Could RFID Help Support Electronic Health Records?

The stimulus spending package, or American Recovery & Reinvestment Act (ARRA) of 2009, authorizes $23B in spending for healthcare information technology, with a key focus on the adoption of electronic health records (EHR) by 2014. Of this, $2B is available immediately to begin the process of building infrastructure and support for EHR deployment. According to Dr. David Blumenthal, who has been appointed by President Barack Obama as National Coordinator for Health Information Technology, less than 20% of hospitals have electronic health records today, while the figure for doctors is around 10%. EHRs would provide healthcare professionals with electronic access to an individual’s medical history, even when that history has been recorded by multiple providers. Therefore, the EHR system necessitates inter-operable communication of standardized data between hospitals and physicians. In our view, RFID could play a potential role in the development of these health records, particularly given the tight timeframe that needs to be followed. The Department of Health and Human Services needs to issue its Interim Final Rule by December 31, 2009 and legislative incentives begin in 2011.

The legislation is structured to offer $17B in incentives and $13B in potential penalties associated with driving EHR adoption. Provided physicians employ “meaningful use” of a “certified” EHR, they will receive bonus payments from Medicare beginning in 2011 and ending in 2016. For those doctors that do not employ such systems, they will face Medicare reimbursement penalties beginning in 2015. Hospitals that comply with meaningful use EHRs by 2011 will be provided with a $2M bonus payment. Given this structure, we believe the healthcare community is well incented to participate.

As background, the legislation recognized the Office of the National Coordinator of Health Information Technology (ONC), which is charged with creating a national inter-operable health information system. Providing guidance to the ONC will be two committees, also created by legislation, the Health Information Policy Committee and Health Information Standards Committee. Look for three key pieces of material to come from the ONC as part of the development of EHRs: the definition of “meaningful use,” a set of applicable standards and IT strategy, and the definition of “certified EHR.”

With respect to “meaningful use,” rather than creating a definition based on inputs, such as the establishment of a database, or the number of computer terminals in use, the Policy Committee is essentially looking to define meaningful use by meeting five desired outcomes.

• First, improve quality, safety, efficiency and reduce health disparities, which for example, might require lab results to be incorporated into an EHR as structured data. Today, lab results are provided on an unstructured basis as they are often a “.pdf” that is “attached” to a patient record.
• Second, engage patients and families by providing these parties with access to data and tools to make informed decisions. This could be measured by percent of patients with access to such records on an electronic basis.
• Third, improve care coordination by allowing information to be shared among varying physician groups or hospitals electronically. Today, most information sharing is done with physical file transfers or faxes.
• Fourth, improve population and public health by enabling easier access to data by public health agencies.
• Fifth, ensure adequate privacy and security protections for personal health information, including compliance with HIPPA and electronic security standards.

The Health IT Policy Committee released its recommendations, including a summary matrix, for defining meaningful use in June and July. For each of these areas, the committee is working on establishing objectives for hospitals and providers initially for 2011, with updated versions by 2013.

Our suggestion would be to consider an RFID-based medical identification card that could play a key role in developing EHRs as we see four of the five “meaningful use” criteria that can be addressed through RFID (the exclusion is No. 4, which requires a database to aggregate data for public health agencies). While we expect in the long run that extensive patient medical records will be housed in electronic database(s), we see lots of complexity with implementing such a solution and the possibility for records to be cross contaminated without proper checks. We could see a two-phased approach, with the first phase leveraging RFID as a portable data base, and the second phase as developing a more extensive set of databases that can communicate standardized EHRs.

In this first phase, we believe RFID could represent a faster and less complex implementation, and longer-term could provide the mechanism that ensures proper database alignment with each patient, even those with similar or the same names. Consider that an RFID-based card with extended memory could contain a unique identification number for each patient, and provide a large amount of medical information on each individual. This information can be structured and written on to the card by varying providers, thus promoting information access to interested parties. Such a solution might offer ease-of-implementation advantages given that integration of readers into hospital or physician computer systems at the point of medical care would not be very complex. Further, the option might offer a more economical approach to data exchange for smaller organizations that cannot afford meaningful capital outlays. In addition, these cards are readily portable, which could be valuable for emergency medical technicians working in an ambulatory environment.

With respect to standards development, the ARRA legislation requires the Secretary of Health and Human Services (HHS) to “…publish a set of initial standards, implementation specifications and certification criteria…” by December 31, 2009. The legislation also includes $20M provided to the National Institute of Standards and Technology (NIST) to help advance healthcare integration and standards, and to provide for a set of conforming tests. In addition, the legislation also requires HHS to publish a federal health IT strategic plan by the end of the year. The Standards Committee will initially focus on the policies developed by Policy Committee. In order for RFID to be a viable alternative, the committee likely needs to understand its capabilities and create a framework that allows RFID to be considered. Given that privacy is a key outcome, we recommend that standards development consider the use of short range technology, and on-card encryption to protect sensitive personal information.

For Certification, today it is done by the Commission for Health Information Technology (CCHIT), which is a private industry group. HIT Policy Committee will re-evaluate the CCHIT methodology, which is currently deemed too detailed and not well understood. Compliance testing is also conducted by CCHIT. The committee has put forth an initial recommendation that provides guidelines for HHS to develop the certification criteria. The recommendation also suggests that a third party be responsible for the testing process and awarding certification.

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