anywhere else. Think about this:
Why aren't health plans more aggressive
in promoting the long-term health of their members, like getting them
to eat better, stop smoking, get a little exercise, and all that? Because
of "churn." For something that has immediate consequences,
helping their members stay healthy has an immediate payoff for the health
plans. But most of the big things that would make you healthier take
a longer time to manifest: You quit smoking or start eating better,
you will have a much better health profile in five years, but it won't
make as much of a difference in, say, one year.
"Churn" is the industry term for the annual percentage of members who leave a health plan, and it can be surprisingly high. If each year 20 percent of a health plan's members go to some other health plan for whatever reason (they move, lose their job, change employers, get Medicare, find a better deal), then it is not worth it for the health plan to invest in their members' long-term health. If the health plan invests time and effort (which means money) to get you to quit smoking, and you then quit and become someone else's customer, they lose that investment - and the other company gains, by getting a customer who is less likely to need expensive long-term treatments.
But what if they did not lose that investment?
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Organ Donors Shouldn't Be Penalized
It can be challenging to find an organ donor for someone who needs a transplant. But when a donor and desperately sick person are matched up, living donors should not be "punished" for their gift, especially by the health insurance industry.
This is a little-known aspect of the health care debate that should be brought to light -- the fact that there is nothing that prevents health insurance companies from either denying coverage or charging higher premiums to those who donate an organ by categorizing them as people with "pre-existing conditions."
This lack of regulation makes it potentially difficult for donors to get health insurance after giving the gift of life.
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The Health Internet vs. the NHIN -- A Matter of Control, Cost, and Timing
There is growing tension within the Obama administration's health team over who will control health data exchange: everyone (including consumers and their doctors), or just large provider organizations. The public debate will be framed in terms of privacy, security, and the adequacy of current exchange standards. But what really matters is who gets to make decisions about where health data resides, how it can be accessed, how much exchange will cost, and how long it will take for exchange to become routine.
Now is a good time to re-visit the plans for a National Health Information Network (NHIN), since we can finally observe and compare different health data sharing and exchange models in the marketplace. NHINs represent an older model that tries to use regional health information organizations (RHIOs) to establish secure networks, privately owned and operated by large provider organizations, mostly hospitals and health systems. The idea was that, over time, each private regional network would develop a gateway to other networks, creating a "network of networks" that would allow Stanford to talk to Partners Health, or Kaiser to Mayo. This communications model was enterprise/provider-centric. Patients/consumers were relegated to depending upon each RHIO's policies for access to their health information. It was also a massively expensive and time consuming - think decades - way to build a health data network.
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November 18, 2009
Practice Fusion throws its hat in the consumer ring
Practice Fusion has been making a fair bit of noise recently with its investment from Salesforce and its trumpeting of 18,000 + physician users. If that number is true it probably makes it the most used EMR outside of EPIC or VISTA—bear in mind that AthenaClinicals only claims around 2,000 users. I’m inclined to take that number with a large grain or two of salt, and suspect that the number they’re reporting is “registered” users rather than “active” users. However, either way you slice it their “free SaaS-based” EMR model has put the cat amongst the pigeons (FD PracticeFusion was a sponsor of the recent Health 2.0 conference which I co-founded).
Today Practice Fusion adds a pretty important piece to their armory—the patient view and record called “patient fusion”. Below is a screenshot they sent me.
Now I haven’t reviewed the product nor seriously vetted their claim that it’ll be available to 1,000,000 patients already. But I can tell you that SaaS-based clinical groupware services like this one are an increasingly viable alternative to the traditional EMR vendors. And in these days of cats and dogs coming together, it’s good to see this level of innovation coming to the market.
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The Outlook for a Health Reform Bill in 2009
Readers know of my yearlong pessimism over our getting a trillion dollar health care bill in 2009.
With the historic passage of the House bill, are we now on our way to a big health care bill in 2009—or even by early 2010?
Clearly, Democrats desperately want to pass a bill. Given their compromise over abortion and the neutering of the public option in the House legislation—things most liberals said they would never agree to—it is clear the Democratic leadership will take any deal they can get.
