Patient Engagement as a Two-Way Street Part 3 – Recommendations

In my last post, I spoke of the importance of “getting to know” the patient and asserted that knowing a person can’t be accomplished only by predefined questions. I also referred to the HIT Policy Committee and HIT Standards Committee’s request for comment on Patient-Generated Health Data (PGHD) for Meaningful Use Stage 3 (MU3). Four Siemens employees (including me) submitted comments on that blog last week. Here’s my own summary of the comments, stated as recommendations.

• MU3 should define criteria for EHRs to accept PGHD, initially in either unstructured or structured formats. (Note: “PGHD” should include data not only from patient but from their care givers such as family members)
• Encourage, but don’t mandate, structured data content standards. Define a clear roadmap for standards to come, compatible with data standards for EHRs.
• Clearly define provenance (data source) metadata requirements to inform providers so they can exercise their clinical judgment on how to use the data.
• Focus on relevance, being careful not to overwhelm people with too much data. Allow provider access to additional PGHD where needed.
• While in typical cases the patient is authoritative on many issues, the provider needs to exercise judgment as to trustworthiness in each SPECIFIC patient interaction.
• Avoid being overly prescriptive on which data to gather, but rather let patients say what’s most important to them. We “don’t know what we don’t know.”  
• Strive for wide adoption and low barriers to entry by evaluating and embracing a variety of data entry and viewing technologies most commonly used by patients
• Define clear purposes, expectations and responsibilities for the review and use of PGHD

PGHD is not new: much of today’s healthcare depends on it already. Still, in an increasingly mobile, connected, socially networked culture, there’s a lot more potential for providers to get to know patients better by collaborating with them through the two-way exchange of information. MU1 and MU2 are weighted toward a one-way flow of information from EHRs to patients, but the HIT PC and HIT SC are, commendably, seeking ways to turn this exchange into more of a “two-way street” with PGHD.

Patient Engagement as a Two-Way Street Part 2 – “Getting to Know You”

One of the purposes of patient-generated health data (PGHD) is to help providers know their patients better than they would have otherwise if they relied only on data captured by providers. In my experience, I appreciate doctors who do more physical exams and tests but know more about me that could help them personalize their treatment. As Rodgers and Hammerstein wrote in The King and I, “Getting to know you, getting to know all about you…”

So it is with PGHD. How can it help providers know us better? I worked with colleagues to write a detailed response, which you can find as a comment on the HIT Policy Committee and HIT Standards Committee's blog requesting input on PGHD. I’ll give some highlights in my next installment. The rest of today’s post, while alluding to that response, is my own opinion.

While a patient-provider relationship is special and not necessarily deeply personal, think about how people get to know each other in general. They talk! In ways that can’t be predefined, prescribed, or pigeonholed. Sure there are facts such as your birthday or address. But the vast majority of emotion, experience, and aspirations are richly expressed through natural language. Would you want to get to know someone by filling out structured forms with multiple-choice questions?! So in response to the blog question “does all PGHD for care management need to be in a structured form?” I’d answer a resounding “no!”  As one working in healthcare standards, I understand and fully support the need for structured data in EHRs, for interoperability, analytics, decision support, quality measures, etc. But even if we could magically get all PGHD structured, standardized, tagged, and automatically imported into EHRs, that wouldn’t necessarily make things great. Structured data has precision, but very little nuance. Very few patients think or communicate via structure, and no amount of standards or government regulation will turn patients into health informaticists.

So I suggest crawling before we walk or run when it comes to PGHD. Let’s lower the barrier to entry by embracing PGHD in whatever formats or devices (PCs, smart phones, basic phones with text messaging, etc.) the patients can create it. Yes, there should be a direction for standards so that appropriate data (such as med lists or glucose levels) can flow from patient-facing systems like PHRs into EHRs and be understood. But let patients express themselves in their own words and preserve this in their health record. And speak to them in plain language that they understand (which won’t be structured XML). Then we’ll have the kind of two-way street that will help my providers “get to know me” and deliver the kind of healthcare relationship that I want for myself and my family.

A Harmonious HIT Thanksgiving

Since I’m traveling to visit family over Thanksgiving, I’ll take this opportunity to wish everyone a great holiday week. There’s always time to comment on what could be better! But now’s a good time to reflect on things for which I’m thankful in the HIT industry and my professional career. I won’t lengthen this post with all the personal reasons I have to be thankful, but they are many.

1. I’ve worked in HIT for 34 years at one employer (SMS/Siemens Healthcare). Having a job at all is not to be taken for granted these days, and it’s much more than “a job” because I truly believe HIT, properly applied, can help people.
2. I’ve had so many opportunities to interact with great people from healthcare providers, other vendors, the federal government, states, payers, pharmacies, labs, consumer advocates, certifying bodies, standards developers, and more, who have greatly enriched my understanding and competence.
3. I live in a country where people are free to debate and disagree, but still work together, without fear of reprisal from the government. In fact, we have a government that wants to listen, as evidenced by ONC S&I Framework and public hearings and comment processes.
4. My family and I have received excellent healthcare from many professionals assisted by HIT, and our lives are better (or some are still alive at all) as a result.
5. My colleagues include many healthcare professionals, some of whom have given me high quality medical care, and who use the EHRs that we and other vendors develop, so they understand firsthand what works and what needs to be improved.
6. There are increasing opportunities for me to be engaged, as a patient, in HIT.
7. No one I know is satisfied with the status quo of HIT. We all want it to do more and better in terms of interoperability, usability, efficiency, and promotion of patient safety.
8. There’s much exciting work ahead, so life in HIT is anything but rote and boring!

Have a wonderful Thanksgiving, filled with harmony among those with whom you spend it.

How Will Engaged Patients Get Their Comprehensive Health Information?

