The almost over half-dozen regular visitors to this blog know that I much prefer “snarky” over “wonky.”  However, this is serious stuff (see parts 1 and part 2 of this discussion), and I’m sorry to say that we’ll be eschewing the alliteratively amusing yet enlightening parable on this one for the tediously technical.  Non-physicians are encouraged to move on to this entertaining dog video:

entertaining dog video

Seriously, it’s a great video, where these dogs are dressed up as US Supreme Court Justices.  Even if you think you’re going to read this wonkishly tiresome tirade, take a moment first.  It’ll make the process more palatable.  Or whiskey.  That works, too.

As you may have gleaned from Parts 1 and 2, I believe the current state of the EMR mandated implementation to be no less than a public health crisis.  Over the top?  I don’t think so.  Please ask any physician, nurse, or health care practitioner in the country.  I’ll wait.

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See?  We have to take meaningful, immediate actions to save patient lives and stop the documentary disease that is degrading medical record keeping even as we speak.  My recommendations, therefore, are simple and immediate.  Here they are:

Step 1:  CMS is to immediately suspend the “meaningful use” mandate.  Financial bonuses for those practitioners who implemented EMR should, of course, remain in place.  These folks laid out a lot of good money based on this expectation.  But we should immediately lift the threat of financial penalties for those practices that have not yet fallen down this well.  This will also come as a great relief to the hundreds of practices that paid tens of thousands of dollars to install an EMR and have, in practice, chucked it into the closet because they found it unworkable, and therefore have not been able to meet meaningful use criteria.

Step 2:  Immediately charge the Bureau of Weights and Measures to develop, in a timely fashion, minimum standards for electronic medical record keeping.  Believe me, I would never have thought this up on my own–this was the plan back in the day when we were all talking about how great it would be to have an EMR.  Seriously, the Bureau of Weights and Measures.  These standards should be developed with input from the hospital industry, physicians, midlevel providers, nurses, and database engineers specializing in intercommunicability and security.  This standards-making process should actively exclude representatives from the current EMR companies.  The process should pay no mind for backward compatability concerns.  These are the assholes who jumped the gun in the first place and forced us to buy dangerous, flawed products at exorbitant prices.  Screw ’em.

Step 3.  Require commercially offered EMR programs to be tested and certified by the FDA as a medical device.  You think I’m kidding?  I’m not kidding.  The EMR is a medical device, a device that affects every single patient care interaction.  A bad EMR is dangerous to patients.  If the FDA requires that my felt tip skin marker be certified before I use it to mark a patient, yeah, I think they should check to make sure that the EMR doesn’t systematically screw up my orders. Not such a crazy concept.  Oh, and the current multibillion dollar products already on the market should be retroactively required to pass this testing.  No grandfather clause here–these programs are flawed and dangerous.  Let the FDA sort it out by soliciting open comments from the consumers (that would be us).  They will be swamped with helpful information.

Step 4.  Governmental funding of a standard EMR to be made available to any and all practioners/healthcare facilities at no charge.  This whole EMR idea began when a bright young (or maybe not so young, I wasn’t there) physician stood up (might have just raised his hand, not sure) and pointed out in a committee meeting during the early ’90s that the VA system had this pretty cool computer system that was better than paper charting.  Say what you want about the VA, they were the first and the best at this EMR stuff.  Then we all said, yeah, that sounds great, let’s do for the country what the VA is doing for our vets.  Which, of course, we completely screwed up.  So I propose that the federal government pay the money to improve upon the VA program to develop a simple, effective, broadly applicable, safe EMR.  Then the federal government should make this program available as the minimum default option for any and all health care practitioners and facilities for free.  Because we paid for it already with our tax dollars through VA funding.  This program, of course, wouldn’t be the “bells and whistles” pretty thing that private industry will provide for profit.  But having this free product would establish a baseline that all the other manufacturers will have to exceed if they expect us to lay out a lot of our hard-earned cash.  Because right now we’re paying for a grossly inferior product.

I can already hear my Malthusiastic colleagues and trade group lobbyists saying that these recommendations are bogus, just more government regulation/interference with the free market, blah, blah, blah.  Hey guys–we tried that, and we got this.  So no, it didn’t work.  Mandating purchase of a product immediately disrupts the free market.  Believe me, if we weren’t forced into it, very few of us would’ve purchased the grossly defective products currently on the market at extortionist prices.  The free market will be effective at leading to competitive pricing of an improved product if we take away the threat of near-term penalties and establish standards for this medical instrument. Then, and only then, can the free market work its magic.

I urge my colleagues, representatives, and medical societies to take up this challenge.  Nothing in our current practice of health care is more important.