[Reminder: The place to register an official comment to the government is this page on Regulations.gov.]
SPM member Brian Ahier is Health IT Evangelist at Mid-Columbia Medical Center in The Dalles, Oregon. Today he posted this on Google+; reposted here with permission: (emphasis added)
First, I want to say that I am strongly opposed to the AHA’s misguided opinion on 42 CFR § 495.6(d)(12)(i) and (ii); 495.6(j)(10)(i) and (ii) – “Provide patients the ability to view online, download, and transmit their health information within four business days of the information being available to EPs.” I actually view the four business day requirement as a bit weak…
Patients should have real time access to their health information. They should not only be able to view, download, transmit or do anything they want with their record at any time, but have the opportunity to write their own notes as well. Planetree hospitals have been doing this for years! It’s called being patient-centered…
He links to his own post on this – from 2009:
Healthcare, Technology & Government 2.0: Transparency With Patient Data
It includes this, from a book co-authored by Planetree founder Susan Frampton:
“The Planetree philosophy stresses that one of the most valuable learning resources available was the patient’s own medical chart. Patients were encouraged to read their charts daily, ask questions and discuss findings, and participate in the decisions affecting their care. Patients were also encouraged to keep written records of their experiences and observations in Patient Progress Notes, which became a permanent part of their medical chart if they so desired.”
by Susan Frampton, Ph.D. and Patrick Charmel
Planetree’s a great organization, if you don’t know them. Check ’em out.
Edit note: the title of this post originally said “Planetree hospitals already do it.” The body of the post was unambiguous about “do it” (real-time access to the record) but the title wasn’t, so after talking with Brian I changed it.
First let me be sure that everyone knows I am not speaking for Planetree or any hospital, but only representing my own views.
While not every Planetree hospital may have the technology in place to give immediate electronic access to their medical record, but certainly the patient has immediate access to their chart (even while they are still admitted) and also make their own notes in the cart. If the patient is truly to be a member of the care team, how would keeping the information which the rest of the team has available away from the patient themselves make any sense?
I understand the difficulty of having all the notes signed off and the record complete within 4 days, however, a medical record is not a static document. It is constantly changing but I firmly believe that a patient should have real time access to their record at any time…
Stop the Errors
My on-line pharmacy list has had medications removed; medications added back, medications that never appeared again. The one that was requested to be removed is now gone from my on-line pharmacy list. I didn’t need to ask the HIPPA Specialist at all, I just needed to wait for the KP software department to delete it.
I currently have prescription errors on my on-line medication list that I have not been able to get corrected, even after repeated requests. I’ve thrown away $600+ of insulin delivered overheated due to an error in the prescription process. I have asked multiple times to correct errors in my prescribing information online, on the after visit paperwork, and on the drug bottles. I recently asked to have Glipizide description on the bottle corrected. At what point will these errors harm me?
I’ve asked for drug package inserts and couldn’t get them, so I checked KP online drug database, and it was 2011. I was looking for the current updates on Statin. KP just updated their drug database to 2012, but it still means that my Statin drug changes may not appear until 2013? Why can’t I get package inserts or more current drug data?
I’ll ask member services, and they’ll consider my request a grievance, and will send me a generic/form letter saying they will investigate. I won’t know what they are investigating. I’ll get a customer service liaison calling me, sharing that I don’t understand the review process, and blaming the primary physician for not fixing everything. I’ll explain to the liaison, that I did try to contact my primary, and was told, “I’m a busy internal medicine doctor.” In e-mailing the on-line pharmacy they tell me that they are in California and they’ll can’t do anything for Colorado, and they’ll forward my grievance to Colorado Customer Service. I’ll never hear back. I’ll contact the Colorado on-line pharmacy, and they help me replace the insulin, but then they stop talking to me. A KP Liaison calls me and explains that my concerns about the KP patient website is not the medical record, and it doesn’t need to meet the same standards of the medical record. It doesn’t need to be accurate.
Sandra, it’s vital that you paste exactly that TODAY into the Regulations.gov comment page. They NEED story after story of why consumer engagement in the record (aka fact checking) is desperately needed. Yours shows that in the absence of fact checking our records may be shot full of errors, creating danger.
Please please go to http://www.regulations.gov/#!submitComment;D=CMS-2012-0022-0001 and paste that in. Perhaps just change the first line to “Errors in my record are dangerous. Let me help fix them.”