Tuesday, June 22, 2010

Incentivization and Cautionary Tails

It seems  we will only do things with monetary rewards

Wander off to this website, dedicated to spending the tax payers money for the purpose of installing and using electronic health records in provider offices.  The rule making is only 169 pages long. The devil is in the details.image



It is apparent that most providers want nothing to do with EMR, but have been convinced by 'others' that we must do it, because they know better than we do what is 'good for us'.

Another factor in the equation is that EHRs can be considered to be medical devices, or even 'biomedical equipment".  I think most  of you can see where this is headed.  The Food and Drug Administration (FDA)regulates medical devices as well as pharmaceuticals.

Consider this:  Biomedical equipment must be annually inspected and certified by the appropriate biomedical engineer to be used for patient care.  Devices usually are subject to a 'clinical trial' or reports, or an IDE (Investigative Device Exemption)

EMRs are intimately intertwined with patient care, and involve patient safety issues. 

Where the  feds are involved expect to see more bureaucracy, regulation and oversight.  The feds are just not going to incentivize without regulation. Build in more overhead for regulation.


Certification will not be the end of the story. Just as new drugs require approval by the FDA, so too will software upgrades. After all who knows what an upgrade might cause?

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