As I’ve blogged previously, I believe in the right of patients to access their data. Exercising a right is one thing: deriving benefit is another. The data needs to be usable for the patient or their caregiver/designee. Google Health’s demise, or the fact that patients very rarely ask for an electronic copy of discharge instructions or clinical summary (Stage 1 MU) doesn’t prove that patients don’t want their data: it’s not an “either/or” choice between having convenient functionality vs. having access to the data (see my thoughts here). I’ve made analogies (with caveats) to online banking before. But besides health data being more voluminous and complex than banking data, people usually don’t interact with nearly as many banks as healthcare providers. I as a generally healthy person have visited eight healthcare providers in the last two years, and 12 providers in the last five years. A person with more chronic illnesses would have more providers and far more visits. Will the increasing penetration of EHRs help us as patients? Specifically, how will I get my comprehensive personal health information when it’s scattered in so many different places, electronic or not? Connecting to each one individually doesn’t seem to be the answer.

Here are some ways that might possibly happen (with italicized comments indicating my opinion of feasibility and likelihood):

1. Private or public health information exchanges that connect all my providers (or at least a critical mass), aggregate and perhaps normalize my data, and which have a patient portal with view/download capability for patients.
   A few of these exist, so it may be possible for patients to get somewhat comprehensive information if they stay in the same region or provider network for a while and all those providers share data with the HIE
2. All providers’ EHRs pushing their data to my PHR. This could work with HealthVault, though I don’t know how many other PHRs currently support Direct protocols. The patient can receives separate standardized structured documents (e.g., CCD), but then has the option to merge and reconcile data from those documents into their PHR data fields.
   Unlikely in the near future, though technically possible to the extent that Direct Project becomes adopted and required in Stage 2 MU.
3. All providers’ EHRs making their subset of my data available to me to download, which I then upload into my PHR.
   This is theoretically possible if Stage 2 Meaningful Use continues as proposed by the HIT Policy Committee, but it’s a lot of work for the patient: adds the download + upload steps to the “merge and reconcile” step of #2.
4. Patient Centered Medical Home that aggregates data from multiple providers. Possible in pockets with PCMHs and strong HIE capability
5. All providers having all my data (due to comprehensive information exchange plus EHRs consuming and storing everyone else’s data) so that no matter which one I accessed, I’d have all my personal health info.
   Highly unlikely in the near future, since most EHRs can’t consume and store most of the data. Some EHRs can import some external data, such as medication history.
6. Virtual on-the-fly health record assembled from all sources (similar to the recommendations in the PCAST report).
   Highly unlikely in the near future.

I think #1 and #2 are the most feasible today, though the percent of patients who will actually benefit from them is still low. I’d be interested in your thoughts on what is most likely to gain traction and whether there are other possibilities that are feasible today that I missed.

"Six Months of Strategery?"

I read a story in Modern Healthcare about a discussion with HHS CTO Todd Park at a recent conference in Nashville. He talked about unleashing innovation. I applaud Todd for his bravery in giving out his email address publicly seeking input on innovations, and for his goal of “unlocking the mojo” of HHS staff, rather than having good ideas doomed by “six months of strategery.” I liked that!

There has been plenty of recent discussion, and guidance from NIST about improving EHR Usability (for patient safety, efficiency, and many other reasons). There has also been similar discussion in the HIT Standards Committee implementation workgroup about improving the usability of specifications and standards to remove barriers to adoption so the “little guy” isn’t left behind, and so that everyone doesn’t waste time navigating specs that point to other specs that point to other specs (called “the indirection problem”). Some recent standards efforts, such as the HL7 Consolidated CDA implementation guide, are trying to improve usability of specs in this way.

I plan to write Todd speaking as an individual citizen (remember this blog doesn’t speak for my company though my writing is influenced by working in the Health IT industry). Usability is important for both a positive and a negative reason. Lack of usability (of specs, or software, or anything) tends to waste people’s time and “raise their blood pressure” due to frustration. Wasted a few hours per person multiplied by thousands or millions of people, and you have some serious non-productivity! Worse, it can lead to mistakes (like clinical errors jeopardizing patients) or people throwing up their hands and just not doing things that are too complicated (like refusing to use an EHR). On the positive side, when something is usable, like I consider my search engine, Word processing, email, and blog editing software to be, then people can get amazingly more productive, and can do great things.

What about the usability of the specifications that hover over all of us in the EHR industry, Meaningful Use and Certification regulations? Or for that matter, all Federal regulations published in the Federal Register with its three columns and small print, no index and poor searchability? It’s so “1950’s” and paper-oriented. You can’t just scroll down the page like any normal document or web page, because you have to keep backing up for the next column. Try fitting a page on a screen and you can’t read the tiny font. You can’t search it to find a referenced section number, because the numbers are not a sensible scheme like 178.25.3.2.7, where you always know your context: instead section numbers aren’t even contiguous and searchable. For example, the ONC Standards and Certification Final Rule has text like “The standard specified in § 170.207(a)(2)”  OK, if I want to find that paragraph in the document, it’s easily done in the Acrobat search box, right? Nope, can’t be done! It only finds is the references to the paragraph, but not the paragraph itself. The only way to get to § 170.207(b)(2) is by scrolling around and finally locating 170.207 near the end, then finding subparagraph (b) dangling by itself, and finally finding subsubparagraph (2), hopefully still inside of (b) unless I missed a changed letter in between. And when I finally get there, I still can’t see what the standard is, because it says “the code set specified in 45 CFR 162.1002(a)(2)” which isn’t defined in the document. I have to go out to Google. Those like me who have been doing this for a while know some tricks and short cuts and contacts to ask, but a lot of people don’t have that luxury.

So my suggestion to Todd is very low-tech and has nothing to do with HIT, but a lot to do with usability, productivity, and helping folks actually do what the regulations want them to do! First of all, they need to be able to understand the regs in a reasonable amount of time. I’ve spent hundreds of hours reading regulations affecting HIT. I estimate that just their formatting and numbering alone causes me to spend 50-100% more time to digest them than it should. And I probably also miss important information in the process. Multiply that by thousands of others who have the same problem. While it helps that others have created “Readers Digest versions” to simplify and explain the regulations, but why did they have to create them in the first place?

