Candid CIO

The creation of a social media policy has been a time consuming process for my organizations.  There has been a lot of education and various leaders were in very different positions that we needed to reconcile.  If you have been charged with this task for your organization be prepared to spend a lot of time to bring people along.  Also, have a plan to get the policy out to managers, then staff.  That order is important because your managers need to have the dialogue before they are in a position to effectively support the policy.

Education of the staff is the greatest value of the process.  If you simply post the policy to use for enforcement you have missed out.  Employees need to understand how your organization’s rules apply to the new online world.  You need to provide them with the guidance in the same way you provide your children guidance about what is appropriate behavior online.

While this is our near final policy, one cannot count on this being updated at any point in time.  Ministry employees need to refer to the version in the policy database.  I suspect it will change frequently.  For example, we are already updating the policy and guidance to improve employee awareness of  social engineering tactics.

As always, I appreciate your comments (supportive and constructive):

This is only a summary of the policy principles (the employee guidance).  I may post the full policy later:

Social Media Guidelines for Ministry Workforce Members

The following guidelines have been created to help Ministry workforce members understand how communications through Social Media and Blogs may overlap with their work world and their personal lives.  Ministry recognizes that opportunities offered by Social Media sites and Blogs are subject to constant changes and enhancements; Ministry will strive to continuously address these new opportunities and challenges through this medium and continue to update this guidance.

Today, virtually every Workforce member of Ministry Health Care has an email account and the capacity to access “Our Ministry” and surf the Internet.  Ministry is seeking to find a balance as it relates to Social Media.  On the one hand, there are emerging opportunities to leverage Social Media like Facebook that we are yet to fully understand.  This includes new ways to establish a positive Ministry presence on a wider scale, to collaborate with thought leaders, and perhaps most importantly to engage our patients.  On the other hand, there are significant concerns about Social Media being a Workforce distraction that negatively impacts productivity (especially given the seemingly addictive nature of Facebook and other Social Media sites).

Ministry leadership will continue to evaluate the right balance.  As of this writing, Ministry is not blocking access to Social Media sites because Ministry encourages organizational innovation.  However, some, business units, departments and work groups may develop policies that restrict the use of Social Media sites to any number of degrees (e.g., total ban, specific locations, specific times, etc.).  All Workforce members providing services at or on behalf of an Organization that adopts a more strict policy on the use of Social Media and Blogs must comply with the more strict policy.

There are some simple guidelines to keep in mind when using Social Media sites.  These guidelines are really based on existing policies, but it is worth the exercise of translating those policies for applicability in the online world.  There is a detailed HR Policy on Social Media and Blogs, but here are some key highlights in broad terms:

First And Foremost, Respect the Privacy of Our Patients

Ministry workforce members should never publicly make comments about the care of a specific patient, including online.  Even acknowledging the care of a patient is an unacceptable disclosure of patient identifying information.

Remember, disclosing confidential patient information in an inappropriate manner is a federal offense under HIPAA.  The penalties include significant fines and/or criminal penalties.  Ministry Organizations take violations of patient privacy very seriously and will always take corrective action when aware of such a violation.  Because we share a common electronic patient record with Marshfield Clinic, termination of employment for patient privacy violations can result in your ban from employment by the Marshfield Clinic as well.

Live the Ministry Promise and Values When Online

Don’t post statements on Social Media sites (or any other medium) that may harm the reputation of Ministry Health Care.  This is not to say that everything you say in the public domain about Ministry or Ministry Organizations has to be flattering, but there is a significant difference between occasional constructive criticism and statements that are harmful to the Organization’s reputation.

Be a Productive, High-Performing Workforce Member

It has been Ministry’s policy to only block web sites that are clearly inconsistent with our values.  We do not consider Facebook or other Social Media sites as such sites.  However, many find Social Media sites to be addictive in nature.  While Ministry policy does not ban access to Social Media sites at work, workforce members should not, for example, be checking their Facebook updates or using other Social Media sites for personal, non-work related purposes when they are supposed to be doing their job.  Individual sites or departments may set policies restricting Internet and Social Media site access.

Workforce members should not be checking personal Social Media sites/Facebook when performing work duties.  Workforce members that visit Social Media sites should avoid doing so in the presence of patients and other visitors.  Even if access to Social Media sites is related to work, or carried out on a break, it may be perceived by our customers as neglectful of patient care.

