healthy4u: CMS

Followup to "CMS does not have any information that supports or refutes claims that a broader adoption of EHRs can save lives"

At my April 16, 2014 post "CMS does not have any information that supports or refutes claims that a broader adoption of EHRs can save lives" (<a href="http://hcrenewal.blogspot.com/2014/04/cms-does-not-have-any-information-that.html">http://hcrenewal.blogspot.com/2014/04/cms-does-not-have-any-information-that.html</a>) I noted that the American Association of Physicians and Surgeons (AAPS) had received a reply from CMS to a FOIA request that: <blockquote class="tr_bq">"We [CMS] do not have any information that supports or refutes claims that a broader adoption of EHRs can save lives." </blockquote> Put another way, the country is embarking on a $1 trillion healthcare experiment, and blindly. I mentioned I'd post the letter when received from AAPS.  That just occurred. The letter is below (click to enlarge): <table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="margin-left: auto; margin-right: auto; text-align: center;"><tbody><tr><td style="text-align: center;"><a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhXyGzY3biU0IcibR_jpNBb18X__sIeFWVd7E3T1MoAa300RBg2N_3-t_UMmx2bhlwk3KnobEgycCWCVmwWTy13uQVLGi3VBPFpgdzCHBu_0Qq5-fDamfZIWx-WeLaeYztcEayTGeCU7JIC/s1600/CMS_Letter.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" height="400" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhXyGzY3biU0IcibR_jpNBb18X__sIeFWVd7E3T1MoAa300RBg2N_3-t_UMmx2bhlwk3KnobEgycCWCVmwWTy13uQVLGi3VBPFpgdzCHBu_0Qq5-fDamfZIWx-WeLaeYztcEayTGeCU7JIC/s1600/CMS_Letter.jpg" width="308" /></a></td></tr><tr><td class="tr-caption" style="text-align: center;">CMS: "we do not have any information that supports or refutes claims that a broader adoption of EHRs can save lives."  [But let's spend hundreds of billions of dollars anyway.]  Click to enlarge. </td></tr></tbody></table> I've added it as an addendum to the original post, but thought it worthwhile to call out the letter in a post of its own to those who might not revisit the original. An additional thought: While CMS may "not have any information that supports or refutes claims that a broader adoption of EHRs can save lives", they do have (or should have made it their business to have) information that EHRs cause harm and take lives (e.g., via FDA at <a href="http://hcrenewal.blogspot.com/2010/08/smoking-gun-internal-fda-memorandum-of.html">http://hcrenewal.blogspot.com/2010/08/smoking-gun-internal-fda-memorandum-of.html</a> , ECRI at <a href="http://hcrenewal.blogspot.com/2013/02/peering-underneath-icebergs-water-level.html">http://hcrenewal.blogspot.com/2013/02/peering-underneath-icebergs-water-level.html</a> and others). -- SS

Followup to "CMS does not have any information that supports or refutes claims that a broader adoption of EHRs can save lives"

At my April 16, 2014 post "CMS does not have any information that supports or refutes claims that a broader adoption of EHRs can save lives" (http://hcrenewal.blogspot.com/2014/04/cms-does-not-have-an…

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26 Apr 2014

Innumeracy at the Centers for Medicare & Medicaid Services (CMS)