Could this problem be solved by reformatting new regulations for usability, using a few smart people including human factors engineers, armed with common sense and putting themselves in the “consumer’s” shoes? Could this be done without “six months of strategery?” Hopefully yes, if Todd’s right and “mojo gets unlocked” in this area. I admit that I and probably most people and companies have similar entrenched traditions and rules that get in the way of us doing what we ought to do. I just blogged about this today because I read the interview with Todd and connected his ideas with my reading of the regulations. But the Federal Government’s regulations affect thousands of providers, vendors, and others. There’s a real opportunity for a simple low-tech innovation in the government regulation writing and formatting to help many people avoid wasting time, so they can direct more of their energies to creating innovative solutions that will really help people!

Putting the IT in Care TransITions

On Friday, October 14^th, I look forward to attending a meeting in Washington DC called Putting the ‘IT’ in Care Transitions. That will be followed closely by the ONC S&I Framework Face-to-Face meeting in DC on October 18-19, which will also feature a track on Transitions of Care. Meanwhile, Meaningful Use Stage 2 standards definition marches on, as I wrote in my last blog. Many initiatives are converging (I hope).

The October 14^th meeting will consider three specific patient scenarios: an elderly isolated widow with many chronic conditions; a young child with serious asthma and exacerbating home environment; a homeless man with diabetes and schizophrenia. The premise is: “if the system is designed to assist the most complex patients, then the system will function effectively for all.” I agree with the premise as far as capabilities (more complex scenarios often require more robust capabilities), but I don’t think it’s always true from an adoption and usability perspective. How often have you and I felt that a process or a gadget or a computer UI was “over-engineered” because it was designed for a complex but rare scenario, but was cumbersome for the most common scenarios?

The October 14^th meeting also has a premise that “even the most advanced provider and community organizations acknowledge that new innovation is needed to improve the efficiency and effectiveness of delivering transitional care interventions to large numbers of patients, particularly in an environment in which technology adoption is rapidly growing and the state of technology is changing.” Right on, and so I suggest that these are some key areas for “much new innovation:”

1. Innovative and Usable Presentation of a "just right" level of information to clinicians that avoids the extremes of "information overload fatigue" vs. overly aggressive filtering of information, especially when much information exchange occurs. Can HIT be smart enough to anticipate what a clinician needs? Or must HIT be passive and "do no harm" by leaving all decisions up to the clinician?
2. Policies and guidelines for which electronic information a clinician must read, vs. what they do not need to read. While this is often viewed as a bigger problem for HIE/"Pull" models, it’s a concern even for "push" exchanges, especially if a sender sends information to one provider and copies many others on the "care team." 
3. Reconciliation principles for many types of data, not just medications. E.g., lists of problems/diagnoses, allergies, procedures, and immunizations. The risks vs. rewards of merging, aggregation, deduplication, normalizing across multiple information sources whose vocabularies are not fully standardized. Should HIT strive for “a single source of truth” or just accept that “here is what other sources have said?”
4. Who or what makes a care team? The term is used a lot, but is it clear what makes one? Just knowing who other providers are, and even having access to their records, doesn’t necessarily create a team or a care plan. My hometown football team, the Philadelphia Eagles, has so much talent that some dubbed them a “Dream Team” and surely they know each other’s names and roles, but they aren’t an effective team at the moment. And to play off the meeting title, how will putting the T (Technology) into Team result in better patient Care?

I look forward to blogging about the outcome of these next two meetings.

How Would EHRs Matter to Patients?

In my previous post, I said I’d talk next about patient engagement functions that need EHR data vs. those that don’t.

No doubt, there are some “data-less” functions that can still be useful – you need little or no clinical data to request an appointment, e-mail your doc, or a refill (other than your Rx number). Here’s a list, undoubtedly incomplete, of some functions that I think are Not EHR-dependent vs. those that need (or greatly benefit from) EHR data. Several of the items below are “gray areas.”  

Not EHR-Dependent

• Personal Health Record (PHR) – untethered, if patient is willing to enter the data or settle for existing PHR data feeds (e.g., PBM med history)
• Patient self-service functions (e.g., schedule appointment, request drug refill, view clinical data, pay bill)
• Patient-provider communication and collaboration
• Tools for providers to improve the patient experience
• Technologies to make healthcare more accessible for patients, e.g., telemedicine, virtual visits
• Wellness/lifestyle aids (not just "medical", e.g., diet, exercise, recreation)
• “Find a doctor”
• Search for alternatives to provide services (e.g., price comparisons for services not covered by insurance)
• Patient satisfaction surveys
• Bedside communication with family & friends (e.g., Skype video chat, web access)
• Notification/invitation to events (free screenings, symposiums, etc.)

EHR-Dependent (some may also be provided by Health Information Exchanges)

• Patient access to EHR information (e.g., download)
• Personal Health Record (PHR) – tethered; or untethered PHR with data feeds from EHR (to greatly increase usability)
• Patient Portal
• Patient annotations/amendments to their health information
• Patient provision of information to providers (e.g., home device measurements)
• Providers pushing information to patients via patient preference
• Reminder “app” for taking meds, vaccinations, physical exam, etc.
• Other apps or notifications that help patients follow through with what was prescribed/planned
• Tools for patients to act upon their data (trackers, analytics, access to knowledge)

So patients can accomplish quite a bit without EHRs. But you have questions about your lab or imaging tests and their significance, or your many medications, it sure would help to have the actual data and not rely on memory. I doubt that you’d get full benefit from your med list unless you also knew about your problems/conditions and diagnostic results. I, for one, wouldn’t want to take subsets of my data and redundantly enter it into a dozen separate websites.

If I’m a patient who wants a comprehensive and integrated view of my data, how might I get that? More on that next time…

Do Patients Need and Want Data, or Convenience Features?

