FHIN Public Comment - Sage Software FINAL 121406
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FHIN Public Comment - Sage Software FINAL 121406

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4 Pages
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Sage Software Healthcare Division 2202 N. West Shore Blvd. Suite 300 Tampa, FL 33607-5749 Telephone: 8779326301 December 14, 2006 Lisa Rawlins, Bureau Chief Florida Center for Health Information and Policy Analysis Agency for Health Care Administration 2727 Mahan Drive, Mail Stop #16 Tallahassee, FL 32308-5403 Re: Response of Sage Software Healthcare Division to the Agency for Health Care Administration’s Request for Public Comment on the Financing, Development and Operation of the Florida Health Information Network Dear Ms. Rawlins, Sage Software Healthcare Division (Sage Health) commends the Agency for Health Care Administration (AHCA) for its leadership in welcoming the input of healthcare industry stakeholders in the development of the Florida Health Information Network (FHIN). Sage Health welcomes the opportunity to respond to the questions posed in AHCA’s November 22, 2006 Request for Public Comment. Sage Health (formerly Emdeon Practice Services) is the nation’s leading provider of physician practice management and electronic health record (EHR) systems, supporting more that 185,000 practitioners at 30,000 practice sites nationally and approximately 20% of Florida’s clinicians. Due to the nature and scope of its operations, Sage Health is committed to the development of interoperable health information technology (HIT) solutions and to working with AHCA and the Governor’s Health Information Infrastructure ...

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Sage Software Healthcare Division 2202 N. West Shore Blvd. Suite 300 Tampa, FL 336075749 Telephone: 8779326301 December 14, 2006 Lisa Rawlins, Bureau Chief Florida Center for Health Information and Policy Analysis Agency for Health Care Administration 2727 Mahan Drive, Mail Stop #16 Tallahassee, FL 323085403 Re: Responseof Sage Software Healthcare Division to the Agency for Health Care Administration’s Request for Public Comment on the Financing, Development and Operation of the Florida Health Information Network Dear Ms. Rawlins, Sage Software Healthcare Division (Sage Health) commends the Agency for Health Care Administration (AHCA) for its leadership in welcoming the input of healthcare industry stakeholders in the development of the Florida Health Information Network (FHIN).Sage Health welcomes the opportunity to respond to the questions posed in AHCA’s November 22, 2006 Request for Public Comment. Sage Health (formerly Emdeon Practice Services) is the nation’s leading provider of physician practice management and electronic health record (EHR) systems, supporting more that 185,000 practitioners at 30,000 practice sites nationally and approximately 20% of Florida’s clinicians.Due to the nature and scope of its operations, Sage Health is committed to the development of interoperable health information technology (HIT) solutions and to working with AHCA and the Governor’s Health Information Infrastructure Advisory Board (GHIIAB) toward achieving the widespread adoption of interoperable EHRs and the development of the FHIN. General Comments Sage Health commends AHCA and GHIIAB for the comprehensive discussion of the issues and the accompanying recommendations detailed in the November 11, 2006 White Paper entitled “Florida Health Information Network Architectural Considerations for a State Infrastructure.” Sage Health believes that the White Paper is critically important not only because it provides a framework for establishing the FHIN but also because it clearly sets forth an actionable plan toward delivering interoperable EHRs to all Floridians.Further, the White Paper’s approach to the architectural considerations areconsistent with and support the U.S. Department of Health and Human Services (HHS) ongoing effort to encourage investment in interoperable EHRs to replace paperbased health records. Specific Commentstothe Request for Public Comment: Please find below Sage Health’s specific responses to the discrete questions posed in the Request for Public Comment: 1. The impetus for considering a FHIN is to achieve interoperability of health information technologies used in the delivery of care in Florida as specified in s. 408.062, (5), F.S. Is the working definition of the Florida Health Information Network provided by the Agency in the white paper appropriate? Should it be modified? And if so, in what way?  SageHealth commends AHCA and GHIIAB for developing a wellrounded and comprehensive working definition of the FHIN.We believe that the stated definition is appropriate.
Sage Software Healthcare Division 2202 N. West Shore Blvd. Suite 300 Tampa, FL 336075749 Telephone: 8779326301 It should be noted, however, that the definition of FHIN is dependant upon the proliferation and success of local RHIO’s, to enable interoperability to local providers.Because there is still considerable debate over the financial sustainability of local RHIO’s, consideration should be given to operating FHIN as a RHIO; i.e. to enable local connectivity to the FHIN by provider systems if either a local Health Information Network or RHIO is unavailable.In this way, rural healthcare providers that are out of the reach of a local RHIO are still able to participate, and the dependence on unpredictably financed RHIO’s is lessened We welcome the concept of RHIO connectivity via FHIN, as this eliminates the requirement for us as an HIT vendor to develop and maintain multiple interfaces for each RHIO.We are concerned that the lack of consensus regarding standards may cause the data available from each RHIO to be widely variable. Variability in the quantity of the available data will likely slow adoption by healthcare providers. 2. Has the agency identified the correct functionalities of and the specifications for the statewide infrastructure? As identified by the Agency, these include:  Enterprise master patient index;  Record locator service;  Web services interface for connection to RHIO servers;  Database infrastructure for state agency datasets;  Database software for querying patient records in state agency databases;  Credentialing and authentication of users including query software for access to physician licensing information at the Department of Health, Privacy and security requirements including authorization and access controls; and Web portal for querying data directly from the FHIN. Sage Health commends AHCA and GHIIAB with developing recommendations for an adequate functional set for the FHIN.In particular, we believe that the establishment of an Enterprise Master Patient Index (EMPI) is vital toward reliable clinical data interoperability. One of the products which we provide as a healthcare information company is an MPI, and we are intimately familiar with the challenges of managing an MPI.An issue which we believe is of concern is that the White Paper does not delineate the process by which to update the patient demographic information in the EMPI.Another concern is the issue of patient record matching.We do not believe physicians will have the time or make the effort to evaluate clinical records for relevancy that are not 100% certain of being for the patient in question.The FHIN must be able to return a set of patient records that are verified in advance to meet the necessary matching criteria to ensure proper patient assignment. We share the concern noted on page 22 of in the White Paper about the “relative value of claims data versus data from EMR and other source clinical systems: e.g., “there was value in claims data as supplemental data, but not as a replacement for primary data”. 3. Is the detailed pro forma budget (found on page 54 of the white paper) reasonable? If not, how should it be amended and why? pro forma budget.Because no nationallyIt is difficult to judge the adequacy of the White Paper’s recognized model for the development of a functional statewide health information network currently exists, Sage Health assumes , there are many unknowns which will likely cause the price and timeframe to increase incrementally.As a technology vendor, Sage Health is acutely aware of the costs associated with the challenge of manipulating disparatedata systems toward a unified dataset, and we caution AHCA and GHIIAB to be liberal in estimating cost in order to ensure that funding does not run out before the project is complete.