Realize That Social Media Posts Are NOT Private

Even though there are privacy controls on sites such as Facebook and other Social Media sites, you should assume that anything posted on a website that has not been examined by the IT department will be seen by the general public, as well as your employer.  Don’t rely on privacy settings:

• It is possible for those settings to be accidentally set to more open settings;
• Friends can copy and paste what you post to more open forums; and
• You may not remember everyone that has access to what you post.

Don’t Jeopardize Your Reputation and/or Future Employment Opportunities

You should consider that everything you post online begins to build a lifetime record of you and your activities.  Increasingly, employers will search this online history using Google or web sites like pipl.com:   http://tinyurl.com/nfcgbg.

The Internet is your permanent record.  What is posted on the Internet is cached by Google forever and otherwise copied to innumerable other places out of your control.  The Internet is a pen, not a pencil.

As you post comments on social networking sites that are attributable to you, consider the impact those comments will have when read by potential employers, friends, family, law enforcement or someone you might date.

Don’t Alienate Your Co-workers

Remember, you have to work with these people.  Use common sense.  Remember what your mother told you about gossip.

Social Media Opportunities

At Ministry we believe that social networking may be a sea change in the way people communicate.  Facebook and other web sites have created an opportunity to change the way we work that we do not yet fully understand.

We Need a Tech Savvy Workforce

The skills you develop using the Internet and Social Media sites improve the IT skills that we need Ministry workforce members to possess to compete in the future.  We understand that tech savvy people check their Facebook page several times a day.  In many ways, using Social Media sites has replaced the phone as a means for staying in touch.  While we have concerns about workforce member productivity, we want to support the lifestyle of the tech savvy worker.  Unlike other companies, we have decided not to block Facebook or other Social Media sites at the system level; instead, we are asking our workforce members to use this access responsibly and asking our managers to address irresponsible use through appropriate Corrective Action, not technical restrictions.

The Best Advertising Used to be Word-of-Mouth – Now it is:  “Word-of-Mouse”

In the near future, Ministry’s best advertising will come from workforce member sharing with their communities how we are living Our Promise every day.  A well-written Facebook or similar Social Media site post about a new service or the care that we provide to our patients will have far greater effect than a paid TV commercial.  While that post may not have the same reach, the fact that it is coming from a person that is trusted in their community will mean the message has more weight.  People listen to people.  Corporate voices are discounted to a large degree, no matter how glossy the pictures or well written the copy.

It is OK to tell people you work for a Ministry Organization in your social profiles.  We are proud of our workforce members and we believe our reputation is enhanced when people know the quality of our Workforce.

We are encouraging workforce members to talk about work online, but in a responsible, legal manner avoiding the pitfalls we have outlined above.  We hope workforce members will write about positive experiences that they have working with their co-workers.  We hope workforce members will write about thank-you notes they receive from appreciative patients (of course, without identifying the patients).  We are hoping workforce members educate their communities about the services we provide that can benefit their family and friends (online and “traditional” communications).

Ministry management understands that we have discussed many restrictions regarding information sharing.  The natural result may be hesitancy on the part of some workforce members to share anything.  To assist you, we will be working on communicating the types of things you should feel free to share on Social Media sites.

To start, we encourage you to become a fan of Ministry Health Care at our Facebook page: http://www.facebook.com/home.php#/pages/Ministry-Health-Care/196535570649

Workforce members are always welcome to share Ministry fan page posts with their friends.  In the future we will work with others that produce internal communications and encourage them to identify which of their communications can be shared on Social Media sites and which are for internal use only.  We will also develop guidance for workforce members regarding the day-to-day activities in their work place that are appropriate to change.  For example, we would love for everyone on Facebook to tell their friends when the office hours change in the clinic where they work.

Share Your Knowledge

Everyone that works at Ministry has knowledge, talent, and special skills.  Ministry workforce members who participate in social media and blogs are encouraged to share this information on Social Media sites.  There is a halo effect to doing so.  If such information is shared with others, they will remember you and your Organization when it comes time to get those services.  It can also be beneficial to your own career development when you establish yourself online as an expert in your field and passionate about your vocation.