So it seems that most patients were not “engaged” to, and certainly not “married on” independent PHRs such as Google. Many people including myself have learned more from failures than successes. Sometimes it helps to learn not just from my own failures but from the failures of others. So while the recent announcement of Google Health demise was no surprise, it offers an opportunity to learn. What do patients want? What do they need? Are needs and wants the same?

Mr HISTalk wrote about what Google Health should have done, and asked what actual users (not only HIT pundits) think. Missy Krasner, a founder of Google Health, echoes some of the same observations about people wanting convenience functionality, not a medical archive. She also asks the same question (“to tether or not to tether”) and comments on PHRs not being “social enough” – see my posts about Being Engaged to Multiple EHRs and Social Healthcare and Social HIT).

So, answering Mr. HISTalk’s call, here’s my experience. I was/am a user of both Google Health and Microsoft HealthVault, hoping that one or both would get over the hump of updating my record with providers’ data so I wouldn’t have to enter it myself. Technically, both of them were partially over that hump since they could import medications from my Pharmacy Benefits Manager (Medco), and Lab Results from my main lab provider (Quest), except that I had to get a physician authorization for the labs (why this barrier?), which was an example of the authentication hassle that Missy mentioned. Microsoft was more proactive than Google in allowing HealthVault PHR updated with discrete data extracted from a clinical summary (e.g., CCD) sent by an EHR via SMTP (email) protocol, which I’ve done successfully. While Google was nominally a member of Direct Project, Microsoft was much more involved and visible. Will HealthVault actually be updated by many EHRs, and even so will it still meet Google’s fate? I won’t speculate on that, except to say that Microsoft made it farther over the hump than Google did.

You Don’t Want Only Data, but You DO Need Data!

Nearly everyone intones that a PHR is not useful if it’s just a passive data “filing cabinet.” They say Google Health just didn’t “DO” enough to capture the minds and time of patients, although both HealthVault and Google Health had “ecosystems” of applications that would work with them. A few years ago, I thought “patient engagement” largely meant PHR (including their ecosystems) + patient portals. But I now realize that patient engagement goes way beyond PHR – I’ve got a large and growing list of what it encompasses. Still, just because functionality and convenience are what “sell,” that does not mean that data is unimportant! A physician or hospital won’t want to buy an EHR just for a raw database if the EHR lacks functionality and usability. But an EHR without a solid data foundation probably won’t be very functional or usable either!

Not all patient engagement is data-dependent. For example, I could schedule an appointment without having any of my electronic health information. In my next blog post, I’ll discuss which patient engagement functions clearly need EHR data, which ones don’t, and which ones are in a gray area.

Happy Independence Day!

Certification Retrospective Part 3 – Controversies Along the Way

Note: this blog post continues my discussion of experiences in CCHIT. The opinions are mine only and do not necessarily reflect the views of CCHIT or Siemens. Please bear this in mind especially considering that the topic is “Controversies”

From my last Certification Retrospective post, I promised to share lessons learned and some “agonizing controversies” we faced in the CCHIT Interoperability workgroup (IOWG). I thought I could do both in one post, but now realize that I’ll need a “Fourth Movement” after this. Each controversy could easily take up a post of its own, but I’ll try to squeeze them into this post, deferring Lessons Learned to Part 4.

1. When should HITSP specs be incorporated into certification? Once HITSP was formed, it (not CCHIT) was designated to select standards. CCHIT, however, could decide when/if those standards would be certified, striking a difficult balance between supporting the federal strategy (HITSP was HHS-funded, CCHIT was partially HHS-funded) and yet being pragmatic. It would have been difficult to require EHRs to develop too much at once when certification was “all or nothing” and not modular. From working in both CCHIT and HITSP, CCHIT tended to give more weight to considerations such as market adoption and lead times, not just whether a suitable standard existed. I along with Jamie Ferguson were appointed to co -chair the 10-member HITSP-CCHIT joint working group, whose goal was to coordinate the work of HITSP and CCHIT and address how/when to include HITSP specs in certification. But some HITSP-selected standards were still in “trial implementation” with little adoption, and the approval of a standard (HL7, HITSP, or any other) didn’t mean it should be mandatory within a specific timeframe. And there were just so many of them to digest, let alone certify! Some people weren’t pleased, thinking that CCHIT should be a more aggressive “enforcement arm” of HITSP. In the end, we included more of HITSP in 2008 and 2009 certification criteria than ONC did in its 2011 certification criteria, most notably the HL7 2.5.1 Laboratory results with LOINC vocabulary starting in 2007, C32 CCD starting in 2008 (adding RxNorm, UNII, SNOMED CT vocabularies in 2009) and HITSP TP13 (IHE XDS.b – see point #2 below). But we also roadmapped (2-3 years out) most other HITSP specs when we published our 2009 criteria. I believe this was a sensible middle of the road approach. IMHO, if we had mandated many more HITSP specs in certification, there would be few or zero certified products today!
2. Should certification require transport standards? Fourth & Ten – we’d better punt! Seriously, we debated this during 2008 and 2009. We recognized this as a glaring gap in interoperability, and wanted to make headway, realizing that lack of secure transport standards would hinder interoperability even if content were standardized. The Direct Project didn’t exist back then. We were aware of diverse ways that HL7 messages were transported, that IHE had defined SOAP-based web services for document transport, and that HITSP had selected many IHE specifications. Many vendors had already tested IHE Cross-Enterprise Document Sharing (XDS.b) at Connectathon. So the IOWG approved XDS.b as 2009 certification criteria (along with PIX/PDQ to support it). But the Board of Commissioners decided to designate these as optional interoperability criteria, not required for certification, because despite the IOWG’s recommendation and strong EHRA support, some commented against it. This was the one case I can recall where my workgroup’s recommendation was overridden by the Board, which I know was a tough decision since the Board usually didn’t do that. This was also a case where we were less aggressive in CCHIT than the EHR Association had proposed. EHRA had sometimes criticized CCHIT for not providing enough lead time, but in this case they were very disappointed that CCHIT had not required this in certification. This one still bothers me as a missed opportunity.
3. Should we require discrete data import, and who owns that decision anyway? We felt that the main point of requiring standardized content formats and vocabularies, not just human readability/liquidity, was for the discrete data to be consumable. Following our “methodical march” mentioned in part 2, we thought in 2008 that the time had come to propose discrete data import (e.g., update your medication, allergy, or problem lists using data from other providers). But now we were into a “boundary condition.” Where did interoperability’s “turf” end and functionality begin? We had a series of “discrete data import” meetings between the IOWG and the Ambulatory and Inpatient Functionality workgroups. We recognized that data must not only be exchanged, it needs to be reconciled (medication reconciliation being an example), and that you can’t just “slam in” all meds, allergies, problems from many external sources to automatically update the active med/allergy/problem list. The functionality workgroups didn’t think the time was right to require such capability in certification for 2009 or 2010. But how were we going to keep making progress toward semantic interoperability? In the end, we proposed criteria to import very specific discrete data elements for medications, allergies, demographics, and immunizations (with problems to come later), as described in my last post. But we didn’t define the functionality, as long as the discrete data were stored somewhere. And in any case, reconciliation criteria would belong to the functionality workgroups, not the IOWG. I think this would have been a reasonable “baby step” but because of the change in certification that started in 2009, those roadmap criteria never had the chance to be certified. I hope that similar careful thought will go into decisions in ONC certification, whenever it gets to that point. End-to-end interoperability involves content creation, secure standardized transport, and content consumption, all of which should be considered holistically.
4. Should we push the industry toward a single standard for clinical problems? This was really part of the broader topic of converging on a singular standard vocabulary for each type of data, but SNOMED CT for problems was the lightning rod topic for several reasons: a) the difficulties of getting physicians to create medical problem lists at all; b) ICD-9 diagnosis codes were already required for reimbursement and some physicians systems were built around ICD-9; c) ICD-10 was already complicating things by looming on the horizon; d) anything that imposed more work on physicians could hinder usability and adoption. So though SNOMED CT seemed a clear winner for an interoperable clinical vocabulary and was HITSP-endorsed, we received considerable pushback from some members of the other workgroups as to how fast SNOMED CT could be required. I was pleased that many in the IOWG stepped up to provide statistics and research facts such as analysis of mapping of ICD-9 to SNOMED CT and clarification that standard codes don’t have to be visible in the clinician’s UI. We knew this was a contentious issue, but staked out our positions in the 2009 roadmap and a Q&A document.

