Mr. Chairman and members of the committee, I am Floyd Eisenberg, a physician consultant with Shared Medical Systems (SMS). On behalf of SMS, I want to thank you for the opportunity to testify before you today on the very important subject of the standardization of surveillance data for immunizations.
Before I begin my comments, I would like to introduce my company to those of you who may not know us. SMS, now in its thirtieth year, has focused exclusively on serving the information technology needs of participants in the health industry. We have made it our business to develop, deliver, and support the information solutions that help our customers meet their varied and changing business needs.
SMS provides these health information solutions to customers in 20 countries and territories across North America, Europe, and the Asia-Pacific. Our customers include integrated health networks, multi-entity health corporations, community health information networks, hospitals, physician groups, government health facilities, managed care organizations, health benefit plan administrators, and payers. Based on customer need, our solutions can include any combination of clinical, financial, and administrative applications, enabling technologies, and integration and support services.
My testimony today will consider SMS customer-based activities for immunization tracking as well as explore potential methods to encourage private sector interaction with local and regional registries.
SMS has over forty customers that currently perform immunization registry and tracking functions using SMS systems for hospitals and clinics. Many of these facilities function under the auspices of county health departments. Some of these facilities, including one state health department use immunization tracking in conjunction with practice management and billing software. In partnership with these customers, and based on their requirements, we have worked with HL7 code sets and additional detail to increase the specificity of information storage. Specific additional granularity has included:
Immunization records are entered once at the point of care and stored in real-time in the clinical data repository so that any provider reviewing the record anywhere in the delivery system has direct access to the most recent service delivered.
Due to the requirements of our customer base, SMS has included this type of granularity in our health information systems and our ambulatory clinical and billing software. We welcome the movement to further standardization of terminology as beneficial in this area for SMS as a vendor, and for each of our customers.
Our customers that perform immunization registry functions as health departments experience similar challenges as those presented earlier in this session. Vaccinations are not included in the registry if they are provided to the commercially insured population in physician offices and health clinics not affiliated with the health department. That connectivity is of interest to our customers working in the public health sector.
Currently, many physician offices document immunizations in a paper record, using electronic transactions primarily for billing. Integrated health networks and private sector physician organizations have also identified the requirement to track immunizations and other preventive care activities for the populations they serve. We originally developed this feature in our practice management billing/encounter system to meet the needs of the public health clinics; it quickly caught on with the primary care providers using our system in the private sector. The private sector customer base has not, however, identified a priority to transmit vaccination or other information to existing local or state registries.
To be effective a process to transmit immunization information from the private sector to an immunization or regional registry has the following requirements:
1. Transmission must provide added value for the physician or business entity, which includes receipt of information that updates the records of persons actively followed in that office or clinic. This function carries with it a requirement for security authorization as well as the possibility that other preventive care parameters will be included in the information returned from the registry to the local information system.
The process of updating the office record is useful to improve productivity, saving the time and expense involved in record retrieval for new and existing patients. Updated records are also beneficial for improving the accuracy of performance measurement efforts based on preventive care delivery. Such measures are increasingly being used by health plans and practice management organizations as an indicator for performance incentive payments to clinicians. Other potential benefits to a clinician’s practice include improved patient satisfaction and member retention due to improved productivity, allowing more time for patient contact and decreased waiting times for service delivery.
These potential benefits, however, require that a critical mass of information is reached in the immunization registry. As the senders, clinicians bear the costs of a) additional information technology function, b) accommodating electronic reporting into routine procedures, c) attempting to maintain an appropriate level of compliance, and d) transmission and error recovery. Until there is sufficient, reliable information retrieval from the registry, the clinician will not experience significant productivity improvement or performance improvement with respect to patients for whom he or she is held accountable. The receiver (the immunization registry) gains the information needed, but the initial value to the physician or business entity may be minimal.
2. The transmission must be cost-neutral to the physician or business entity. As noted above, unless there is perceived value, the physician office is unlikely to accept transmission charges. Therefore, the transmission must occur through existing equipment and connectivity (e.g., a modem and telephone line currently used for other purposes such as claim transmission to third party payers). The transmission must also be productivity-neutral. It must occur in the background, without affecting the speed of existing office practices, and it must require no additional data input for the end user.
Potential modes of transmission include Electronic Data Interchange (EDI), direct modem, internet or intranet transmission. To be effective, the transmission to an immunization registry will require standardization of provider identifiers and the identifiers used to match patients, as well as appropriate security and encryption. Patient authorization will also be required for any information returned to update the initiating private practitioner database. Transmission to a local or state immunization registry could be performed in batch mode, which would require storage of daily activities for replication with the appropriate server at a predetermined time.
Currently electronic transmissions are most commonly used for claim submission. One consideration for submitting immunization delivery information is simultaneous with the claim transmittal. Data from billing systems, however, require some management. Bills that are never issued would clearly not be transmitted to an immunization registry. A single service may be billed to several insurance carriers and the guarantor until payment is collected. The transmission to an immunization registry would, ideally, occur only on the first claim submission for the service. The receiving system, however, would need to ascertain if the transmission were a duplicate. In addition, claims are generally submitted as X12 transactions. For the transmission of immunization data with claims, a combined solution, such as enveloping HL7 data within an X12 message should be addressed.
EDI transactions generate transmission charges to the physician or business entity. Connectivity to an immunization registry must be simultaneous with eligibility and or claims transmission, or pre-programmed to occur after office hours for no additional fee. In light of the current lack of demand, it is not clear that EDI vendors would provide this function without charge. Similarly, direct modem or internet/intranet transmission would need to occur through an existing connection, also after routine hours, and for no additional cost.
Healthcare Data Exchange (HDX), a subsidiary of Shared Medical Systems, Corp. (SMS) has extensive experience in delivering batch and real-time transactions as a by-product of existing work-flows as with eligibility, authorizations and referrals between provider, payer, and utilization review organizations and third party administrators. HDX processes more than 5 million such transactions each month. The key to success is standardization, and SMS and HDX have contributed many resources to the development of such standards in HL7, X12, DICOM, CPRI, and others. We believe the development of a national standard is valuable, and there should be a national implementation guide that governs the use of the standard similar to the effort for the X12 transactions identified for use under HIPAA/Administrative Simplification.
In summary, SMS has significant experience providing functional immunization registries and tracking functions to our customers. We encourage and support standardization to increase the value of our clinical systems. The challenges of integrated care delivery across the continuum of care are exciting. We are pleased to be included in this discussion with the National Immunization Program and the National Center for Vital and Health Statistics, and we look forward to continued cooperation in this and similar efforts.
Mr. Chairman and members of the committee, this concludes my statement. Thank you.