<div class="MsoNormal">A physician participant in an American Medical Informatics Association listserv I subscribe to had some time ago commented that the CMS, in their requirement that physicians meet certain percentages on measures regarding adherence to the "Meaningful Use" incentive program for EHRs, were calculating those percentages incorrectly.</div><div class="MsoNormal"> </div><div class="MsoNormal">He followed up with an actual response from CMS, and has given me permission to repost.  I am redacting his name:</div><div class="MsoNormal"> </div><blockquote class="tr_bq"><div class="MsoNormal">... I have posted previously that the CMS calculator found at <a href="https://exchangeweb.drexel.edu/owa/redir.aspx?C=mnsZV_x_TUmIjS3hVz8N2LbSo8knNNEIzqgX1E2MFvWksVZnCP86blNjPEz3cFW5L-p0fS64-Xw.&URL=http%3a%2f%2fwww.cms.gov%2fRegulations-and-Guidance%2fLegislation%2fEHRIncentivePrograms%2fStage_2.html" target="_blank">http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Stage_2.html</a> appears to calculate improperly.  Last night I received a response from CMS regarding my concern:</div><div class="MsoNormal"> </div><div class="MsoNormal" style="margin-left: .5in;">“Dear Mr. (sic) [name redacted],</div><div class="MsoNormal" style="margin-left: .5in;"> </div><div class="MsoNormal" style="margin-left: .5in;">Thank you for your recent inquiry. Below is the information you requested about the attestation calculator.</div><div class="MsoNormal" style="margin-left: .5in;"> </div><div class="MsoNormal" style="margin-left: .5in;">As adopted by CMS, measures generally require that providers achieve "more than" a specific percentage. The language in these measures is clear; "more than 50 percent" would equate to 51 percent or more. This has consistently been the policy from the beginning of the program.</div><div class="MsoNormal" style="margin-left: .5in;"> </div><div class="MsoNormal" style="margin-left: .5in;">The attestation calculator now rounds fractions of a percent to the closest whole number. This correctly identifies when the required performance level is reached.</div><div class="MsoNormal" style="margin-left: .5in;"> </div><div class="MsoNormal" style="margin-left: .5in;">The tracking number for this inquiry is 2014-XXXXX. . . . “</div><div class="MsoNormal"> </div><div class="MsoNormal"> </div><div class="MsoNormal">My examples included a numerator of 549 with a denominator of 10,000 for a metric that required “greater than 5%”.  These are screen shots of the submission:</div></blockquote> <div class="separator" style="clear: both; text-align: center;"><a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhz4oQ46S84r4Sngb24v9Pa9ZGQwMsdKclLNIrq5OxygKMLJGGKhi8FHYQyCVhakiWWGKCj_wYEPDAVkgBA_La0WQxm0UiKpVx9XWgp61BWs_Ot8HivmbQJu11s0bx0yLQlxc0ty6HrHVbX/s1600/calc.jpg" imageanchor="1" style="margin-left: 1em; margin-right: 1em;"><img border="0" height="335" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhz4oQ46S84r4Sngb24v9Pa9ZGQwMsdKclLNIrq5OxygKMLJGGKhi8FHYQyCVhakiWWGKCj_wYEPDAVkgBA_La0WQxm0UiKpVx9XWgp61BWs_Ot8HivmbQJu11s0bx0yLQlxc0ty6HrHVbX/s1600/calc.jpg" width="400" /></a></div> <blockquote class="tr_bq"><div class="MsoNormal"></div><div class="MsoNormal" style="margin-left: .5in;"></div><div class="MsoNormal"> </div><div class="MsoNormal">Note that the calculator appears to use 3 significant figures, but in fact rejects the calculation by rounding to only 1 significant figure.  </div><div class="MsoNormal"> </div><div class="MsoNormal">Years ago at a CMS conference I remember the speaker remarking that physicians and hospitals only had to enter the numbers “and we could agree on the arithmetic.”  I learned in fourth grade how to round numbers, and how to count significant digits.  I do not agree with their arithmetic, nor do I accept their determination that “more than 50 percent" would equate to 51 percent or more”.  Granted, one hopes that those attempting to attest will not have numbers that skim so closely to the metric limit, but it could happen.</div></blockquote><div class="MsoNormal"> </div><div class="MsoNormal">I note in the reply from CMS this statement:</div><blockquote class="tr_bq"><div class="MsoNormal"> </div>"The language in these measures is clear; 'more than 50 percent' would equate to 51 percent or more."</blockquote> I emphasize:    THE - LANGUAGE - IN - THESE - MEASURES - IS - CLEAR. Here are  actual instructions for, say, CPOE measurement on medication ordering (<a href="http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Stage2_EPCore_1_CPOE_MedicationOrders.pdf">http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads/Stage2_EPCore_1_CPOE_MedicationOrders.pdf</a>): <blockquote class="tr_bq">Attestation Requirements DENOMINATOR/NUMERATOR/THRESHOLD/EXCLUSION Measure 1: Medication DENOMINATOR: Number of medication orders created by the EP during the EHR reporting period. NUMERATOR: The number of orders in the denominator recorded using CPOE. THRESHOLD: The resulting percentage must be more than 60 percent in order for an EP to meet this measure. EXCLUSION: Any EP who writes fewer than 100 medication orders during the HER (sic) reporting period. </blockquote> Now, I had a perfect "800" in math on my SAT test in 1974, so (while probably excluding me from some employment in today's culture of stupid due to having "too much experience"), I do believe I am perfectly well qualified to determine that "more than 60 percent" would mean, anything more than 60.0, such as, say, 60.1%. Let's consider possible explanations. Possibility (1) Perhaps CMS is performing their calculations with an old Pentium-1 computer whose CPU has the FDIV bug causing math errors (<a href="http://en.wikipedia.org/wiki/Pentium_FDIV_bug">http://en.wikipedia.org/wiki/Pentium_FDIV_bug</a>)? On second thought: I don't think that is a good explanation. Possibility (2) Perhaps I have become demented from too much exposure to the numeracy-challenged since 1974? An experiment is in order: In 1969, we landed men on the Moon.  It took a lot of math to perform that feat, and miscalculation would have led to disaster, for example on the 25,000-MPH re-entry into Earth's atmosphere at precisely the correct angle required to avoid burn up, or skipping off the atmosphere like a stone off a pond, back out into space to be lost forever. I learned computing about that time on a Digital Equipment Corporation PDP-8/S, a computer from that era (<a href="http://cci.drexel.edu/faculty/ssilverstein/medinformatic1/gw-pdp8s.htm">http://cci.drexel.edu/faculty/ssilverstein/medinformatic1/gw-pdp8s.htm</a>). I wrote and ran a small program on a PDP-8 emulator WinEight (available free at <a href="http://www.sparetimegizmos.com/Software/WinEight.htm">http://www.sparetimegizmos.com/Software/WinEight.htm</a>) that perfectly emulates the old PDP-8.  Here is the program in the programming language FOCAL, 1969 version: <blockquote class="tr_bq">CONGRATULATIONS!! YOU HAVE SUCCESSFULLY LOADED 'FOCAL,1969' ON A PDP-8 COMPUTER. SHALL I RETAIN LOG, EXP, ATN ?:YES PROCEED. *1.1 SET P=(601/1000)*100 *1.2 IF (P-60) 1.3, 1.4, 1.5 *1.3 TYPE "P IS LESS THAN 60%";G 1.6 *1.4 TYPE "P EQUALS 60%";G 1.6 *1.5 TYPE "P IS MORE THAN 60%" *1.6 TYPE !;QUIT</blockquote> The program sets variable "P" to 601/1000, then multiplies by 100 to derive a percent.  It then compares the result stored in "P" to 60, and branches to the correct statement regarding the relation of P to 60%.  Let's run the program: <blockquote class="tr_bq">* *GO P IS MORE THAN 60% *</blockquote> Good news. I guess I am not demented after all. Possibility (3) Someone (or a group of people) at CMS doesn't or don't realize that in large datasets, percentages are often not integer whole numbers. Possibility #3 can be illustrated best by a cartoon: <table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="margin-left: auto; margin-right: auto; text-align: center;"><tbody><tr><td style="text-align: center;"><a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEiCRwf49Ok93IT5g9puPUujkyj3ul4BmKe8A8RqrIo0xa-IaaqSuPQaQrL1HN0B62MUgOK7Lcam4QlpMYcJK7erGTMTlgEUngVZ2fkD5omr5yNOIa8vwH_dDUQNEFcdUckR1lsJtHNkEyXH/s1600/dunce.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" height="200" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEiCRwf49Ok93IT5g9puPUujkyj3ul4BmKe8A8RqrIo0xa-IaaqSuPQaQrL1HN0B62MUgOK7Lcam4QlpMYcJK7erGTMTlgEUngVZ2fkD5omr5yNOIa8vwH_dDUQNEFcdUckR1lsJtHNkEyXH/s1600/dunce.jpg" width="133" /></a></td></tr><tr><td class="tr-caption" style="text-align: center;">Click to enlarge.  1+3 = 13, right?</td></tr></tbody></table> Or perhaps this: <table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="margin-left: auto; margin-right: auto; text-align: center;"><tbody><tr><td style="text-align: center;"><a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEiUDXpKjjMtOtSTY_6Jibyh2Cf2AQJvS5BhjbKbKf43JslhQ3Ly9hKSQNypPSiY2v7EsycBsKEoCNGL3uf8ankUN8BXdRawaP6xZDCyqbNCramZgQkeYYs72OwJQ806XeQiW_JZkQBofhv8/s1600/Butterfinger-math.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" height="152" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEiUDXpKjjMtOtSTY_6Jibyh2Cf2AQJvS5BhjbKbKf43JslhQ3Ly9hKSQNypPSiY2v7EsycBsKEoCNGL3uf8ankUN8BXdRawaP6xZDCyqbNCramZgQkeYYs72OwJQ806XeQiW_JZkQBofhv8/s1600/Butterfinger-math.jpg" width="200" /></a></td></tr><tr><td class="tr-caption" style="text-align: center;">Math for Underachievers.  Click to enlarge.</td></tr></tbody></table> I leave it to the reader to determine which of the three possibilities is the explanation for the assertion by CMS that "The language in these measures is clear; 'more than 50 percent' would equate to 51 percent or more." Note: this post was meant as satire and humor and irony, but innumeracy in our healthcare regulators is anything but funny. -- SS