The above four were prototypical of the controversies we faced in content, vocabulary, and transport. I could go on with more examples. That’s part of the challenge of interoperability work, as evidenced by the fact that ONC and the HIT Standards Committee still have all of the above issues to ponder for Stages 2 and beyond. I should mention that one more big controversy arose in the very first year, when CCHIT was newly formed and struggling to figure out how to set the interoperability bar. Eyes were upon those first members to resolve the CDA vs. CCR debate. Unlike the four issues above, where we took a stand, we weren’t ready to force a decision in 2006, and then HITSP was formed by ONC to deal with such “standards harmonization” issues. So at least our punt had a receiver (and football wasn’t locked out)!

I promise that Part 4 will really conclude this series with my thoughts on Lessons Learned, proudest accomplishments, regrets, and hopes for the future, stemming from my CCHIT experience. Thanks for listening to my sharing from “inside the trenches” of discussions of which the public was not aware.

Would You Like to be Engaged to Multiple EHRs?

There’s strong agreement that for meaningful use of Healthcare IT, patients and families need to be “engaged.” The question is, how? In Stage One, patients are to be given an electronic or paper copy of clinical summary information from office visits and hospitalizations, as well as discharge instructions from hospitals. This is good and a step beyond mere paper. But that raises the question of how this information can be used by the patient, other than viewed as if it were paper. What’s the “Quicken” equivalent of a “killer app” for patients to manage their health? (Oops, maybe “killer” app is not so good for healthcare…). The Stage 2 Meaningful Use Request for Comment proposes that patients be able to view and download their information from a “web based portal” that is a module of an EHR (considering that the incentive program is about “certified EHR technology”).

The best tool for any given patient depends on the individual, so speaking in statistical terms may gloss over some things. But let’s suppose that all EHRs were to offer such a portal. How many of them would a patient need to access? For myself last year, that would have been five (four EP and one hospital). According to an article by Peter Bach of Memorial Sloan Kettering Cancer Center, the typical Medicare patient sees seven doctors in four practices in one year, and those with multiple chronic conditions saw 11 docs in seven practices in one year. If you then throw in a hospital, that means eight healthcare organizations possibly with eight EHRs for one patient in a year. If you’re a family member caring for your children or aging relatives, multiply all that. You might have to interact with more than 20 web portal accounts, ending up with over 40 separate downloaded files (you’d probably need more than one per organization per year). Even if they’re in a standardized format, who or what will reconcile or pull them together? Will you be the one, using copy & paste with a spreadsheet or word processor? I don’t think so… If you use a web-based tool specifically designed to deal with those files, well then you’re probably using a Personal Health Record (PHR).

The problem with the current MU proposal for downloading from individual EHRs is that it implicitly endorses a “tethered PHR” model – a PHR extension of an EHR. But that PHR is not really patient-centric, because it contains the patient’s data from the organization using the EHR. Over time, the data will broaden as EHRs import and reconcile data from other sources such as EHRs or Healthcare Information Exchanges, but most EHRs aren’t there yet. And “tethered” is only one of several approaches to patient-centric health records. Other flavors include independent personally-controlled PHRs such as Microsoft’s and Google’s; health record banks; payer-based PHRs such as Blue Cross; employer-based PHRs such as Walmart’s using Dossia. They all have their strengths and weaknesses, but the personally controlled PHR has recently made some significant headway, associated in part with the Direct Project announcement re Dr. Paolo Andre’s EHR and Beth Israel’s Direct Push to Healthvault. If independent PHRs can be updated through a standard transport protocol (Direct secure SMTP), that securely pushes standardized content (e.g., CCD or CCR) into the PHR in a way that is structured and codified, as already required in Stage 1 MU, then the potential for a comprehensive, patient-centered record (not tied to any one provider) has increased. Now this isn’t magic – the patient or family member still needs to decide which data from the CCD are relevant and should be added to their master problem list, medication list, etc., as I’ve done with my own PHR. An ecosystem of innovative products (trackers, monitors) can then flourish around the PHR, given the influx of more robust data to operate on.

