IHE - Mobile Access to Health Documents

The MHD implementation guide could enable patient managed applications to submit medical information to their clinician. The MHD implementation guide provides methods of expressing the medical data (document), the Provenance of that document (metadata), and the reason for submitting (submission Set).

​​​​​​​Data provenance - Identify patient data over time

As patient supplied data is integrated within a record its origin needs to be considered. Data provenance is an important  factor within this workflow, as commented earlier data provenance needs to be refined and supported with specific guidance.

Push Patient-Generated Health Data into Integrated EHR

We live in a mobile and global world. Our health data need to reflect our mobile, instant, connected world. It is our right as patients to access and own the results of our medical care instantaneously for our own longitudinal record, and shared with whomever we please. We as patients should own our health information and digital results of our care free of charge. We already paid for them by paying for the medical service through our insurance premiums, copays, deductibles, and taxes.

We should be allowing for the design of the future rather than addressing the dysfunction of today. In doing so, this will empower the consumer to control their own health information so they can make better choices about their health.

This EHR should be readily available by the patient and secured by the patient’s choice of password combined with third party verification, biometric or facial recognition, or the state-of-the-art technology as used in other sectors.

Providers and their software vendors need to allow for open technology development, leveraging existing state-of-the-art security and patient safety measures like thumbprint, voice, or facial recognition and device verification. The electronic medical record should be transactional, mobile, and secure like mobile banking is in the financial industry. A patient-centered longitudinal record gives the patients the choice of when, how, with whom, and to what extent their own medical records can be shared.

The patient receipt of their own health care record should be automatic. We need to eliminate the requirement for the patient to ask for copies of their information and copies of their films. A copy or photo of an image or film should be automatically provided to the patient. The patient should not have to go to a separate location in the hospital, fill out a separate form, and then wait up to 30 days to receive their information. Those 3 things collectively inhibit timely and quality care. We can achieve timely and the best of quality care if we provide the patient with immediate access to his or her own patient-owned integrated EHR.

We need our electronic health record to follow us so we are free to receive care wherever we choose. Through cooperation and non-discrimination, we can have one, single, mobile, longitudinal record.

Multiple, separate portals from each provider, difficult to access, each acting as an island unto itself, is a broken way for a physician to provide optimal health care. It is onerous, expensive, and redundant. It is broken. It does not work.

Patients need ownership rights to their own health information and data, and ability to have an aggregated, integrated, longitudinal, patient-owned electronic health record. That EHR should be readily available to them through their mobile devices. Hospitals/providers should have open API’s, and images, films, EKG’s, CT’s, MRI’s, radiology, open notes regarding discharge and care should be readily accessible in a shared, open architecture for other institutions on behalf of the patient. The EHR should also have available linkage to the patient’s pharmacy for populating a history of prescription fills.

We can greatly improve the quality of health care and provide timely, life saving measures to patients in emergent care with informed physicians and patients, family and caregivers alike. We can substantially reduce costs of health care by eliminating redundancies in providing care across institutions. This common sense approach can, in fact, be readily done with today’s technology, as evidenced in almost every industry other than health care.

Digital copies of new tests and electronic files should be available immediately in the patient’s own designated banked account. As lab results, physician notes, and tests become electronically available to the physician and provider/facility, a copy should instantaneously be populated into the patient’s own, integrated and aggregated, patient-owned, “banked” EHR.

The patient’s integrated EHR should be transactionally populated, much like the financial community, where each digital transaction is shown in the patient’s “banked account.” It should be integrated and aggregated through the patient’s applications of choice, much like Mint or Quicken aggregate financial transactions. Wherever the patient receives care, the patient receives that information into the patient’s “banked account.” Categories such as labs can be dated and aggregated, and trends and results can then easily be charted by the patient and the patient’s care providers.

For example, as a test result or x-ray is read and becomes digitally available to the institution, the patient should be able to have the results and findings reported electronically to their own application and site of choice. Eventually, in addition to lab reports and radiology reads, relevant photos and images should be included in the patient-owned and integrated EHR.

Near term, providers and patients alike (especially emergency departments) need readily available, shared access to existing images produced for patients. Imaging sharing should be open such that any institution could pull up an image no matter where it is, and that access should be provided across institutions for the patient.

We should eliminate the need for the patient to fill out a form to get access to their information. It should be instantaneously populated, versus up to 30 days. Thirty days is not an acceptable time frame. Those 30 days greatly diminish the quality of care.