$Innumeracy at the Centers for Medicare & Medicaid Services (CMS)$

Innumeracy at the Centers for Medicare & Medicaid Services (CMS)

A physician participant in an American Medical Informatics Association listserv I subscribe to had some time ago commented that the CMS, in their requirement that physicians meet certain percentages o…

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25 Apr 2014

CMS does not have any information that supports or refutes claims that a broader adoption of EHRs can save lives?

If this is true, the EHR hyper-enthusiasm problem is even worse than I believed. From the April 2014 newsletter of the American Association for Physicians and Surgeons (<a href="http://www.aapsonline.org/index.php/about_us/">http://www.aapsonline.org/index.php/about_us/</a>), an organization that is dedicated "to preserving the sanctity of the patient-physician relationship and the practice of private medicine": <blockquote class="tr_bq">CMS Claims to Have No Information on EHRs On Mar. 14, 2014, the Office of Strategic Operations and Regulatory Affairs of the Centers for Medicare and Medicaid Services replied to a Freedom of Information Act (FOIA) request sent Apr. 4, 2012:  The American Recovery and Reinvestment Act of 2009 (ARRA) created the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.  While our Office of E-Health Standards and Services works to implement the provisions of the ARRA, we do not have any information that supports or refutes claims that a broader adoption of EHRs can save lives."</blockquote> However, that doesn't stop our government from spending billions of taxpayer dollars on them, when, in fact, we do know of harms they cause.  One can reasonably assume their primary interest is in bookkeeping. With FDA, it's even worse.  Rather than stopping at admitting they simply don't know due to admitted impediments to knowing, they simply leap to a conclusion that the technology is of 'sufficiently low risk' not to warrant their regulatory attention, even if such systems meet the statutory requirements to be a medical device and thus fall under the Food, Drug & Cosmetic Act. See my Apr. 9, 2014 post "FDA on health IT risk: We don't know the magnitude of the risk, and what we do know is the tip of the iceberg, but health IT is of 'sufficiently low risk' that we don't need to regulate it" and its ten-point (and non-comprehensive) summary of risks: <a href="http://hcrenewal.blogspot.com/2014/04/fda-on-health-it-risk-reckless-or.html">http://hcrenewal.blogspot.com/2014/04/fda-on-health-it-risk-reckless-or.html</a>.  Another FOIA request is surely needed... More generally, I know from personal development and implementation experience that when "done well", that is, when good health IT and good implementation practices are offered and with patient safety as a priority, health IT can save lives and improve care.  It's just that the commercial for-profit health IT sector does not meet those expectations, due largely to its leadership model from the merchant-computing culture.  Instead, bad health IT is the norm.  From my academic site at <a href="http://cci.drexel.edu/faculty/ssilverstein/cases/">http://cci.drexel.edu/faculty/ssilverstein/cases/</a>: <blockquote class="tr_bq">Good Health IT is IT that provides a good user experience, enhances cognitive function, puts essential information as effortlessly as possible into the physician’s hands, can be easily, substantively and cost-effectively customized to the needs of medical specialists and subspecialists, keeps eHealth information secure, protects patient privacy and facilitates better practice of medicine and better outcomes. Bad Health IT is IT that is ill-suited to purpose, hard to use, unreliable, loses data or provides incorrect data, is difficult and/or prohibitively expensive to customize to the needs of different medical specialists and subspecialists, causes cognitive overload, slows rather than facilitates users, lacks appropriate alerts, creates the need for hypervigilance (i.e., towards avoiding IT-related mishaps) that increases stress, is lacking in security, compromises patient privacy or otherwise demonstrates suboptimal design and/or implementation. </blockquote>  I am seeking source material from the AAPS and will post it. -- SS April 26, 2014 Addendum: Below is the letter to AAPS from CMS.  Click to enlarge. <table align="center" cellpadding="0" cellspacing="0" class="tr-caption-container" style="margin-left: auto; margin-right: auto; text-align: center;"><tbody><tr><td style="text-align: center;"><a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEiSrd8gxZN0QHQd4cLK_aeA3uDI-a9I__6VVZfa32Gz6iCAm8Y-r2APJEzYw_Mav9oJSOWtFXXJYCz3iIELuUPqiJtPt_xtwa1k4hzcXTmEwYOhHSHKmfx6bGUSrXInxG2ax_nK15KLDeDV/s1600/CMS_Letter.jpg" imageanchor="1" style="margin-left: auto; margin-right: auto;"><img border="0" height="400" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEiSrd8gxZN0QHQd4cLK_aeA3uDI-a9I__6VVZfa32Gz6iCAm8Y-r2APJEzYw_Mav9oJSOWtFXXJYCz3iIELuUPqiJtPt_xtwa1k4hzcXTmEwYOhHSHKmfx6bGUSrXInxG2ax_nK15KLDeDV/s1600/CMS_Letter.jpg" width="308" /></a></td></tr><tr><td class="tr-caption" style="text-align: center;">CMS:  "we do not have any information that supports or refutes claims that a broader adoption of EHRs can save lives."  [But let's spend hundreds of billions of dollars anyway.]  Click to enlarge. </td></tr></tbody></table> An additional thought: While CMS may "not have any information that supports or refutes claims that a broader adoption of EHRs can save lives", they do have (or should have made it their business to have) information that EHRs cause harm and take lives (e.g., via FDA at <a href="http://hcrenewal.blogspot.com/2010/08/smoking-gun-internal-fda-memorandum-of.html">http://hcrenewal.blogspot.com/2010/08/smoking-gun-internal-fda-memorandum-of.html</a> , ECRI at <a href="http://hcrenewal.blogspot.com/2013/02/peering-underneath-icebergs-water-level.html">http://hcrenewal.blogspot.com/2013/02/peering-underneath-icebergs-water-level.html</a> and others). -- SS

CMS does not have any information that supports or refutes claims that a broader adoption of EHRs can save lives?