But there are still some giant obstacles on the way to a Rose Garden bill signing late this year or early next:
- Getting and keeping 60 Senate votes across a wide spectrum of complex issues. Senate Majority Leader Reid has not achieved a 60-vote consensus on any of the dozen or more contentious issues. In the wake of Pelosi not being able to get more than a two-vote margin for the neutered public option, some Democratic Senators will have no interest in the “robust” version with the state opt-out Reid has been talking about. He has made even less progress on all of the other contentious issues--and you can put abortion on the top of that list. Figuring out the “sweet spot” on each issue that keeps the same 60 votes on side for the entire bill would take a super computer—if that were even possible.
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Extormity launches WHIO to compete with Health Internet
Electronic health records vendor Extormity, seeking to establish itself as the dominant force in the healthcare IT space, is launching its World Health Information Organization or WHIO platform at a public launch event in Brussels.
“WHIO is like a mega-RHIO or HIE, and it is pronounced the way Barbara Walters would say RHIO,” said Extormity CEO Brantley Whittington from a shareholders meeting in Monte Carlo. “We view the repackaging of the NHIN into the Health Internet as a disruptive move capable of making us obsolete, so we decided to make a bold play and launch a global health ecosystem that will one day combine search, advertising, content, connectivity, partners, devices, health and wellness tips, recipes, diagnostic tests, medical advice, physician and hospital ratings, car care guidelines, health related ringtones and a whole bunch of functionality we haven’t even dreamed of yet.”
To cement its international position, Extormity is going to offer WHIO in every language on the planet, including obscure dialects. “We even have a team of programmers working on the way some remote tribes communicate using a series of clicking noises, which is incredibly difficult to code,” added Whittington.
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Controlling Health Care Costs: How to “Bend the Curve”
As Congress nears passage of the first substantial health care reform in decades, there is an ominous challenge: No reform will be sustainable unless we slow the rapid growth of health care spending.
Health care costs are rising at a staggering pace. Expenditures have been increasing at 2.7% per year faster than the rest of the economy over the past 30 years. In 1980 the US spent about 8% of GDP on health care. We now spend over 17%. We need to rein in growth of health care spending to levels no higher than overall economic growth -- or ideally "bend down" the growth curve to an even lower figure.
How do we “bend the curve”? What are the best ways to slow the growth of health care costs, thus making other reforms sustainable?
There are three major areas in which reforms will help bring health care spending under control.
Prevention: US health care is burdened by diseases that are preventable. If we can improve lifestyle issues – nutrition, exercise, obesity, tobacco use – we will lower the future incidence of diabetes, heart disease, cancer, and other costly maladies. Current health reform proposals that allocate $10 billion for a Prevention and Wellness Fund represent a major step in the right direction. Disease prevention likely provides the greatest return on investment regarding health care costs of anything we do.
Hospital and Physician Behavior: Hospitals have no incentives to prevent unnecessary hospitalization. Physicians, paid mostly by fee-for-service, have every incentive to order more tests and procedures. Neither is rewarded directly for making – or keeping – patients healthy. Key to controlling health care costs in the future will be to realign these incentives.
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November 17, 2009
"The possible" vs "what we want," resumed
Not so long ago (actually less than 2 weeks), there was quite the spat on THCB between the Four Horseman (Klepper, Kibbe, Lazewski & Enthoven) and Maggie Mahar. Essentially it came down to this question:
Is there enough in the current House & Senate bills to restrain spending and remake the health care system? Or is the whole effort so bought off by the health industry as to be a waste of time?
I put myself in the camp of agreeing with both the Four Horsemen (that the bills were pretty much emasculated) and with Maggie (in that at least we’ll get some significant improvements in coverage for the uninsured).
And don’t they need it. In fact I wonder how many of the 50–odd million uninsured and the 50–odd million Americans who don’t have enough to eat are the same people.
But today the chorus of “fiscal responsibility through health reform” being orchestrated by the Administration got a little louder. It started about a week ago with Peter Orzsag banging the drum for health care reform being deficit neutral. He pointed to a letter from a group of moderate to liberal economists supporting HR 3962.
Today many of that same group (although not all and without the non-economists) were joined by some heavy hitters on the health economics side supporting many of the tenets of the Senate bill. This new group includes many of the same liberals but also some sensible Republicans (well Mark McClellan) and some real big guns including Uwe Reinhardt, Victor Fuchs, Joe Newhouse, Laura Tyson, Henry Aaron, Alan Garber and Kenneth Arrow. Alain Enthoven (one of the Four Horsemen) is notable by his absence.