In preparing comments to the HIT Policy Committee’s Meaningful Use workgroup, I’ve recommended that MU should focus on the goal: getting the information to the patient or caregiver’s hands in a way that they can use, not on inadvertently favoring an EHR-centric “tethered PHR” flavor. Let the EHRs do the behind the scenes work of transmitting the patient’s info into PHRs of the patient’s choice (which might be any of the flavors I mentioned), enabling patients to interact productively with a tool they like, rather than making them “polygamously engaged” to multiple EHRs/portals and encumbered with lots of files to manually import into PHRs. For patients who don’t want to use a PHR, they can still get their electronic copies (as in MU Stage 1). But for those who want the opportunity to have their electronic information together in one place, there’s a great opportunity for MU, defined in a way that allows flexibility and innovation, to leverage the Direct Project and the existing and emerging clinical content standards like harmonized (I like that word) CDA Consolidation Project templates building upon CCD/C32.  

So, patient and family engagement: yes! Let this relationship between patients and HIT be productive, patient-centered, simple-to-use and... engaging, please!

“Quickening” the Flow of Health Information – Part Two

Sometimes you just have to be quick. And I wasn’t, so Part Two is later than I planned. Here are some more analogies between Quicken (which I use for my “Electronic Financial Record”) and an Electronic Health Record inasmuch as both require information exchange. Of course, “money” and a relatively small data set are exchanged in financial transactions, rather than the vast array of health information. So with that caveat, here I go.

• Making payments is analogous to Direct Project “push” messages. I enter payments that are pushed to payees in a format that they can accept (some electronic, some paper checks). I can enter these payees’ addresses or have Quicken look some up in a directory. My interaction is simple, but Quicken and the financial network (like a healthcare HISP) securely route the transaction behind the scenes.
• Quicken updates my register pulling relevant data from my bank. To me, the bank is analogous to a Healthcare Information Exchange in that it received and aggregated transactions from many payees, so I don’t have to connect to all the payees. I can download from the bank as needed. Of course, the bank has security and privacy protections for my data, similar to how health data must be protected.
• Balancing my register, which occurs automatically, is comparable to data reconciliation in an EHR (though it is much much simpler for money than for health data!)
• I can set up automatic actions such as reminders and payments, which is analogous to workflow automation features in healthcare, where events (like signing a letter or discharging a patient) can trigger data to be transmitted to others.
• Quicken interfaces to tax preparation software such as Turbo Tax, which then files taxes with the IRS and state. This is analogous to healthcare transmissions to public health and quality reporting agencies.

The bottom line is that I use Quicken because it saves time and money and helps me do things that would be hard to do on my own. Just avoiding the late fee on one credit card bill pays for the software investment. I’ll surmise that healthcare providers would insist on those kinds of benefits and more. If a provider can have an EHR that can do more than just the electronic equivalent of FAX -- like quickly match and autofile incoming messages to the right patient, help reconcile the data, notify the user that new information is available, provide clinical decision support, improve efficiency  – that EHR would ultimately pay for itself with or without incentives. All of us who work on EHRs need to keep that in mind: if my professional livelihood depended on using this EHR, would I use it? Personal Health Records (PHRs) are an even closer analogy to Quicken, and I believe that they too need interoperability and Quicken-like value to deliver on their potential (rather than being something that most consumers don’t have time for).

Interestingly, Dr. Clem McDonald (an HIT pioneer) recently  wrote a similar analogy, that ideally healthcare data import ought to be as easy as importing bank statements to Quicken, in his commentary Clinical Decision Support and Rich Clinical Repositories in the Archives of Internal Medicine (sorry, the link used to be public but now requires membership).

To wrap up… securely pushing information, as simply as e-mail, is good progress. Liquidity of information, whether health or financial, enables value to be realized when software acts upon it. Financial software has progressed far beyond just moving information. Healthcare isn’t nearly as far, but it’s advancing and more options are becoming available. Not all EHRs are right for everyone, but I believe that they’re on the road to being as if they were “healthcare Quickens.”

"Quickening" the Flow of Health Information -- Part 1

Yesterday was a big day for The Direct Project, which I’ve been pleased to be able to participate in. Kudos to those who have started demonstrating successful “pushing” of communication of clinical information across providers! As pointed out by many speakers, it’s great to see collaboration for the common good among many organizations that are competitors in the marketplace. There’s a quickening momentum as the trickle of information exchange grows to become a flood.

As ONC's Dr. Blumenthal aptly said, The Direct Project is “a lane in the information highway.” What he didn’t say was “but it’s not the cars, passengers, or cargo being transported down the highway.” That’s an important distinction that not everyone may realize, since the pilots really showcase much work that is outside the scope of Direct, such as “integrating patient data across provider settings and during transitions of care” as one pilot announcement said. Direct was used to transmit the data, but didn’t integrate it, because it’s the highway, not the cars or the place that the car is going to. It’s secure transport, not data content nor use of the content.

One beauty of Direct is that it is unbiased, neutral, toward the content it is transporting. It uses established standards to securely deliver any content to the right place so that only the intended recipient can read it (it’s an honest mailman who doesn’t read your mail). But the content had to exist in electronic form before Direct can encrypt and send it. The data could have come from EHR, or a scanner, or a person typing an e-mail message, but someone or something created it first, and someone else (not Direct itself) does something useful with it on the receiving end.