If this is true, the EHR hyper-enthusiasm problem is even worse than I believed.From the April 2014 newsletter of the American Association for Physicians and Surgeons (http://www.aapsonline.org/index.…

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16 Apr 2014

Former FDA Commissioner, CMS Administrator McClellan adds Johnson and Johnson Board Membership to Positions with General Atlantic LLC, Capital Royalty, Castlight Health, and AvivReit

Our latest example of the interchangeability of top insiders within corporate health care and the government agencies that are supposed to regulate corporate health care comes via an <a href="http://www.investor.jnj.com/releaseDetail.cfm?ReleaseID=796836&year=2013">announcement</a> from Johnson and Johnson, <blockquote class="tr_bq">Johnson & Johnson (NYSE: JNJ) announced today that Mark B. McClellan, M.D., Ph.D., Senior Fellow in Economic Studies, and Director of the Initiative on Value and Innovation in Health Care, Brookings Institution, will join the Board of Directors on October 15, 2013.  Dr. McClellan will serve on the Regulatory, Compliance & Government Affairs Committee and the Science, Technology & Sustainability Committee of the Board. As former commissioner of the U.S. Food and Drug Administration (FDA) from 2002 to 2004, and as the former administrator of the Centers for Medicare & Medicaid Services for the U.S. Department of Health and Human Services from 2004 to 2006, Dr. McClellan has more than two decades of public service and academic research experience. From 2001 to 2002, he served as a member of the President's Council of Economic Advisers and senior director for health care policy at the White House. During President William J. Clinton's administration, Dr. McClellan held the position of deputy assistant secretary of the Treasury for economic policy.</blockquote> So Dr McClellan has gone from running the US Food and Drug Administration, the primary government regulator of the pharmaceutical industry, to stewardship of one of the biggest pharmaceutical (and biotechnology and device) companies. Not noted in that announcement was that Dr McClellan has been collecting positions in health care corporations since at least 2009.  The examples I found included in chronological order: 2009 - General Atlantic LLC This appears to be a private equity firm which <a href="http://www.generalatlantic.com/about-us/a-proud-legacy/">claims</a> to be a "leading global investment firm." From a 2010 a Mergers & Acquisitions <a href="http://www.themiddlemarket.com/news/General-Atlantic-Adds-Healthcare-Vet-201877-1.html">article</a>, <blockquote class="tr_bq">A year ago, the firm hired Dr Mark McClellan, previously a commissioner of the Food & Drug Administration, to its healthcare practice as a special advisor.</blockquote> According to the firm's <a href="http://www.generalatlantic.com/people/special-advisors/">current website</a>, he is still a special advisor.   2010 - Capital Royalty LP In a 2010 <a href="http://www.capitalroyalty.com/news/item/firm-news/capital-royalty-establishes-strategic-advisory-committee/">press release</a>, this apparently private equity firm claimed to be <blockquote class="tr_bq">a market pioneer and innovator in healthcare investing with a focus on intellectual property investments in FDA-approved biopharmaceutical assets</blockquote> In that release, it announced the creation of a Strategic Advisory Committee that included Dr Mark McClellan.  He <a href="http://www.capitalroyalty.com/about-us/strategic-advisory-committee/dr.-mark-mcclellan-md-phd/">still sits</a> on that committee.  2012 - Castlight Health In a 2012 <a href="http://www.castlighthealth.com/2012/mark-mcclellan-joins-castlight-health%E2%80%99s-advisory-board/">press release</a>, this firm claimed to be <blockquote class="tr_bq">developer of a personalized health care shopping portal offering unbiased information about health care cost and quality</blockquote> That press release announced the addition of Dr McClellan to the firm's Advisory Board, <a href="http://www.castlighthealth.com/company/advisory-board/">on which</a> he still sits.  2013 - AvivReit This firm "specializes in the ownership and triple-net leasing of post-acute and long-term care skilled nursing facilities (SNFs)" per its <a href="http://www.avivreit.com/about-aviv/">website</a>. Dr McClellan is currently on its <a href="http://ir.avivreit.com/od.aspx?iid=4328838">board of directors</a>.  He apparently was appointed in 2013.  Notably, I did not see anything in any of these firms' announcements about Dr McClellan or their biographies of him that noted his board or advisory committee positions with other firms. Summary Dr Mark McClellan rose through the ranks in the US executive branch ending with positions as FDA commissioner and administrator of the Center for Medicare and Medicaid Services (CMS) within the Department of Health and Human Services (DHHS).  He served under two presidents, Clinton and George W Bush.  Within 3 years of exiting DHHS, he picked up his first important commercial position, at General Atlantic LLC, and then added other positions with Capital Royalty, Castlight Health, AvivReit, and now the biggest of all, Johnson and Johnson.  Meanwhile he apparently continues at the Brookings Institution.  He must be one very busy man. This case could be lumped with those of another former FDA commissioner and Secretary of Health and Human Services who ended up as a Director of Medtronic (see <a href="http://hcrenewal.blogspot.com/2011/10/former-us-secretary-of-health-and-human.html">this post</a>),  another Secretary of DHHS who ended up on the boards of multiple health care corporations (see <a href="http://hcrenewal.blogspot.com/2011/06/embedded-networks-of-influence-in.html">this post</a>), a director of the National Institutes of Health (NIH) who became a Sanofi executive, etc, etc (see <a href="http://hcrenewal.blogspot.com/2010/12/former-nih-director-spins-trhough.html">this post</a>). While some might argue whether his acquisition of a leading advisory position with a private equity firm three years after he left DHHS technically constituted a spin through the <a href="http://hcrenewal.blogspot.com/search/label/revolving%20doors">revolving door</a>, Dr McClellan's cumulative acquisition of four more such positions within the following four years certainly demonstrates how our corporate dominated health care system and the government agencies which are supposed to be regulating it to assure the health and safety of patients, and the maintenance of the public health seem to be run by an interchangeable cast of insiders.  We have asked before whether we can trust federal regulators to put patients' and the public's health first when they know they could easily become  candidates for lucrative private positions in the companies they regulate, or which are affected by their regulations, presumably assuming they have not done too much during their time in government to offend the leaders of such companies. We have noted that the system in which government and big corporations largely overlap in terms of their leadership and presumably goals is called <a href="http://hcrenewal.blogspot.com/search/label/corporatism">corporatism</a>.  One can argue that such systems end up being run primarily for the benefit of corporate and government insiders.  Until we dispel the fog of corporatism that has spread over the government that was once supposed to be of the people, by the people, and for the people, expect no real health care reform, and expect continuing rising costs, declining access, and worsening patient care. Obviously, true health care reform would start with the government and its officials putting patients' and the public's health first, way ahead of the financial comfort of corporate leaders. I would note that neither the currently controversial and now operational Affordable Care Act, nor any of its opponents schemes for alternatives addresses this issue. by Roy M. Poses MD for Health Care Renewal