Many people at Ministry are doing that today.  The IT Director at Our Lady of Victory has a blog where he regularly posts what he observes in IT.  A rad tech at Affinity uses Facebook to share with other rad techs what she is learning on the job.  Many others are using Social Media sites to share their knowledge, talents, and skills with others.  This reflects positively on them and on Ministry.

These individuals are routinely contacted by others, including the media, through the Social Media tools they used based on the contributions they have made.  As they are cited by the media as experts in their fields, that has a positive reflection on Ministry.  If you are contacted by the media as a result of your Social Media activities, you are encouraged to contact Marketing.  Marketing not only wants to track these experiences, they can also assist in providing you with guidance in responding in a knowledgeable and articulate manner.

Email is out of control in the corporate America.

More and more people believe they have completed a task by emailing someone to do something.  No follow-up, no tracking and no attempt to make sure the email recipient has the time to complete the task.  I sent you the email, now this is your problem.

What’s worse are emails that describe something that I might not need to know for several weeks.  The burden is transferred away by emailing what you want done to scores of people.  It is now the responsibility of each employee to hold onto that information until they need it.  Some people will store it in their user directory, some people will print it, some (like me) will just leave it in their inbox.

Folks, if you are creating reference material, put it some place where people can find it.  Better yet, put it somewhere people can find the most recent version.  See the difference?  One person is filing the reference material instead of everyone that need the information.  This is the purpose of corporate intranets.

One more email rant, you are not doing your job if you send an email to the widest possible audience so each person can decide if they need the information.  It is the senders job to target the email to the correct audience.

I receive well over a thousand email messages a week.  Don’t assume that I am going to remember your email.  I have a pretty good memory, but I am not Google.  I cannot index that much information.  Business people need to stop thinking that sending an email is the completion of a task.

Email has just become a crux for all of us.  As the CIO I need to help people see these behaviors and understand that they are counter-productive.  I need to make sure that the corporate intranet is easy to update and is usable.  I need to investigate tools like Yammer for moving nice-to-know information out of email.  I am looking forward to new technologies, like Google Wave, to help us parse all of this.

What do you think?

PS, I have to give credit to Kevin Behr for the phrase “I am not Google.”

PSS, I have been guilty of all of these things.  I am trying to do better.

I know everyone  is working on this.  What is management’s response to the sudden and enormous popularity of social media sites?  How do we manage its effects on employee productivity (and perceived productivity)?  How do we provide employees guidance so they don’t post something that violates a patient’s rivacy rights or otherwise embarrases the organization?

Ministry and Affinity have been tackling this too.  Because I have been writing a blog for several years a lot of people have asked me about this hoping we were further ahead in figuring this out.  So, I thought I would post what we have done so far (with the blessing of my fellow social media council members).  I am hoping this is a good crowdsourcing excercise and that your comments will improve this draft.  I plan to post updates to the documents.

My big concern when tackling this is that management would try to set the clock back to a time when people didn’t check Facebook before their morning coffee.  I am concerned that they only sell see this as a problem to be mitigated.  I bbelieve we have a huge opportunity for employers to turn all of their employees into uber-effective marketers that promote every new and worthy aspect of our services with far more credibility than corporate voice advertising.  Focusing only on the negative aspects of social media, and not the opportunity, is a risk.

There are two documents below.  The first is the DRAFT policy.  It is very legalese, but it is intended to provide employees unambiguous direction.  The second is an employee guidance which is intended to be an easier read in plain English.  Once the spirit and content of the employe guidance is finalized we intend to make that available to all employees, perhaps as content in our Learning Management System.  I am also thinking of doing a YouTube video.

TITLE:  SOCIAL MEDIA Policy

 Defined terms are “Capitalized.”  Definitions are imbedded in or included at the end of the Policy.

Policy Statement/s: 

