In response to Joseph Conn's "RTI report includes controversial EHR requirement":
The article cites the report recently released by the Office of the National Coordinator for Health Information Technology in which a panel of experts selected by RTI International under a contract from ONCHIT crafted recommendations for requirements of electronic health records that could assist in fraud management and improve data quality. I was the chairman of the expert panel.
First of all, I certainly appreciate the coverage you have given to this important effort. Since the article is somewhat negative about our report and since neither I, nor any of the principals in this effort were contacted for comment, I felt it would serve the HITS readers to have some balance in reporting.
The individuals who served on the expert panel all did so voluntarily and without compensation. We represent a broad spectrum of stakeholders including providers, payers, medical informatics experts, law enforcement professionals, data quality professionals and others. The claim by the one outside person that was quoted in this article that it is "a ruse" that we were focusing on the problem of fraud but rather were promoting the "profit" motive of the industry is certainly an uninformed opinion.
Our charge and our focus was fraud management (the prevention, detection and prosecution of fraud) and how EHRs can be a proactive positive element in fraud management. In the course of our deliberations, we recognized that only a very small fraction of healthcare participants are responsible for the enormously costly fraud problem. We certainly did not want to burden the vast majority of EHR users with requirements focused solely on the few bad actors. Instead, we shaped our requirement toward functions, which would have the dual purpose of assisting in fraud management, but also improving overall record quality and, in fact, protecting the majority from unfair claims of improper behavior.
One might legitimately question why we are focusing on EHRs when most fraud today is perpetrated by people who don't use them. It is the consensus of people expert in this area that without proactive features built into EHRs, that the potential for fraud actually will increase in an electronic environment. Now is the time to anticipate this problem.
The title of the article focuses on one of 14 recommendation areas that the reporter states is "controversial." I think the concern is legitimate that audit data that is useful in detecting fraudulent activity could also be used inappropriately. We recognized this concern, agree with it and provided severe limitations to its use in our recommendations. We believe there are ways to prevent illegitimate use of this audit data without jeopardizing our ability to reduce fraudulent activity. This is an area that requires balance, not extremes.
I, and the others who spent many long hours working on this report welcome feedback and, most importantly, constructive assistance in solving this major healthcare problem.
Donald Simborg, M.D.Nevada City, Calif. To submit a letter to YOUR VIEWS, click here. Please include your name, title and hometown.