Former FDA Commissioner, CMS Administrator McClellan adds Johnson and Johnson Board Membership to Positions with General Atlantic LLC, Capital Royalty, Castlight Health, and AvivReit

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18 Oct 2013

The Scientific Justification for Meaningul Use, Stage 2: The NWB Methodology

The Final Rule for Meaningful Use Stage 2 has been released.  It is at <a href="http://www.ofr.gov/OFRUpload/OFRData/2012-21050_PI.pdf" target="_blank">this link</a> (PDF).  It is a mere 672 pages in length, a quick read during one's evenings of leisure. Here is, from page 18 verbatim, the scientific justification for the program.  The finest scientific methods were used to achieve these criteria in justification of spending of $15 billion of taxpayer money in "incentives" (probably a low estimate), not counting the additional hundreds of billions the buyers themselves will spend that is diverted from your healthcare to the IT sector: <blockquote class="tr_bq">3. Summary of Costs and Benefits This final rule is anticipated to have an annual effect on the economy of $100 million or more, making it an economically significant rule under the Executive Order and a major rule under the Congressional Review Act. Accordingly, we have prepared a Regulatory Impact Analysis that to the best of our ability presents the costs and benefits of the final rule. The total Federal cost of the Medicare and Medicaid EHR Incentive Programs between 2014 and 2019 is estimated to be $15.4 billion (these estimates include net payment adjustments for Medicare providers who do not achieve meaningful use in 2015 and subsequent years in the amount of $2.1 billion). In this final rule we have not quantified the overall benefits to the industry, nor to EPs, eligible hospitals, or CAHs participating in the Medicare and Medicaid EHR Incentive Programs. Information on the costs and benefits of adopting systems specifically meeting the requirements for the EHR Incentive Programs has not yet been collected and information on costs and benefits overall is limited.  Nonetheless, we believe there are substantial benefits that can be obtained by eligible hospitals and EPs, including reductions in medical recordkeeping costs, reductions in repeat tests, decreases in length of stay, increased patient safety, and reduced medical errors. There is evidence to support the cost-saving benefits anticipated from wider adoption of EHRs.</blockquote> There's no truly robust evidence of generalizable benefit, no randomized trials, there's <a href="http://hcrenewal.blogspot.com/2011/02/updated-reading-list-on-health-it.html" target="_blank">significant evidence to the contrary</a> (that, incidentally, is deliberately being ignored), there's risk to safety that this disruptive technology causes in its present state (but the magnitude is unknown, see quotes from 2012 IOM study <a href="http://hcrenewal.blogspot.com/2012/03/doctors-and-ehrs-reframing-modernists-v.html" target="_blank">here</a>) that MU and "certification" <a href="http://hcrenewal.blogspot.com/2012/02/hospitals-and-doctors-use-health-it-at.html" target="_blank">do not address</a>, there's a plethora of <a href="http://hcrenewal.blogspot.com/2011/01/maude-and-hit-risk-mother-mary-what-in.html" target="_blank">hair-raising defect reports</a> from the only seller that reports such things, but CMS justifies the program with the line: <blockquote class="tr_bq">"Evidence [on benefits] is limited ... Nonetheless, we believe there are substantial benefits that can be obtained by eligible hospitals and EPs ... There is evidence to support the cost-saving benefits anticipated from wider adoption of EHRs."</blockquote> I am deeply impressed by the level of rigorous science here.  We are truly in a golden age of science. I recommend NIH, NSF, FDA and all other research and regulatory agencies immediately adopt this rigorous HHS methodology (called the "NWB" methodology for "nonetheless we believe") in their professional pursuits and research grant approval processes. -- SS

The Scientific Justification for Meaningul Use, Stage 2: The NWB Methodology

The Final Rule for Meaningful Use Stage 2 has been released. It is at this link (PDF). It is a mere 672 pages in length, a quick read during one's evenings of leisure.Here is, from page 18 verbatim,…