To the extent that something wonderful is done with the data that’s being sent securely through Direct, that’s done by innovative and usable applications of one sort or another, and while Direct didn’t make those applications, it sends them something to work with. Applications analogous to Quicken. Why do I say that? Well, I’ve often heard the healthcare industry unfavorably compared to other industries like banking, where everyone lauds the benefits of their interoperability through ATMs and the ability of banks to download data into personal financial software like Intuit's Quicken (which I’ve used for years). I'm sometimes skeptical of such comparisons because health data is so different than money. Nevertheless, there are some very useful parallels.

If my connection to the bank securely delivered images of paper bank statements as PDF files, and images of checks, it would have some value by saving postage, trees, drawer space, and a little time. But no one would be satisfied with only those benefits today. My account data is not just delivered as images of checks or my old monthly paper statements; it’s delivered in a discrete “consumable” form that I can use to write checks, transfer money, set up automatic payments, manage a budget, analyze my expenses, search, import into tax software – all while my ledger is automatically kept up to date and saves me from having to do the dreaded “reconcile the checkbook” chore that I thankfully abandoned long ago. The semantic standards are pretty basic compared to healthcare – we agree on dollars and cents and dates and times, not so much on the payees (I realize I’m oversimplifying).

So my message to end today’s post, which I’ll follow up with part 2 in another day or so, is that the flow of health information is quickening, and I’m happy that the Direct Project is playing an important role in doing that. But it’s health IT's Quicken counterpart at the other end that makes it really useful. I believe that to get the most value out of secure health transport, we need to increasingly send content that is human-readable but also appropriately structured and consumable at the receiving end. Deciding what that content should be is work for other projects ahead. Whatever it turns out to be, the Direct Project will help push it quickly where it needs to go.

"All the World's a Stage"...Two

”All the world's a stage,

And all the men and women merely players:

They have their exits and their entrances;

And one man in his time plays many parts,

His acts being seven ages…”

[As You Like It, William Shakespeare]

Oh no, as if music analogies weren’t enough, now I’m quoting Shakespeare? Actually, I’ll confess that I’ve never read As You Like It but I thought of these lines in the context of Healthcare IT and Meaningful Use (MU) Stages. The monologue quoted above goes on to list seven “ages” (which we would call “stages”) of life: infancy, childhood, the lover, the soldier, the justice, old age, dementia/death. I think HIT has gotten beyond infancy, probably into “childhood” and wants to grow more mature with each Stage (stopping well before dementia and death, of course).

The eyes of the HIT world are watching the “players” from the HIT Policy Committee, who are proposing Stage 2 MU which will start in FY2013. When it’s defined, will it be “as we like it” and will we believe it is taking us on the right path? What’s the vision and strategy to which Stage Two is a stepping stone?

Most of us indeed play many parts (roles). For instance, with respect to HIT, I ‘m a public citizen commenting on regulations, standards developer, interoperability champion, product developer, PHR user, patient, and caregiver. The dedicated people on the HIT PC also play many parts  simultaneously, which may include clinician, developer, researcher, business executive, standards developer, and of course policy maker and patient.

Before submitting detailed comments, I want to share some themes and associated issues that I gleaned from my initial reading of the 19-page HIT Policy Committee Meaningful Use workgroup’s Stage 2 recommendations.

• There’s more recognition of the need for evidence to support objectives. A little over three pages of references are given, though I wish that there were more explicit connections between each objective and the citations. Consider that regulations that affect thousands of providers, hundreds of vendors, and millions of patients have high stakes. So it’s reasonable to expect evidence not only of benefits but of associated costs including impacts upon workflows. The public comment period will undoubtedly cause more evidence to surface (and I encourage everyone who comments to include evidence as to why you agree or disagree, not just assertions or emotions).
• There’s a broader view of the clinical team. I see progress towards a balanced perspective with the focus on medication administration, assessments, longitudinal care plan, and care team members, though there’s a lot of room for interpretation as to what the last two mean. There’s also more clarity of clinical/discharge instructions in Stage 2. It’s good to see the acknowledgement of other professionals such as nurses, pharmacists, and therapists, in addition to physicians.
• Patients are increasingly considered part of the team. I’m all for “engaged” patients and consider myself one. The most challenging Stage 2 objective for patient engagement may be the patient download-upon-demand feature for all EHRs. What do patients want out of the data and how does it improve their health? I’d like to see this addressed in the Evidence Base/Rationale section.
• More and more information will be exchanged. That’s no surprise, and can be a good thing for patients and providers, if…it’s usable and relevant, as I wrote in my three part December series starting with Information Liquidity. As stated by Dr. Lyle Berkowitz who gave testimony to the HIT Standards Committee: “Data sharing alone is never enough. Dr. Reid Coleman from Lifespan had the quote of the day when he said,   ‘Data is like salt water… you need a filter to drink it’. I’d also add that it helps to have good plumbing to connect it to the right facilities, and then also to have plenty of glasses available to make it easy for people to get it to the ‘final foot.’”

The Policy Committee has a tough tightrope to walk – on the one hand they’d like to wait for more early returns, evidence of how the industry is doing adopting Stage 1; they could then incorporate those experiences before finalizing Stage 2. On the other hand, they have heard that everyone need lots of lead time to work Stage 2 into their roadmaps, and needs its requirements finalized “yesterday” or at least 18 months beforehand. So they’re trying to send a “signal to the market” but they can’t guarantee that the signal won’t change. They’ll probably receive hundreds of comments. Interesting times lie ahead!

An Aid to Survey the River of Clinical Information

Recently, I’ve had discussions with many people in the HIT industry about the future direction for Meaningful Use (MU), especially about exchanging clinical information. It’s clear that Stage 1 is only the start of a journey, and that increasingly robust sets of clinical information will need to be exchanged. However, such exchanges need to be helpful rather than burdensome, and much work needs to occur to figure out how to display what’s significant, accurate, reconciled, and usable for clinicians and patients (see my recent blog series Part 1, Part 2, Finale).

