Request for comments

Attached is a draft of a proposed resolution that I am planning to submit to a professional medical organization. I would be grateful for any comments, particularly as to whether there is agreement or disagreement with the "WHEREAS" statements, but any and all comments would be welcome.

Bruce Wilder

(attachments)

2005_Open.doc (24.5 KB)

Bruce,

The WHEREAS statements seem to be valid, in my opinion of course.
I would suggest, to avoid jargon issues, that you rephrase the first one
as:

WHEREAS, The present Administration has decreed that all medical records
in the United States will be acquired and kept in electronic form (e.g.
an electronic health record often expressed as th acronym; EHR) by the
year 2015; and

I suggest modifying resolution number 1 as follows:

"Promote development and implementation processes that deliver peer
reviewed, open content licensed standards with cross-platform
interoperability."
         
Regards,

What about:

WHEREAS methods for improving the care of patients has always been openly
available for peer review and to provide for dissemination for the greater
good of all....

Kevin

Excellent foundational (logical) proposition.

Bruce Wilder MD MPH JD wrote:

Attached is a draft of a proposed resolution that I am planning to
submit to a professional medical organization. I would be grateful for
any comments, particularly as to whether there is agreement or
disagreement with the "WHEREAS" statements, but any and all comments
would be welcome.

This is clearly intended for a US audience, which I am not, so take my
comments under advisement...

a) The content, to an outsider, seems fine.

b) The language seems terribly legalistic. I thought that US doctors
hated lawyers? Maybe recasting it in medical jargon would make it more
palatable to its intended audience? Or perhaps just plain English?

c) A document pleading for storage of medical records in open source EHR
systems should not itself be distributed in a a close, proprietary
document format such as an MS-Word .doc file. Suggest that you circulate
future copies as a PDF or in OpenDocument format or best of all, as
plain ASCII text.

Tim C

Hello,

I would agree with your statements and conclusions, but would also stress
the expected direct and indirect economic advantages (Estimated by CITL as
at least $78 Billion over the $200 Billion costs identified).

These costs and benefits depend upon various assumptions, and are available
as models.

In addition to your statements on key topics, your audience may appreciate
knowing the amount of attention now focused on interoperability ( i.e.,
ability to connect in meaningful ways many different data models). One
example of modeling integration is the OMG-HL7 workshops being held
(www.omg.org ), an example of standard integration is the Ontolog Panel held
2 weeks ago (
http://ontolog.cim3.net/cgi-bin/wiki.pl?ConferenceCall_2005_08_25 ).

To the extent that open standards, and openEHR platform compatible
applications are used, the transitions to new levels of health data will be
less expensive and more effective.

Regards,

Bob Smith, Ph.D.
Health Ontology Projects
Tall Tree Labs

WHEREAS, The present Administration has decreed that all
medical records in the United States will be acquired and kept
in electronic form by the year 2015; and

This contention may not be that US specific. I suppose, there
is serious thinking in this direction all over. Many other
places like France and Norway, I am told, has much closer
deadlines to achieve the same.

WHEREAS, Open source software has been demonstrated to have at
least the potential for significantly reducing the cost of
developing and maintaining EHR systems;

WHEREAS, Open source has significantly greater potential than
proprietary systems for the effective development and upgrading
of interoperable EHR systems from the ground up; and

I am not certain, whether it would be appropriate to enforce an
Open Source development environment. (Even java is not strictly
open source). This should be left to the implimentors. But the
data formats has to be 100% open, and utilisable by any system,
for now and the future.

Just my POV

Dr USM Bish
Bangalore

Hi Bruce,
I’d like to direct a few high level comments to your 4-part call to action, which appears to be limited to promotion, as opposed to implementation. This makes sense, of course. First the industry would have to understand and embrace these ideas, necessitating a promotional/educational effort before it could even imagine how to implement them. While these ideas are obviously worthy of promotion, the worthiness of any particular promotional effort would seem to depend on which organization was doing the promoting, and which audience it was speaking to… its budget, manpower, and a host of other admin issues. In other words, even the promotion of such ideas begs the consideration a fairly complex business plan.

One also wonders, after the promotion is completed, how the industry will be better prepared than it is today for the implementation phase. Will the promotion inspire an organized effort among providers to carry out what they have promoted? If so, then a completely separate business plan needs to describe the implementation organization, outline its high level mission and vision, its strategic goals and objectives, explain where it will find its intellectual, financial, and other necessary resources… etc, etc.