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29 Aug 2012

Divide by Zero: Weird Math in CMS Clinical Quality Measure (CQM) Criteria

From the CMS "<a href="https://www.cms.gov/EHRIncentivePrograms/Downloads/EP_Attestation_User_Guide.pdf">Medicare Electronic Health Record (EHR) Incentive Program - ATTESTATION USER GUIDE For Eligible Professionals (EPs)</a>" (warning: large PDF), page 41/64: <blockquote>... Step 25 – Core Clinical Quality Measures (CQMs 1 of 3) EPs must report calculated CQMs directly from their certified EHR technology as a requirement of the EHR Incentive Programs. Each EP must report on three core CQMs (or alternate core) and three additional quality measures. If one or more core CQMs is outside your scope of practice, you will have to report on an equal number of alternate core CQM(s). If the denominator value for all three of the core CQMs is zero, an EP must report a zero denominator for all such core measures, and then must also report on all three alternate core CQMs. If the denominator value for all three of the alternate core CQMs is also zero an EP still needs to report on three additional clinical quality measures. Zero is an acceptable denominator provided that this value was produced by certified EHR technology.</blockquote> Now, while I had an "800" in the math section of the SAT, where I believed that a fraction with a denominator of zero had a value of either infinity or 'undefined', that was many moons ago. Perhaps my knowledge of mathematics is now obsolete... Wait - I tried this simple program on an old Microsoft MS-DOS GWBASIC interpreter, ported ca. 1981 to the Intel 8086/88 from Bill Gates' original 8080-based MBASIC, that I have laying around on my PC: <blockquote>10 INPUT X 20 LET Y=X/0 30 PRINT Y 40 END</blockquote> and got this warning/error message, right from Bill Gates: "Division by zero" and the answer: 1.701412E+38 (infinity in the 8/16-bit world from where GWBASIC sprang). So ... allow me to say I find CMS math just a bit puzzling. Wait ... now I understand. Infinite quality! :-) But thank heavens the zero denominator is only accepted when produced by <a href="http://hcrenewal.blogspot.com/2012/02/hospitals-and-doctors-use-health-it-at.html">'certified' health IT</a>. Uncertified health IT is liable to produce a denominator of "i" (that is, the square root of -1). -- SS Addendum: since I am not a government math genius, I checked with <a href="http://en.wikipedia.org/wiki/Fraction_%28mathematics%29">Wikipedia</a>: <blockquote> ... A common fraction (also known as a vulgar fraction or simple fraction) is a <a href="http://en.wikipedia.org/wiki/Rational_number" title="Rational number">rational number</a> written as a/b or <img alt="\tfrac{a}{b}" class="tex" src="http://upload.wikimedia.org/wikipedia/en/math/e/c/3/ec3e447b2dcda3eb68860a5cb3780bf7.png" />, where the <a href="http://en.wikipedia.org/wiki/Integer" title="Integer">integers</a> a and b are called the numerator and the denominator, respectively.<a href="http://en.wikipedia.org/wiki/Fraction_%28mathematics%29#cite_note-0">[1]</a> The numerator represents a number of equal parts and the denominator, which cannot be zero, indicates how many of those parts make up a unit or a whole.</blockquote> -- SS Addendum: This post is partly satire. I was a day late for April 1 but... -- SS

$Divide by Zero: Weird Math in CMS Clinical Quality Measure (CQM) Criteria$ Divide by Zero: Weird Math in CMS Clinical Quality Measure (CQM) Criteria

From the CMS "Medicare Electronic Health Record (EHR) Incentive Program - ATTESTATION USER GUIDE For Eligible Professionals (EPs)" (warning: large PDF), page 41/64:... Step 25 – Core Clinical Quality …

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02 Apr 2012

The Center for Medicare and Medicaid Services' Quiet Coziness with Wall Street

An <a href="http://www.pogo.org/pogo-files/alerts/government-corruption/wall-street-in-washington-gc-ii-20111208.html">article</a> from the Project on Government Oversight (POGO) reveals a new aspect of the growing coziness between the US government and big corporations with obvious relevance to health care. CMS' Coziness with Leaders of the "Capital Markets" Here is the introduction and the example most relevant to health care: <blockquote>Nearly a dozen senior staff at the Centers for Medicare and Medicaid Services (CMS), the giant agency that administers hundreds of billions in federal health care dollars, had been called to a meeting. After a discussion with five Wall Street professionals that lasted nearly two hours, one senior CMS analyst filed an ethics complaint that later went to the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS). His beef: that a handful of deep-pocketed investors had won a private hearing to probe whether the agency would allow Medicare reimbursement for specific medical devices manufactured by companies in which they already held a stake or might put new money. The market for one device, already approved for Medicare, was rapidly heading toward $1 billion annually; the agency’s impending decision to reimburse competing devices could have major market impact, a shift potentially worth hundreds of millions of dollars. 'This meeting forced agency staff to redirect their attention toward a select group from Wall Street, when neither competing investors nor patient-oriented stakeholders were present,' the whistleblower told the Project On Government Oversight (POGO). 'They got to probe us for hours in private about what we planned to do and how we approached procedures for reimbursing medical devices, the mechanics and psychology of CMS decision-making, in general and with respect to these specific devices.' The meeting was set up by a former CMS employee working for the Marwood Group, an asset manager that counsels big health-care industry investors, the whistleblower says. The firm’s president is Edward 'Ted' Kennedy Jr., son of the late Massachusetts senator and a major supporter of President Obama’s health care reforms, and includes Kennedy cousins Robert F. Kennedy, Jr. and Stephen E. Smith, Jr., as senior advisors. The firm’s website highlights its staff recruitment among Congressional aides, the Executive Office of the President and CMS. One CMS veteran who joined Marwood after the 2009 meeting with Wall Streeters is Barry Straub, the agency's former Chief Medical Officer, who is also an expert on Medicare reimbursement, the website says. A company spokesman had no comment. A supervisor at CMS’s Coverage Advisory Group, which decides which services the agency will pay for, also helped organize the session with investors. The whistleblower says he was told by a supervisor that such get-togethers are 'a routine practice at CMS.' At the time, in 2009, CMS’s top administrator had an aide with the title, 'capital markets advisor,' tasked with tracking investment community activity in Washington and elsewhere. At the investor meeting, Wall Streeters asked a range of questions 'about confidential CMS information.' The whistle blower says he does not believe they received illegal disclosures, though they peppered CMS analysts with queries about the agency’s decision-making process and other sensitive matters which, if answered, could have violated the law or related regulations that bar the sharing of internal deliberations and decisions. The whistleblower first filed his complaint in April 2009. He was terminated in 2011 for being disloyal to the agency mission after he made a series of internal protests, including the objection to what he calls a pattern and practice of unfettered access to CMS staff by Wall Street investors. He says he is currently fighting his dismissal through all available legal and administrative channels. </blockquote>Implications and Summary As the POGO article put it, <blockquote>CMS does have a set of 'Open Door' policies and affords a variety of avenues for public access. The disclosure of payments to physicians and teaching hospitals by pharmaceutical companies and other interests are required under President Obama’s health reform. In practice, however, the public, not to mention competing investors and stakeholders, rarely get the kind of information and insight available in meetings like the whistleblower described.</blockquote> In general, <blockquote>A balance is necessary between the danger of too much insider access, and imposing excessive limitations. Indeed, the biggest problem with special access for Wall Street insiders is not just that they seem to get meetings and acquire information that may be privileged and non-public, but that others, including other investors, do not get a crack at the same material.</blockquote>The activities above have all the usual elements of excess corporate - government coziness.  These include enhanced access for corporate leaders beyond what any ordinary members of the public might achieve; the <a href="http://hcrenewal.blogspot.com/search/label/revolving%20doors">revolving door</a> between government service and corporate leadership; the participation of well-connected inside the beltway types, etc, etc.  It also includes the apparent formalization of representation of corporate interests, e.g., the "Capital Markets Advisor," with no parallel formalization of the public's or patients' interests.  Even more worrisome is that an effort to make this all less <a href="http://hcrenewal.blogspot.com/search/label/anechoic%20effect">anechoic</a> resulted in alleged intimidation of a <a href="http://hcrenewal.blogspot.com/search/label/whistle-blowers">whistle-blower</a>. So, let's see, CMS, the Center for Medicare and Medicaid Services, the US Department of Health and Human Services (DHHS) branch which controls the Medicare and Medicaid programs, the government run single-payer programs for the elderly, the disabled, and the poor, does not seem to be able to afford to figure out in-house how to pay physicians for specific services.  Instead, it has effectively farmed out this task to a private committee, the American Medical Association's <a href="http://hcrenewal.blogspot.com/search/label/RUC">RBRVS Update Committee (RUC</a>).  As we have <a href="http://hcrenewal.blogspot.com/search/label/RUC">discussed many times</a>, this obscure and secretive committee likely had a major role in structuring the financial incentives that favor procedures and disfavor primary care. leading to excess costs, declining access, and degrading quality.  However, CMS can afford to have a "Capital Markets Adviser" and to use up staff time briefing wealthy investors and hedge fund types.  What is wrong with this picture? In my humble opinion, government health care agencies ought to put the public's and patient's health first. They should not give special consideration to the rich, the powerful, the well-connected, whom some now call the one percent. Yet in the US we seem to have an increasingly <a href="http://hcrenewal.blogspot.com/search/label/corporatism">corporatist</a> state in which government and the plutocrats work together for their mutual interests, regulatory capture writ large. We need to restore government, and our health care agencies to being of the people, by the people, and for the people.  Obviously, true health care reform would start with the government and its officials putting patients' and the public's health first, way ahead of the financial comfort of corporate leaders.