1. Ministry Health Care and its wholly owned subsidiaries identified in the “Scope” section above (“Organization”) recognizes the value of on-line Social Media sites and Blogs as vital resources to positively promote the organization’s mission and values, operational goals, marketing and recruitment activities, as well as a forum for exchange of information by its 12,000 Workforce members.
2. The Organization supports access to Social Media and Blogs by workforce members through the provision of Internet access.  Internet access and use is a privilege and must be carried out in a manner that is consistent with job responsibilities and Human Resources policies addressing appropriate use of scheduled work time and resources.    Access to the Internet by workforce members is supported at the enterprise level and is provided through IT to all workforce members through available devices.  An organization and/or business unit may choose to establish local work rules for Internet access, including Social Media and Blogs, by policy.  Due to the need for workforce members to have Internet access, IT will not provide resources to block access by geographic sites, individual devices, or websites (certain websites will continue to be blocked at the enterprise level (e.g., illegal sites).
3. The Organization shall establish and maintain an organizational presence on popular Social Media sites and through Blogs.  This presence will facilitate expanding communication opportunities for patients, employees, and other stakeholders in the communities served by Ministry. 
4. The Organization has established the Social Media Steering Committee as an enterprise level oversight structure to develop and manage the organization’s Social Media and Blog communication strategy, as well as respond to issues and concerns related to the use of Social Media and Blogs.  This Committee will function under the oversight of the IT Customer Advisory Board (CAB).  Participants shall include representatives from Marketing, Human Resources, Information Technology, Corporate Integrity, and Education.
5. The use of Social Media and Blogs for Ministry official business operations shall be under the guidance of the responsible business unit leader as noted below:
   1. Marketing/Business Development – VP of Marketing & Business Development.
   2. Human Resource Recruitment – VP of Human Resources.
   3. Information Technology Operations – Chief Information Officer.
   4. Corporate Integrity – Director of Privacy.
   5. Education – Director of Education and Development.
   6. Others – To be defined as developed.
6. All uses and disclosures of patient identifying health information shall be carried out in a manner compliant with applicable patient privacy policies, regulations, and standards. Prior to sharing patient identifying health information or images through Ministry sponsored Social Media and Blogs, the individual responsible for the project involving the sharing of that information shall obtain a written authorization for the use and disclosure of the information from the patient/patient’s legal representative.  
7. The Organization supports its Workforce members’ use of Social Media and Blogs for personal and professional use, recognizing that Workforce members have a strong voice in representing the organization.  Workforce members engaged in personal or professional Social Media and Blog communications that reference Ministry-related content shall do so in a manner consistent with the organization’s mission and values, enterprise administrative policies and procedures, and safeguards to ensure the privacy and security of patient health information, as well as proprietary business information.   Ministry has developed guidelines for Workforce members on communicating Ministry-related content through Social Media and Blogs (see attachment). 
8. At no time shall Ministry Workforce members utilizing personal or professional Social Media and Blogs share confidential patient or proprietary business information.  
9.  Prior to discussing work-related activities on Social Media and Blogs, the individual should consider:
   1. Does the discussion positively promote the individual’s role as a Ministry healthcare Workforce member?
   2. Does the discussion reflect positively on individual’s co-workers/colleagues? The individual’s work unit? The organization?
   3. Does the discussion conflict with Ministry’s mission, culture, and/or values?
   4. Does the discussion reveal confidential patient or proprietary business information?
   5. Does the discussion include any information that could directly (e.g., name, Social Security number, address, etc.) or indirectly (e.g., provider name, date of birth, diagnosis, images, etc.) identify a patient under the care of the individual/organization?
10. The Social Media Steering Committee shall serve as a resource for questions and concerns regarding the appropriate use of Social Media and Blogs by Workforce Members.  The Committee can be notified of a concern by contacting the Corporate Integrity Department (Director of Privacy).
11. The inappropriate use of Social Media and Blogs by Workforce members that conflicts with the Organization’s mission and values, violates enterprise administrative policies and procedures, and/or compromises the privacy and security of confidential patient health or propriety business information shall be subject to corrective action, up to and including termination.  In addition, breach of confidential patient health information may also be subject to legal proceedings and/or criminal charges.

Attachment:  Guidelines for Ministry Workforce Members Communicating Ministry-Related Content through Social Media and Blogs (Pending)

Related Policies/Position Statements /Other Documents

• HR-5709:  Corrective Action
• HR-5723:  Internet Use by Workforce Members
• PV-15:  Media Access To and Disclosure of Patient Protected Health Information
• PV-19:  Disclosure of Patient Health Information
• SE-5:  Workstation Use and Security
• Corporate Communications Policies (Under Development)
• Confidentiality/Computer User Agreements

Definitions:  

Blog:   A blog is a website maintained by an individual or organization with regular entries of commentary, descriptions of events, or other materials such as graphics or video.  Blogs may provide commentary or news on a particular subject; others function as more personal on-line diaries.   