However, the economists probably wouldn’t disagree with the Four Horsemen about how limited the changes in the Senate and House bills actually are, and they appeal for an independent Medicare Commission and serious delivery system reform—all of which will be emasculated in Congress. But nonetheless they are providing valuable intellectual cover for the Administration—no one on the other side will be able to put a crew like this together! Meanwhile over on the Health Affairs blog Jack Wennberg (with Shannon Brownlee) is giving an assist by stepping up his counter-attack against the Academic Medical Centers who are complaining that their patients are sicker.
So the “realists” are coming out in support—all believing that once we get the legislation out of Congress and into sensible hands within the Administration there’s a chance that we might be able to do some good in terms of delivery system change.
Stay tuned. This is a good reason to keep reading THCB for the next decade.
Matthew Holt, Medicare, Policy, Policy/Politics | Permalink
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November 16, 2009
Spotlight on Health 2.0: In The Doctors Office, from SF 2009
Every week we bring you a new video from Health 2.0! This week we're featuring Health 2.0 In the Doctors Office, a special showcase featuring physician-facing tools and services from the recent Fall conference in San Francisco.
To see more videos from past Health 2.0 conferences, or to purchase the entire conference DVD sets from '07 & '08 click here. 2009 DVD sets will be available shortly, please check back for updates.
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November 14, 2009
Health Reform: Measurables and Immeasurables
"Our scientific age demands that we provide definitions, measurements, and statistics in order to be taken seriously. Yet most of the important things in life cannot be measured." - Dennis Prager, 1948 - radio host, lecturer, columnist, ethicist
"My first goal for Intermountain is that anytime a physician or nurse says, ‘In my experience’ when they’re talking to a patient, they mean ‘In my measured experience.’ ” - Brent James, MD, Chief Qualify Officer, Intermountain Healthcare, as quoted in “Dr. James Will Make It Better,” by David Leonhardt, New York Times Magazine, November 8, 2009
It all sounds simple enough. You measure everything you do. You gather claims data. You measure what works. You show measures of what works to doctors and nurses. You write protocols for doctors and nurses to follow what works. You pay more for what works. You pay less for what doesn’t work. You remove pay incentives that cause doctors to do more. You gather together doctors who lead organizations with track records for providing better care at lower costs at the White House.
You trot out the theory of evidence-based care,
1. For any given diagnosis, the doctors has a number of options, and you assume most diagnoses fall neatly into diagnostic bins.
2. Committees of doctors and others, such as health plans and Medicare medical directors, track data outcomes related to these options and develop protocols for best results.
3. Doctors follow protocols, and outcomes improve.
Voila! You have the rudiments of a national policy for providing higher quality care at lower costs.
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November 13, 2009
Conspiracy theory Friday (FDA & CCHIT related)
Two fun things—First, Mark Leavitt says he’s quitting CCHIT in March. He says that he’ll be 60 then and wants to go do other stuff. Of course the cynics among you will say that he’s had enough of being beaten up by David Kibbe and Brian Klepper, and that CCHIT’s role as arbiter of meaningful use has been downgraded by David Blumenthal. Leavitt says in his outgoing email (not on any website I can find but I have a copy)
“Given the current high-strung health IT news environment, the media may seek to conjure up some sensation-worthy driver of this decision, but the fact is that I am simply keeping a promise I made to my family and myself to retire from full-time work within a certain window of time”
It also happens that this announcement comes the day after Blumenthal sends out an email to the Health IT world that Vince Kuraitis (at the very least) sees as a direct shot at large health IT vendors whose products don’t play nice with others (i.e. aren’t too interoperable) yet are already CCHIT certified. Here’s Vince’s take on who should have got that email.
Second, the twittersphere has been abuzz with a series of hearings where the FDA has been taking opinions on how and why they should regulate Pharma advertising in social media. this is a non-trivial issue for both sides. Pharma wants to reach patients, patients want those social media players to exist, and the sites need money (which will have to come from Pharma, unless something changes in the space time continuum). I don’t pretend to know the outcome except to remind you all (via Bill Silberg) that a similar meeting was held more than a decade ago and the result was….nothing. no guidance, no policy.
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Will Business Force Reform Back To The Drawing Board?
Until now, non-health care business has been noticeably absent from the health care reform proceedings , and quiet about the bills' impacts on their management of employee benefits, on cost, and on the larger issues of global competitiveness. Where have the voices been of the powerful business leaders who will pick up much of the tab?