The Center for Medicare and Medicaid Services' Quiet Coziness with Wall Street

An article from the Project on Government Oversight (POGO) reveals a new aspect of the growing coziness between the US government and big corporations with obvious relevance to health care.CMS' Cozine…

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09 Dec 2011

Novel Idea on Healthcare IT: Worth a Billion Dollars!

From an <a href="http://www.amia.org/">AMIA</a> announcement: <blockquote>CMS Innovation Center Announces $1 Billion Funding Opportunity: CMS announced a new initiative, the Health Care Innovation Challenge, which will provide grants for new ideas to improve care and lower costs for those in Medicare, Medicaid and CHIP. CMS will award up to $1 billion in grants for a 3 year period and is encouraging providers, payers, local government, public-private partnerships and multi-payer collaboratives to develop new and innovative ways to improve care. To learn more about the grants and application process, check out the CMS Innovation Center website and be sure to register for the CMS webinar on Thursday.</blockquote> CMS, I have an idea! It's a really, really novel idea! "Let's regulate HIT to improve its safety, usability, usefulness, fitness for purpose, effectiveness, etc." ™ That will lower healthcare costs! Save lives, too! ---------------------------------- Can I have my Billion Dollars now? <div style="text-align: center;"><a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhhinLWA0LEqtIx0hVUJ7BPLp62RwF2t6YjMjk5lObwSrXxX4ixGktTylUJpX3p3Fs1ty_pliiW-F7mrn6m4CFH1GqwZ4cfVYxz-97Vv0EJUIKBKGhfWEZr2hwI8k42p1RGUSDY2Q-L4TEW/s1600/Billion_Front.jpg"><img alt="" border="0" id="BLOGGER_PHOTO_ID_5675578351849844338" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhhinLWA0LEqtIx0hVUJ7BPLp62RwF2t6YjMjk5lObwSrXxX4ixGktTylUJpX3p3Fs1ty_pliiW-F7mrn6m4CFH1GqwZ4cfVYxz-97Vv0EJUIKBKGhfWEZr2hwI8k42p1RGUSDY2Q-L4TEW/s320/Billion_Front.jpg" style="display: block; margin: 0px auto 10px; text-align: center; cursor: pointer; width: 310px; height: 134px;" /></a>You can do a lot in health IT with a billion dollars - if you're not the HIT industry, that is, that has squandered a large wad of these over the past several decades. </div> -- SS

Novel Idea on Healthcare IT: Worth a Billion Dollars!

From an AMIA announcement:CMS Innovation Center Announces $1 Billion Funding Opportunity:CMS announced a new initiative, the Health Care Innovation Challenge, which will provide grants for new ideas t…

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16 Nov 2011

Another Blow to the Health IT Idealists: Sony CEO Howard Stringer, and HHS OIG, on Information Security