Patients should be able to secure what they want to keep private, and readily share what they choose to share with other providers, physicians, family members, caregivers. Patients should be able to determine the level of privacy and to whom they want to share their own integrated EHR. Patients should be able to choose to “time out” that sharing, similar to a feature of the Find My Friends and Life360 apps.

Innovation needs to allow for compatibility of our health records with all technology vendors, and for the ability to analyze, aggregate, and readily share health data.

The standard needs to be that the electronic record is provided instantaneously, mobile, portable, compatible with all applications in the repository of our choice, and allowing for state-of-the-art and future technologies.

We need a transparent patient-centered record with full visibility into all our health records – labs, radiology, prescription fills, and care plans – to ensure the best, timely, informed, and efficient care.

Likewise, we need transparency into the quality, performance, and cost of care. With access to these metrics, we can shop for physicians and medical services at a competitive marketplace, not be restricted to certain providers, and hold both patients and providers accountable for performance.

The patient needs to know per drug administered the cost to the patient, itemized by the care facility. For instance the cost of Zantac administered from an ER versus the acceptable range of costs versus over the counter. The billing system of the hospital needs to be aligned with the patient’s instantaneous care as it’s populated, so that the patient has full transparency into the costs being charged for services rendered. Additionally, when a procedure like an MRI can be done electively, the cost of that MRI other than under emergent care where available, should be provided, and the price range of cost for the patient choice. Any out-of-network cost should be revealed to the patient upfront.

Cost data should be aligned with the EHR and be visible to the patient and physician. Physicians and patients alike are blind as to the ultimate cost of procedures. They are blind to what is “in network” and “out of network.” The “out of network charges are additional charges that occur unknowingly to patients and can be gamed by providers. To ultimately give the patient freedom of knowledge and choice, we need to strive for a near-term goal of attaching the cost to the insurer and the cost to the patient as it is aligned with the care provided for the patient, real time to the doctor and to the patient when available.

With data driven choice, we can utilize sites similar to Yelp, Amazon, and OpenTable to shop, assess quality, and book our care globally. When aggregated health data is readily available for comparative quality, cost, research, and analysis, the cost of care lowers and the quality improves.

The Hippocratic oath is to “do no harm.” Today’s EHR software companies and providers are causing harm to the patient by using protectionism and misusing HIPAA, blocking the patient from this readily available, integrated, longitudinal record of his/her health. Let’s get it done. The technology is all here. It is being used cost effectively in almost every other industry. It would drastically change the economics of health care for the better and greatly improve the quality of care to patients, as well as the quality of the jobs of our health professionals. Let’s do the right thing and make a systemic commitment to enable the complete, integrated EHR and empower the patient and give the patient freedom of choice.

Provide patients ownership…

Provide patients ownership of their health information. In doing so, this will empower the consumer to control their own health information so they can make better choices about their health. Instantaneous population of medical information (labs, films, test results, etc) into the patient portal/health vault. If the patient chooses to have their portal pushed to their own mobile phone health repository, the provider should allow for the push and for the patient to be responsible for the security. It should allow for two-way communication through email. The patient should not have to ask the institution for a copy of the records. The records should be automatically PUSHED. For example, as soon as an x-ray is available to the provider, at least a photo or pertinent information is populated into the patient’s portal and/or mobile application of choice.

We need an open API to allow for eventual aggregators like Mint, or Quicken (which aggregate transactional data in the financial community) to do the same thing for patient EHRs.

There should be ONE patient-owned EHR. The patient-owned EHR should not be a separate record from what the medical community has.

AMA comments on the 2018 ISA

On behalf of American Medical Association (AMA) I appreciate the ability to comment on the 2018 Interoperability Standards Advisory (ISA).


The AMA requests the Current Procedural Terminology (CPT) Consumer Friendly Descriptors (CFDs) be added to the standards listed for Push Patient-Generated Health Data into Integrated EHR. The CFD code set was developed in 2010 in response to industry demand for a patient-focused version of CPT that is comprehensive and useful. The CFDs take the complex terminology of medical procedures and services within CPT and translates it into a language that patients and caregivers can better understand and use. An example is CPT code “Arthrodesis, great toe; metatarsophalangeal joint,” which translates to the CFD “Fusion of great toe.” The CFDs have been included in the Centers for Medicare & Medicaid Services’ (CMS) guidance to Medicare Administrative Contractors (MACs) for adding new CPT codes. One specific example is CMS Transmittal 3670 on the addition of CPT codes to report physical and occupational therapy evaluations.