They've finally surfaced, and now we'll see whether they have the will to bring reform back on track. They certainly have the strength. The question is whether this salvo by the business mainstream could force Democrats to reconsider and revise the content and structure of their proposals.
On October 29th, a powerful collaborative of major employer organizations sent a letter to Speaker Pelosi and Republican Leader Boehner asserting that the House legislation "falls short of the bipartisan goal of controlling costs and jeopardizes employer-sponsored coverage which now serves more than 160 million Americans." The same group sent a similar letter to Senate President Reid earlier that week.
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November 12, 2009
Abortion Coverage Is About Math As Well As Politics
Let us start by acknowledging that those who think abortion is a sin must be respected, and not forced into a risk pool that covers abortion. Let us also acknowledge that those who are pro-choice need to acknowledge that abortion (except in the case of rape or incest or potential significant harm to the mother) is a personal choice (albeit usually as a result of an accident) rather than a health issue in the narrow sense of the word.
Therefore, leaving all the politics aside and just focusing on the question of what should be covered in a basic benefit, it is not unreasonable to require an actuarially appropriate rider to cover abortion.
What would that "actuarially appropriate rider" be? Probably only a dollar or two a month to begin with. Figure that there are 800,000 abortions per year. They cost maybe $1000 apiece. That’s $800,000,000. Divided by the 21-65 year-old health-insurance-buying population, we are talking about roughly $4/year. Next, figure some self-selection into the rider, so that people with the rider might, on average, think they have (for instance) three times the probability of an unwanted pregnancy than people without the rider, which is why they get the rider. Therefore their likelihood of abortion is three times higher than the average on which the above calculation was based. So that $4 becomes $12/year or $1/month, to begin with.
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The FDA Steps In: Regulating Prescription Drug Promotion on the Internet
The FDA has been widely criticized for not providing guidance for drug companies eager to promote their products on the internet. Earlier this year, the FDA expressed the view that the message was what was important, not the medium, meaning that companies should simply apply the rules governing prescription drug advertising in print media to the internet. On April 2, 2009 the agency issued Notice of Violation letters to 14 companies who sponsored links on internet search engines advertising their products; the links gave the name of the drug and, in some cases, its indicated use, without including the required “fair balance,” i.e., safety information such as contraindications and potential side effects. In reliance on the so-called “one-click rule” — which had never actually been adopted by the FDA — the companies had put the required safety information one click away on a separate page.
In recent months, the FDA has indicated that it is open to providing internet-specific marketing guidance. Yesterday and today (November 13th) the agency is holding a hearing on “Promotion of FDA–Regulated Medical Products Using the Internet and Social Media Tools.” Representatives from advertising agencies, consumer groups, health-related websites, pharmaceutical companies, and search engines are scheduled to testify.
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Regina Holliday's mural for Fred
Regina’s story has been on THCB before—Fred’s Life & Death at 73 cents a page. But you may not have seen the mural. (From NPR)
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November 11, 2009
Pay (Only) for Health Care that Works
Health care is expensive partly
because governmental payers and insurers foot the bill for large quantities
of medical services that are ineffective, unnecessary, or unproven.
According to a RAND report, studies of clinical efficiency “indicate
that one-third or more of all procedures performed in the United States
are of questionable benefit.”
When state and federal governments set the minimum terms for insurance coverage, this problem is likely to worsen. Governmental decisions reflect the political power of providers (who want to sell more services), the sympathy felt for patients (who want to consume more services and have other people pay for them), and the desires of bureaucrats (who generally want to maximize their budgets and their importance). These interests coalesce, causing governments to aggressively mandate coverage of services that may or may not be necessary.
The health reform proposals pending in Congress require all Americans to have insurance coverage. The problem with this “individual mandate” is that Congress (or some other regulator) will have to decide the minimum amount of insurance Americans can carry. The need to set this requirement is an open invitation to aggressive lobbying by health care providers. Wanting to ensure that the minimum benefit package covers their services, providers will spend millions on advertisements and campaign contributions to persuade legislators and regulators that more coverage is better. Lobbying from providers and supportive patients explains why many states already mandate coverage of elective services like in-vitro fertilization, massage therapy, and visits to athletic trainers. Concerns about the efficacy and cost-effectiveness of treatments are washed away by a stream of campaign contributions, and sad stories about patients who can only obtain the “necessary” services if the insurer will pay for them. The result is a one-way ratchet toward richer (and more expensive) benefit packages.