In a series of Healthcare Renewal posts such as those linked below, I pointed out that healthcare IT information security was largely a pipe dream, and that plans to create a national network of health information, while a seductive idea dating to the beginnings of computer networking, is not a good idea now. <ul><li>"<a href="http://hcrenewal.blogspot.com/2010/02/networked-emrs-and-healthcare.html">Networked EMR's and Healthcare Information Security: Practical When Massive IT Security Breaches Continue</a>?",</li></ul><ul><li>"<a href="http://hcrenewal.blogspot.com/2010/02/networked-interoperable-secure-national.html">Networked, Interoperable, Secure National Medical Records a Castle in the Sky?</a>",</li></ul><ul><li>"<a href="http://hcrenewal.blogspot.com/2010/01/it-flaws-and-coverups-of-same-why-i.html">Operation Aurora And a Widespread Reluctance to Discuss IT Flaws: Is Universal Healthcare IT Really a Good Idea in 2010?</a>",</li></ul><ul><li>"<a href="http://hcrenewal.blogspot.com/2010/10/medical-data-breach-of-week-but-your.html">Medical data breach of the week - but your EMR data is secure, trust us, we're IT experts</a>", </li></ul><ul><li>"<a href="http://hcrenewal.blogspot.com/2010/11/insurers-test-data-profiles-to-identify.html">Insurers Test Data Profiles to Identify Risky Clients</a>",</li></ul><ul><li>and <a href="http://hcrenewal.blogspot.com/search/label/medical%20record%20privacy">others</a></li></ul> Now you can hear it from another source: The CEO of one of the world's largest electronic companies, Sony. Emphases mine: <a href="http://online.wsj.com/article/SB10001424052748703421204576328982377107892.html"></a><blockquote><a style="font-weight: bold;" href="http://online.wsj.com/article/SB10001424052748703421204576328982377107892.html">Sony CEO Warns of 'Bad New World' </a> Wall Street Journal May 8, 2011 TOKYO—After spending weeks to resolve a massive Internet security breach, <a href="http://online.wsj.com/public/quotes/main.html?type=djn&symbol=SNE" class="companyRollover link11unvisited">Sony</a> Corp. Chief Executive <a href="http://topics.wsj.com/person/s/howard-stringer/243" class="topicLink">Howard Stringer</a> said he can't guarantee the security of the company's videogame network or any other Web system in the "bad new world" of cybercrime. Mr. Stringer's comments in a phone interview Tuesday, ahead of a New York roundtable discussion with reporters, come on the heels of a trying month for Sony. The company partially restored two of its online game systems and a streaming movie and music service over the weekend after shutting the services for several weeks when a breach compromised the personal information of more than 100 million account holders. While Sony has restored part of the PlayStation Network—an online game system for its PlayStation 3 videogame console—in the U.S. and Europe and bolstered security measures, Mr. Stringer, 69 years old, said maintaining the service's security is a "never-ending process" and he doesn't know if anyone is "100% secure." He said the security breach at PSN, Sony Online Entertainment, an online game service for personal-computer users, and its Qriocity streaming video and music network his company could lead the way to bigger problems well beyond Sony, or the gaming industry. He warned hackers may one day target the global financial system, the power grid or air-traffic control systems. [And healthcare, where identity theft, data alteration, and data destruction might occur - ed.] <div style="overflow: hidden; text-decoration: none; border: medium none;"> <div style="overflow: hidden; text-decoration: none; border: medium none;"></div></div></blockquote><div style="overflow: hidden; text-decoration: none; border: medium none;"><div style="overflow: hidden; text-decoration: none; border: medium none;"> I really don't think this is the time to be setting up a national health information network. Beyond that, I offer no additional comments, other than that regarding the impossibility of keeping healthcare information secure on a national or even regional network, you may have heard it first here at Healthcare Renewal. It would be prudent and consistent with the Hippocratic Oath to tone down our grandiose expectations and grandiose plans for these technologies in healthcare. If you feel insecure yet, just wait a moment. Going from very, very bad to very much worse: An independent audit of ONC's and CMS's security programs by the HHS OIG (Office of the Inspector General) produced concerning if not alarming results to say the least: <a href="http://www.healthleadersmedia.com/content/FIN-266313/HIT-Security-Problems-Found-at-CMS-ONC"></a><blockquote><a style="font-weight: bold;" href="http://www.healthleadersmedia.com/content/FIN-266313/HIT-Security-Problems-Found-at-CMS-ONC">Federal Audits Find HIT Security Problems at CMS, ONC </a> John Commins, for HealthLeaders Media May 18, 2011 Audits of the federal agencies charged with implementing and monitoring security measures for healthcare information technology identified this week lax oversight and insufficient standards for healthcare providers. The audits were conducted by the Department of Health and Human Services' Office of Inspector General, and targeted HIT security standards, privacy protection under HIPAA, and other security measures at the Centers for Medicare & Medicaid Services, and the Office of the National Coordinator. "These two reports are being issued simultaneously because OIG found weaknesses in the two HHS agencies entrusted with keeping sensitive patient records private and secure," OIG said in a media release. The CMS audit, Nationwide Rollup Review of the Centers for Medicare & Medicaid Services Health Insurance Portability and Accountability Act of 1996 Oversight, examined seven hospitals across the country and found 151 "vulnerabilities" in systems and controls that are designed to safeguard electronic protected health information. Those lapses included 124 "high impact vulnerabilities" such as unencrypted laptops and portable drives containing sensitive personal health information, outdated antivirus software and patches, unsecured networks, and the failure to detect rogue devices intruding on wireless networks, the OIG audit said. "These vulnerabilities placed the confidentiality, integrity, and availability of ePHI at risk. Outsiders or employees at some hospitals could have accessed, and at one hospital did access, systems and beneficiaries' personal data and performed unauthorized acts without the hospitals' knowledge," the OIG audit said. "As a result, CMS had limited assurance that controls were in place and operating as intended to protect electronic protected health information, thereby leaving ePHI vulnerable to attack and compromise. OIG's Audit of Information Technology Security Included in Health Information Technology Standards examined ONC's mandate under the HITECH Act to develop HIT security as part of a national HIT interoperability infrastructure. The audit found "no HIT standards that included general information IT security controls … which provide the structure, policies, and procedures that apply to a healthcare provider's overall computer operations, ensure the proper operation of information systems [which obviously also impacts patient safety - ed.], and create a secure environment for application systems and controls.</blockquote> That's not very reassuring. In fact, it is downright frightening. ONC has to learn such lessons from HHS OIG? Read the whole thing.I somewhat mordantly note that organizations such as ONC and CMS would probably never hire a person like me, who might actually kick-start true critical thinking on these issues. This is due to my non-bien pensant "bad attitudes", and lack of faith in cybernetic idols. <a href="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEgmnwU_sH88Ham6kL2ikFt88_2qx899yg4zsSynC9_sggBBClRDUYMxnZnxfE06yrPqWhz7crbwSYQdkbQc8scVnH0kyg5Y9-g4MUsvHlEcswajJ_WzalDVaLBTGwwOB4RJ7rim6pJZRmDD/s1600/golden_calf.jpg"><img alt="" border="0" id="BLOGGER_PHOTO_ID_5608090912264648962" src="https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEgmnwU_sH88Ham6kL2ikFt88_2qx899yg4zsSynC9_sggBBClRDUYMxnZnxfE06yrPqWhz7crbwSYQdkbQc8scVnH0kyg5Y9-g4MUsvHlEcswajJ_WzalDVaLBTGwwOB4RJ7rim6pJZRmDD/s320/golden_calf.jpg" style="display: block; margin: 0px auto 10px; text-align: center; cursor: pointer; width: 305px; height: 217px;" /></a>Click to enlarge. A well-known idol of gold. Computer circuits use gold, no? -- SS </div></div>

Another Blow to the Health IT Idealists: Sony CEO Howard Stringer, and HHS OIG, on Information Security

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18 May 2011

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