Sage Software Healthcare Division 2202 N. West Shore Blvd. Suite 300 Tampa, FL 336075749 Telephone: 8779326301 4. What is the most appropriate method for funding the development of the Florida Health Information Network and what are the justifications for the suggested funding source(s)? The health care sector faces significant financial challenges, with rising costs and decreasing reimbursements. InSage Health’s view, it is not realistic to expect healthcare providers to fund the development of the FHIN.We believe that development of the FHIN is a public health initiative, and should be funded by the State of Florida, supplemented if possible by grants from HHS or other Federal government agencies. 5. What is the appropriate method for funding the operation of the statewide network on a sustainable basis? Similarly to our response to question number 4, above, Sage believes that it is not realistic to expect healthcare providers to fund the ongoing operations of the FHIN. As a healthcare information technology vendor with approximately 20% market share in Florida, we are very knowledgeable of the “mindset” of healthcare providers.In general, they believe that the true cost savings of an interoperable electronic health record (in terms of reduction of redundant tests and higher quality of care) accrue primarily to payers, employers and consumers.In large part this is because the current healthcare compensation structure is based on volume rather than quality and it is a disincentive for healthcare providers to provide fewer services, even when those services are redundant. While the solution to this dilemma is beyond the scope of the FHIN project, the cumulative result may be that healthcare provides will not elect to participate in the FHIN if there is a cost to do so. However, Sage Health is nowseeing signs among the provider community that this mindset is changing, with the national focus on EHRs and interoperability; albeit slowly. We believe that the appropriate funding for the operation of the FHIN is as a public health initiative, funded by the State of Florida and supplemented, where possible by HHS or other Federal government grants and payers. 6. How should the entity that will operate the Florida Health Information Network be structured and what is the ideal governance model? Are there benefits to a nonforprofit organization vs. a forprofit organization? Should the state consider a statutorily created public/private partnership? Sage Health believes that to gain credibility as a public health initiative in the provider community, the FHIN should be a notforprofit organization.Provider acceptance and participation are the keys to success of the FHIN.. Sincethe healthcare provider mindset is that the savings enabled by interoperability accrues to payers, employers and consumers, to establish the FHIN as forprofit, or public/private partnership could be perceived as just another way to squeeze us “rich doctors”. We also have the following comments regarding the White Paper. Page 11 – “It is essential that the provider be able to record a patient visit and add data elements to the minimal clinical dataset at the RHIO server.This function should be enabled by the FHIN interface, or by the provider’s EHR. Based upon our experience at healthcare provider practices, Sage Health believes that it is not a realistic to expect that providers who are not using EHR’s will manually add data elements to the minimal clinical dataset, without monetary compensation..Indeed, the expectation that providers will manually
Sage Software Healthcare Division 2202 N. West Shore Blvd. Suite 300 Tampa, FL 336075749 Telephone: 8779326301 enter data to the RHIO, while at the same time documenting that data as part of the local patient chart places a significant, uncompensated administrative burden on providers. This highlights a crucial point.While Sage Health understands that the interoperability initiative has to start somewhere, we believe that a greater emphasis should be placed on providing incentives to healthcare providers to adopt electronic health records.In order for interoperability to be successful, data with which to interoperate must be created as a byproduct of the patient exam, versus expecting a provider to duplicate a subset of the exam data manually in an online system.It would be an unfortunate outcome if the FHIN is built and then underutilized because of the cost and logistics of manually adding data. Page 29 Minimal Clinical Dataset We commend AHCA and GHIIAB for acknowledging that standardized data is a prerequisite for interoperability. Wesuggest that the CCD standard, recently endorsed by HITSP and soon to be required by the CCHIT be utilized.Utilization of this standard will enable faster adoption by HITvendors such as Sage Health because we will be able to support the same standard for interoperability as will likely be adopted nationally. Summary As a healthcare information technology vendor with divisional headquarters in Tampa and a staff of more than 500 throughout the State of Florida, Sage Healthwould like to thank AHCA and GHIIAB for the opportunity to comment and to congratulate you on the accomplishments to date regarding the FHIN.We look forward to participating, both as a contributor and a consumer as the FHIN takes shape. In summary, Sage Health hopes that the comments provided above are of assistance to AHCA.Of course, should you have any questions or require further clarification, please do not hesitate to call me. Very truly yours,
Michael E. Burger Director, Strategic Clinical Initiatives