Social Media:  For the purposes of this policy social media is an on-line social structure made up of individuals or organizations that are tied by one or more specific types of interdependency, such as values, visions, ideas, financial exchange, friendship, business operations, professional exchange, etc.  Social media sites operate on many levels, from families up to the level of nations, and play a critical role in determining the way information is exchanged, problems are solved, organizations are run, and the degree to which individuals succeed in achieving their goals.

Workforce:      Under HIPAA, the workforce is defined to include employees, medical staff members, volunteers, trainees, and other persons whose conduct, in the performance of work for a covered entity, is under the direct control of such entity, whether or not they are paid by the covered entity.

Background:

The healthcare industry, like many other industries, has embraced the use of Social Media and Blogs.  Social Media sites and Blogs facilitate communication, education, collaboration with others, research, business travel, remote work, etc.  For many, the Internet is a tool to aid in daily business practices that improves work quality and job satisfaction.  The Internet provides a wide array of resources, services, and interconnectivity to Ministry Health Care and Workforce members.  However, there are also risks associated with inappropriate Internet access and use which must be addressed through appropriate safeguards, policies and practices, education and training, and appropriate corrective action when necessary.  Monitoring appropriate use of the Internet by Workforce members is a joint responsibility of the organization’s leadership, information technology (IT) support staff, and human resources leaders.  

Distribution: Ministry Health Care and all wholly owned Ministry organizations, except Agape.  Agape Community Center will be provided notification of and access to all Ministry Administrative Guidance and will determine applicability and the need to implement. 

Values:  This Policy has been reviewed for support of the Ministry Health Care Values.

Key Words:   Facebook, Linked-In, MySpace, Social Media, Social Networking/Networks, Twitter, Yammer

For More Information Contact:  Vice President, Marketing and Business Development, Chief Information Officer, Director of Privacy

Notice:
This information is an accurate statement of published Ministry Health Care Policy as of the time of publication. Permission is granted to electronically copy and to print in hard copy for internal use only. No part of this information may be reproduced, modified, or redistributed in any form or by any means, for any purposes other than those noted above without permission of the Responsible System Leader. Ministry adopts the Policy and recommends that the user always check for the latest version on Our Ministry, the Ministry Intranet site before any subsequent use. Ministry may make changes to the Policy without notice and may deviate from the Policy as determined in its discretion.

Social Media Guidelines for Ministry Workforce Members

Today, virtually every workforce member of Ministry Health Care has an email account and the capacity to access “Our Ministry” and surf the Internet.   Large companies, including Ministry Health Care, often have a love-hate relationship with Facebook and other Social Media websites

Progressive organizations recognize that encouraging employees to use Facebook and other Social Media tools can have much greater benefit that drawback.  Ministry strategically supports leveraging Social Media tools to establish the organization at the leading age of optimizing presence in the on-line environment.

There are some simple guidelines to keep in mind when using Social Media sites.  These guidelines are really based on existing policies, but it is worth the exercise of translating those policies for applicability in the online world.  There is a detailed policy on social media, but here are the highlights in broad terms:

Don’t betray our patient’s trust (and don’t get arrested)

Remember, disclosing confidential patient Protected Health Information (PHI) in an inappropriate manner is a federal offense.  The penalties include significant fines and/or arrest.  Ministry employees should never publicly make comments about the care of a specific patient, especially online.  Even acknowledging the care of a patient is an unacceptable disclosure of PHI.

Don’t get fired

Your employment at Ministry is based upon the premise that your value is a least  equivalent to your salary.  If you are using Social Media (or any other medium) to harm the reputation of Ministry Health Care then your value to the organization has diminished greatly, regardless of your job performance.  This is not to say that everything you say in the public domain about your employer has to be flattering.  But there is a significant difference between occasional constructive criticism and statements that are harmful to the organization’s reputation.  Don’t:

• Post work-related information that may compromise Ministry’s business practices or patient privacy and security.
• Engage in any form of harassment, including derogatory or inflammatory remarks about an individual’s race, age, disability, relation, national origin, physical attributes, sexual preference, or health condition.
• Violate copyrighted or trademarked information. 

Don’t Cheat Your Employer

It has been Ministry’s policy to only block web sites that are clearly inconsistent with our values.  We do not consider Facebook or other Social Media as such sites.  However, many find Social Media sites addictive in nature.  While Ministry policy does not ban access to Social Media sites at work, employees should not be checking their Facebook updates when they are supposed to be doing their job.

