Mr. Gellman, members of the committee, I am Lewis Lorton, Executive Director of the HOST consortium (Healthcare Open Systems and Trials consortium). HOST is a national, nonprofit consortium of more than 40 companies and health care institutions based here in Washington, created to improve healthcare through information technology. Our members share a belief in the importance of information systems and the profound impact these systems will have on healthcare. HOST members cooperate on a variety of projects; all focused on the use of information technology to maintain quality, lower costs and increase access to healthcare.

I am here, as a representative of our members to make three points in my testimony: Complex problems that arise in forging new policy in confidentiality/privacy do not lend themselves to simple technology solutions. In fact, as the issues are investigated, the complexity of the solution, and thus its difficulty, usually grows.

Before any problem can be solved by technology, there must be a complete understanding of what the problem is – and even more important – what a successful solution would be at the operational level.. Only when there is such an understanding of the new problems and the new requirements can technologists understand where the difficulties will lie in implementation. Technology is not, and can not be, the 'magic bullet.' Technology is not magic; all systems are constrained in a myriad of ways; many of which are neither obvious nor intuitive. The limitations in the flexibility or ability of any computer system may become visible only when the system is tasked in new areas. Cost and efficiency constrain the performance of any information system no matter how sophisticated.

Depending only cutting-edge technology to solve difficult problems isn't feasible; the level of technology available to healthcare organizations across the country varies widely. Cutting edge technology cannot be everyone's fallback position for the obvious reason that the penetration and level of technology is far from uniform across the industry. The degree of information automation in the healthcare industry ranges from superb in some places to insignificant in a great many places.

Thus saying that any specific problem can be cured by some new technologic development ignores the real issue that every health care environment must function with the system it currently uses and with what technology it can reasonably implement. In planning a solution to a problem, the question should not be "Can technology do it?" but "What proportion of the industry can be expected to be able to do it?" What may be a technologic non-issue for a well-supported information system with specific technology already installed could easily be an insurmountable obstacle for less well-supported healthcare providers or whose technology is based on other concepts.

An enormous store of knowledge and experience exists in the information technology organizations which could be tapped in the policy deliberation stage. Accumulations of technical experience and knowledge, such as that represented by the HOST consortium, can be a crucially important resource for policy formers.

Managing information within the healthcare environment is not just keeping hard drives running and consoles connected. Within any specific healthcare environment, the data management is inexorably intertwined with the operational procedures of practitioners and organizations that generate and require information. There are many activities, which involve personal medical information, such as telemedicine consultations or prescription records, which may not even involve the traditionally conceived-of medical record. The management of this wide spread information requires wide understanding and a range of expertise from semantic issues in vocabulary to the electronic problems of wide area networking. There are few uncomplicated issues – or answers.

In this environment technology is an enabler, not a determiner and, just as there are 'best-practices' at the clinical level of medicine, there are also 'best-practices' at the technology level. Because of the enormous complexity of the healthcare enterprise, these technology best practices may not be as readily apparent until the specific problem is well analyzed..

We would like to make the experiences and knowledge of HOST projects and members available to the National Committee to provide a functional, operational and technologic viewpoint.

In summation: We are not implying that operationally or technologically challenging policies should not be implemented. We are suggesting that a full functional and operational analysis of proposed solutions should be part of the process and an assessment of the technology impact of proposed policy changes should be done. This will make clear the real impact on the healthcare environment and all parties to the discussions will be better empowered to make good decisions.

Testimony to the Subcommittee on Privacy and Confidentiality
National Committee on Vital and Health Statistics
Lewis Lorton, Executive Director, HOST
February 19, 1997