The spirit of your “manifesto” reminds me of the project that I promoted and worked tirelessly to bring to critical mass within the US Vision care industry between early 2000 and around April of this year, when I finally had to let go of it. I learned a lot during those 5 years about the almost brain-numbing complexity contained within such grand ideas. But my greater and possibly even more helpful insights have been into the underlying human psychology of what is clearly a struggle of epic proportions. I’ll try to summarize that insight at the risk of overwhelming this email.

I see both a Collective Conscious and a Collective Unconscious in play here… with the latter performing a compensatory or balancing function for the former. Both are huge, of course… multinational, in fact. They are also in a state of shadowy conflict with one another. By definition, the unconscious contents of the industry’s collective psyche are invisible to the Industry Organism, itself. This becomes clear to “outside” observers whenever the industry speaks or acts as a collective oneness. Individuals, on the other hand, can often separate themselves momentarily from the “organism psyche”, as most of the people on this list can, and in their capacity as relative “outsiders”, are then able to appreciate these [collectively] unconscious contents. We can also begin to see how the “irrational” points of view of what appears as a largely unconscious Industry Beast are locked in counter-position to the more rational (e.g., computer-modelable or “programmable”) points of view. The result is a state of almost-holy warfare between the “rational” and “irrational” aspects of one whole problem.

To the extent the conflict is between the rational and the irrational, it cannot be resolved. It becomes a “bad marriage” and its differences are forever deemed “irreconcilable”. In healthcare, the “irrational” is pretty much the whole of the process of caring for sick people. The “rational” aspects are the payment/admin models and our efforts to “rationalize” care with evidence-based [“programmable”] care guidelines, structured vocabularies and ontologies of care, etc. Divorce between these dueling adversaries is not something we (the “children” in this “marriage”) are willing to think about. That leaves only reconciliation [of the “irreconcilable”] or prolongation of The War of The Roses!

These are the only two outcomes that I can imagine from the industry’s present warlike state of gridlock: Continued resource-wasting warfare among competing, profit-motivated stakeholders or the emergence of a true consensus-body which is able to literally marry the rational with the irrational… into one, wise, unified Consensus View. An organization (probably growing from the ISO/CEN/UN/CEFACT world) must find a way to emerge… to facilitate this “marriage” in an organic and therefore, lasting way. Commanding and threatening (e.g., the HIPAA approach) by powerful governments is obviously not ever going to work. In fact, that’s the best way to start more wars. What we… essentially, the consciously enlightened mind of the healthcare industry… must do, has never been done on such a grand scale. Not in the last 5000 years, anyway. It’s clear, however, that nothing short of that will help us out of the current mess.

As we move further from the psyches of individual industry observers (who will always be “too small to be taken seriously” and, therefore, to implement anything important), however, and more toward the corporate psyches of “official” representative organizations and governments… that is, as we approach the truly collective Industry Mind with this problem, the more we can see the predominant viewpoints becoming irrational. We see governments, for example, simply “commanding” things like HIPAA and “EHR interoperability by 20-whatever”… without having a clue as to what organization would shepherd such Herculean tasks… and with almost laughable disregard for the costs. I see my own government, for example, spending millions on EHR demonstration projects… and almost nothing on the machinery to create and vet the necessary data standards with coordinated input from doctors.

Obviously, HIPAA is irrational… the tail of a flawed broker/payment model wagging the dog of care. Yet there it still is after 10 years… still the official party-line of my government, one of the largest stakeholders! Have you ever tried to “reason” with a powerful but obviously irrational beast? The best one can hope for is to survive such confrontations… and in order to do even that, he is often obliged to walk away from it. Sometimes, all one can do in good faith to just let the system implode into chaos and then hope that we can pick up the pieces later and make something that works.

Sorry about the Armageddon motif! In summary, I must say that I LOVE your proposed resolution as you have written it. Naturally, I would love to see something like this widely upheld as the Truth and I would love to see a wise organization rise up like the Phoenix and lead us toward the Promised Land of Interoperability and universal access to care. I have yet to see, however, a logical step-wise plan for how to get such a ball rolling. I can imagine how to do it (and have even outlined that image in the form of http://visionebiz.org/ ). I simply cannot imagine how our present industry would implement it.

All the best,
-Chris

Christopher Feahr, OD
(former secretary, Vision E-Business Council)

Would this complicate matters excessively?

WHEREAS worldwide interoperability of medical record systems would
facilitate the care of our citizens abroad and foreign nationals residing in
the United States, and

Couldn't agree with you more. I hope you can get it up in your jurisdiction
as this would be an excellent precedent for the rest of us.
It would be very helpful to start with a standard for electronic storage of
EHRs preferably in a human/machine readable form where such information is
normally human readable.
Regards
Chris Clay
Dermatologist, Australia