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The Best Health Care Idea All Year
Out of almost nowhere has come momentum for a proposal to create a bipartisan entitlement and tax commission to draft proposals to control the long-term costs of Social Security, Medicare, and Medicaid. The idea would require the Congress to quickly vote the recommendations up or down via a super majority vote.
The idea isn't new--proposals for a such a commission have been around for a longtime.
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Medicare’s Biggest Change in 40 Years on the Horizon?
Earlier this week CMS issued a typically cryptic Announcement indicating that they were shelving the Medicare Medical Home Demonstration (MMHD) and instead would focus on the recently announced Multi-Payer Advanced Primary Care Initiative (MAPCI). My blog post from Tuesday provides details and asks the question “What does all this mean?”
Medicare’s Biggest Change in 40 Years?
CMS’ Announcement about the rise of MAPCI and the fall of MMHD struck me as highly significant…but all the pieces didn’t fit. I’ve spent a fair amount of time emailing and talking with colleagues this week…and the big picture is emerging…and it’s really BIG. My working hypothesis is that Medicare is on the verge of its biggest change in 40 years:
- Medicare was created as a centralized, monolithic payment model. It’s been one size fits all, and that size is created in Washington DC. There has been little tolerance of regional administrative variability, and the ironic result has been high variability in regional costs and quality.
- Medicare seems poised to do a 180. It’s signaling movement toward supporting state-based, multipayer initiatives — where Medicare is at the table and influential, but not in control. It’s a recognition that health care is local and that unique solutions will be needed in different regional markets. The Obama administration is demonstrating strong support for the Patient Centered Medical Home (PCMH) and Accountable Care Organizations (ACOs) as important building blocks in this transition.
…and while this shift could be solidified by national health care reform legislation, it doesn’t seem to be dependent on such legislation. Success will measured at the level of individual state MAPCI’s.
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Dave Durenberger on Lieberman
Former Minnesota Senator Dave Durenberger, a thinking centrist Republican (remember them?) puts out an occasional newsletter full of gems. This is today’s zinger:
The Senate has a better bill than the House, but it also has a 60-vote requirement which empowers the odd-ball "if not my way, the highway" members - like Joe Lieberman claiming that something like a public insurance plan violates his "conscience." I guess I don't understand Conservative Judaism.
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November 10, 2009
Intermountain Healthcare -- Proof That U.S. Hospitals Can Improve
I urge everyone to read this story by David Leonhardt in this Sunday’s (November 8) New York Times. (Thanks to HealthBeat reader Lisa Lindel for spotting it. )
Leonhardt profiles Intermountain Healthcare, a network of hospitals and clinics in Utah and Idaho that President Obama and others have described as a model for health reform.
Leonhardt concludes:
“If you simply looked at Intermountain’s overall results — the good outcomes and low costs — you might be tempted to dismiss them as a product of the environment. Utah has the youngest population of any state, as well one of the lowest rates of alcohol and tobacco use. More than half of the state’s residents are Mormons. This homogeneity creates a noticeable sense of community, even a sense of mission, among many Intermountain doctors and nurses.
“The places that spend far more on medical care and get worse results — south Texas, south Florida, New York City and its suburbs — don’t have those advantages. They tend to have more diverse populations and a more diverse set of medical needs. None of these places is ever likely to reduce its costs, or raise its life expectancy, to Utah’s levels.
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Certification versus Meaningful Use
Recently, clinicians have asked me "why should I implement my organization's preferred EHR when I've found a less expensive vendor that promises meaningful use?"
This illustrates a basic misunderstanding of the difference between Certification and Meaningful Use.
The certification process will be codified in a December 2009 Notice of Proposed Rulekmaking (NPRM) and will define the process for certifying electronic health records including modular and open source approaches. (The Standards for data exchange will be codified in a December 2009 Interim Final Rule and become law immediately.) We know that ONC will specify certification criteria and that NIST will oversee certification conformance testing which will be performed by multiple organizations. However, we will not have the final certification criteria or the defined process until Spring after a period of comment on the NPRM.
Meaningful Use is about electronic documentation to enhance quality/efficiency and actual data exchange among payers, providers and patients. The definition of meaningful use will be codified in a December 2009 Notice of Proposed Rulemaking. We will not have the final meaningful use criteria until Spring after a period of comment on the NPRM.
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