Don’t Think Your Facebook Posts are Private

Even though there are privacy controls on sites such as Facebook and other Social Media sites, you should assume that anything posted on a website that has not been examined by the IT department will be seen by the general public, as well as your employer.  Remember:

• “Friends: can copy your posts and make them available in public. 
• Your friends are likely our patients
• It is easy to for your privacy settings to be set to something other than what you had planned

Don’t Jeopardize Your Reputation and/or Future Employment Opportunities

You should consider that everything you post online begins to build a lifetime record of you.  Increasingly, employers will search this online history using Google or web sites like pipl.com:

http://tinyurl.com/nfcgbg.

Don’t Alienate Your Co-workers

Remember, you have to work these people.  Use common sense.  Remember what your mother told you about gossip.

Ministry loves the Internet

At Ministry we believe in the power of the Internet and Social Medial sites.  We encourage our employees to appropriately use and participate in Social Media activities.

We need a Tech Savvy Workforce

The skills you develop using the Internet and Social Media improve the IT skills that we need Ministry employees to possess to compete in the future.  Furthermore….

The Best Advertising Used to be Word-of-Mouth – Now it is – Word-of-Keyboard

In the near future, Ministry’s best advertising will come from employee’s sharing with their communities how we are living the promise every day.  A well written Facebook post about a new service or the care that we provide to our patients will have far greater effect than a paid TV commercial.  While that post may not have the same reach, the fact that it is coming from a person that is trusted in their community will mean the message has more weight.  People listen to people.  Corporate voices are discounted to a large degree, no matter how glossy the pictures are well-written the copy.

We are encouraging employees to talk about work online.  But in a responsible, legal manner avoiding the pitfalls we have outlined above.  We hope employees will write about positive experiences you have working with your co-workers.  We hope employees will write about thank-you notes they receive from appreciative patients.  We are hoping employees educate their communities about the services we provide that can benefit their family and friends (online and physical).

Share Your Knowledge

Everyone that works at Ministry has knowledge, talent, and special skills.  Ministry employees are encouraged to share this information on Social Media sites.  There is a halo effect to doing so.  If you share information with someone they will remember you and your organization when it comes time to get those services.  People at Ministry are doing that today. Many are using Social Media sites to share their knowledge, talents, and skills with others.  This reflects positively on them and on Ministry.

 These individuals are routinely contacted by others, including the media, through the Social Media tools they used based on the contributions they have made.  As they are cited by the media as experts in their fields, that has a positive reflection on Ministry.  If you are contacted by the media as a result of your Social Media activities, you are encouraged to contact Marketing. Marketing not only wants to track these experiences, they can also assist in providing you guidance in responding in knowledgeable and articulate manner.

As I mentioned in my last post I got a chance to meet with Microsoft CEO Steve Ballmer.  He started the meeting asking what we wanted to hear.  The 5 CIOs went around the table asking for information on various technical topics.  The last CIO asked Steve Ballmer what advice he would give to CIOs.  I wish I would have asked that question.

Ballmer had a number of suggestions, but two stuck with me as being most enlightening.

Firstly, he said that CEOs are frustrated that they have invested so much moneyin IT yet they have little additional insight into their business.  He hears this often.  He did not want to characterize this as business intelligence or push any technical solution.  He shared that even Microsoft with all of their IT expertise does not have data about their total headcount – a revelation that gave me a sense of relief.  He also said that he has a rule for his CFO, never give him data in a format that he cannot manipulate, preferably it would be a pivot table.

Ballmer also suggested that the future of enterprise IT can be found in the consumer arena today.  This was the case with cloud computing and is likely to be the case in such areas as social networking.  As IT professionals we should keep an eye on that space.  It is our crystal ball.  I loved that insight.

My last post covered the opportunity I had to meet with Microsoft CEO Steve Ballmer in a small group setting.  He said a couple of things about healthcare that I though were noteworthy.

Firstly, he said that Microsoft develops technologies that are intended to be used across all industries.  He said they were a horizontal software company.  But, he went on to say that healthcare is the one vertical that is fragmented among many software providers.  Since there are no SAPs, Microsoft is making investments in this industry.

