In response to Joseph Conn's "RTI report includes controversial EHR requirement":
Thank you very much for providing coverage and exposure to this important report. First, as voluntary chairman of the prevention work group for the report, I can assure you and your readers that the concept voiced in your article that fraud prevention and data quality improvement were not central objectives is wrong.
Reference to the two earlier reports will help substantiate the context, especially the second, entitled "Report on the Use of Health Information Technology to Enhance and Expand Health Care AntiFraud Activities." If further proof is of interest, I am sure the Office of the National Coordinator will oblige.
Speaking then as a volunteer participant in this and a number of efforts aimed at assuring data quality and information integrity in the electronic health-record realm, the importance of this report cannot be underestimated. For various historical reasons, fundamental and well-established principles for how business records (including medical records) must be created and managed in electronic environments have not been highest priorities in the EHR marketplace. An unintended consequence has been the persistence in the marketplace of EHRs that may have difficulty meeting well-established requirements for how medical records are created and managed. One example from my firm's product research is that some EHRs may not show the original content of a medical record that has been amended or corrected. Of greater concern is the ability to authenticate system users insofar as the second fraud report indicated that by far the greatest share of healthcare fraud is perpetrated by organizations with no legitimate purposes; their only purpose is to bilk the system. Helping all EHR users adapt faster to authentication best practices is an evidence-based priority, serving all stakeholders, which was one of the objectives of this report.
There are innumerable competing functional requirements we can reasonably list that will be absolutely necessary to fulfilling the promise of the national effort to improve healthcare information systems. This report simply indicates that, as we figure out how to best use and share this information, we also need to be attentive to the basic validity of information at the point of origination, in accordance with existing rules for business records on computers, with health information management best practices. And standards development organization-certified requirements already in existence, as well as for assuring that reasonable accountability can be demonstrated in the best interests of all: patients, providers, and payers.
Reed Gelzer, M.D.Advocates for Documentation Integrity and ComplianceWallingford, Conn. To submit a letter to YOUR VIEWS, click here. Please include your name, title and hometown.