I have had time to reflect on this and I have 2 thoughts:

1. Epic is nearly reaching the point of having the same market clout as an SAP (maybe they are at Lawson status).
2. Microsoft might want to examine why that is the case and what happened to all of the other big companies that thought healthcare would be low hanging fruit for a big company (IBM, Alltel, American Express, Siemens and Ameritech come to mind).  Healthcare is complicated.

Ballmer also talked about Microsoft HealthVault.  While he was clearly a believer in a web-based Personal Health Record for patients (PHR) he wondered out loud how Microsoft would make any money doing this.  Clearly a question he has asked without getting a satisfactory answer.  Even when I suggested that the EHR incentives from the federal stimulus bill would bring new opportunities he did not sound optimistic about the contributions that investment would bring to the bottom line.

My next post will be on Ballmer’s advice for CIOs, which I loved.

I love CCHIT.  Having an independent body assess EHR functionality is a wonderful service for us buyers of that technology.  CCHIT gives the seal of approval to those vendors that that have comprehensive EHR functionality requirement.

Apparently someone involved with writing the Federal Stimulus bill loved it as well.  It is apparent to me that it is intended to be a mechanism for determining if a healthcare organization qualifies for EHR incentive payments.

However, assuming CCHIT can determine acceptable EHR functionality is based on the flawed assumption that an EHR is a single purchase from a single commercial vendor.  Organizations that have achieved EHR functionality through the use of multiple specialized applications don’t have a certified EHR in the eyes of CCHIT (and therefore in the eyes of the ARRA it appears).

Let’s say I have a vendor that meets all but one requirement, perhaps their ePrescribing is inferior.  In the past I would simply find someone with niche capabilities to fit that need.  Good for me since I don’t have to start all over just to address that one need.  Good for the start-up that saw a need and met it.

But, in the ARRA world this is no longer an option.  Instead I don’t qualify for EHR incentives because I am not using a qualified EHR technology.

This concern has reached the level of drama in the open source world.  The Open Source folks had an open forum with the CCHIT folks at HIMSS yesterday.  It kind of got ugly.  CCHIT is just tied to an old single vendor paradigm which cannot accommodate this legitimate approach.

The problem is that vendor functionality does not determine how well an EHR is implemented.  I could have a vendor that provided my organization the richest functionality one could imagine, and still implement it in a way that totally sucks.  Conversely, I could cobble together several applications, none of which could qualify on their own for CCHIT certification, but implemented in the right way create something more functional and beneficial to my patients than some CCHIT certified applications.

We should return CCHIT to a buyer’s guide and stop using it to determine government patments.  The goal is good EHRs.  Certification distracts from that more than it ensures it.

Let me be the first to announce the delay of the deadlines to qualify for EHR incentives.  Actually, there is no official announcement or even open discussion – yet.  But, I believe it is inevitable.  I believe this for two reasons:

1. In my experience, government mandates delays are the rule
2. This EHR deadlines are completely unreasonable

Remember APCs, the revised Medicare funding mechanism for outpatient procedures?  Remember the big push for the deadline followed by a last minute delay.  In fact can anyone think of any significant government deadline that did not change?  My favorite example is the recent cutover to digital television.  We gave American couch potatoes years to go buy a converter box (or get cable service).  Millions were spent on advertising, web sites and coupon giveaways.  If there was ever a deadline that should have stuck it was that one.  Still, it was delayed from February to June.

We are giving hospitals and medical groups less time to implement EHRs than we gave television stations to change their broadcast capabilities.  The EHR is at least two magnitudes of order more complex.  Integrated Delivery Networks, such as mine, have essentially one year to implement an EHR for doctors and another year to implement the hospital EHR.  Note: I am assuming the rest of 2009 will be used for planning and waiting for the definition of “meaningful use.”  I have been working on this my entire professional career.  It is not a two year effort.

So, a delay is inevitable.  That is not to say that CIOs and other healthcare executives should plan on a delay.  I don’t think that would be prudent.

The other pressure for us is that healthcare, like corporate America, is focused on belt-tightening.  I have a backlog of really good ideas to reduce the cost of care to our patients.  Our new focus on Electronic Health Records will reduce our ability to implement these ideas.  Then again, I think that was the purpose of the incentives.  Get healthcare organizations to make EHRs a top priority to get them implemented once-and-for-all.