I’m sharing a spreadsheet (a work in progress) showing a library of standardized reusable data sections and comparing many types of electronic clinical documents/records, including the two most “famous” that are required in Meaningful Use Stage 1, CCD and CCR. This spreadsheet may eventually be published in a more final form from an organization, but even now it may be useful to you if you have any of these questions:

• What must be shared in Stage 1 as a clinical summary with providers and/or patients? (See spreadsheet columns B and D green cells)
• Are certification and MU clinical summaries the same? There are some interesting differences that can be found between the standards for certification and the language for meaningful use (See column A and the CMS FR – Clinical Summary tab).
• What’s the difference between a full C32 and what’s required in Stage 1 certification? Quite a bit, actually! (See column D, white check marks)
• What data are not included in CCR and CCD but might be desirable to share in the future? (See all rows and columns). Stage 1 requires only the most commonly requested clinical summary data (meds, allergies, problems, results, etc.).
• How much reusability exists among today’s electronic clinical documents? (See column Q, which also indicates which sections are most often used). There are worthy efforts afoot to improve commonality and reduce divergence, such as the ONC sponsored CDA Consolidation Project. 

Here’s my compulsory “liquid” or “music” analogy of the day. A mighty rushing river is growing, of clinical information and the standards thereof. I hope my high-level spreadsheet serves as an aid, a “Bridge Over Troubled Water” where you can safely survey the river before you plunge in. Although I created this spreadsheet, with plenty of review from Health Story and EHRA members, I’m far from being the authority on clinical documents. Robin Raiford did wonderful work on a similar spreadsheet in 2009, which was actually more detailed, but was limited to HITSP CDA documents and preceded the ONC Final Rules. I recommend that you read the original specs, and follow Keith Boone’s blog and his upcoming CDA book.

Finale: Drinking Safely and Healthily from Liquid Information

Happy New Year! If you must drink, do it responsibly and safely. Which brings us to the subject of this Finale to a blog series that started here. How can Health IT systems help clinicians to consume/drink the liquid information that will increasingly flow to them? How can these systems help users protect both patient safety and clinician productivity?

The faucet has been opened. It’s fairly easy to tell developers to send clinical information to others. It’s harder to know what to tell providers to do with what they receive. The trickle of information exchange hasn’t become a flood yet, but let’s be prepared! Clinicians want the information to be usable, not a hindrance. They want to do the right thing, but they can’t afford to reduce their capacity to see patients, and they don’t want to be liable for negligence if they can’t read every word of every available electronic record for the patient. Policies and guidelines for realistic expectations and duties of clinicians to retrieve and read electronic information would be very helpful coming from medical, legal, and health information management professional associations.

Patient safety is impacted both if there’s inadequate information flow but also if there’s too much. We’ve heard of “alert fatigue” in clinical systems, and could face “information overload fatigue” too, where important information is obscured by “noise” that could lead to errors or duplication as occur in the absence of information flow. While the PCAST report on health information technology proposes applying search technology (good idea), that may be helpful but insufficient. I can “Google” anything, but how often do you or I look beyond the first page of results, even when there are thousands of hits? I implicitly rely upon the search engine to display the most relevant links first, since my time is limited. While a patient’s medical records are much less voluminous than data in web searches, even dealing with only 24 clinical documents per my personal health example requires indicators of relevance to aid decision making. If I don’t look at Google search results page 2, it’s probably not a big deal, but the stakes are much higher for patient care: who can decide what’s most important to show for a clinical encounter, especially since that varies depending on the encounter’s purpose?

Thankfully, healthcare and academic organizations realize the need to tackle this challenge. I was fascinated by the findings from this medication reconciliation project at Partners Healthcare: “design of a novel application and the associated services that aggregate medication data from EMR and CPOE systems so that clinicians can efficiently generate an accurate pre-admission medication list.” It was pioneering work at the time, and was a springboard for further research, such as refined aggregation algorithms based on more standardized data, and clinician-vetted UI techniques to reduce cognitive burden and add value.

In 2008 when I helped interoperability and ambulatory workgroups (including physicians, nurses, pharmacists, engineers, and others) write the CCHIT certification criteria and roadmap through 2011, we proposed 2009 as a first step in consumption of discrete data such as medications and allergies from C32 CCDs, but concluded that we shouldn’t be prescriptive about EHR functionality or workflow to handle such data.

Medications are just one example of data that needs to be reconciled after being exchanged. A new clinical data Reconciliation project at IHE offers promise to advance the cause of clinical decision support for reconciling problems, allergies, medications, and more. It’s humbling to acknowledge that HIT isn’t so sophisticated or trusted to make clinical decisions, any more than web search can buy your next car automatically. Instead, we should share the results of research to inform and stimulate innovations that are then tested in multiple care settings, before even thinking about regulating and standardizing functionality. But I’m all for specifying how standardized information exchanges can be inputs to these innovative algorithms and UIs.

To return to my musical analogy, music isn’t just playing the notes in a score: but rather how the score is brought to life to touch the heart through the genius of great performers. We shouldn’t try to turn musicians into robots where every nuance is pre-programmed. Similarly, in HIT MUsic, there’s room for the art as well as the science!

If anyone reading this can point to interesting research and experiences regarding consuming health information that’s exchanged, I’d love to hear about them. The results would benefit providers and developers EHRs and HIEs as well.

Andante: What Happens When the Trickle Becomes a Flood?

This is the second part of a “Symphony in Three Movements” blog. The second movement of a symphony is often the slow movement: Andante literally means “a moderately slow tempo (a walking pace).” The first movement (information liquidity) is Allegro (fast, lively) because there’s a national momentum around Meaningful Use (MU). But using/consuming/”drinking” the information has moved slowly for reasons that I’ll discuss now.

All of us have experienced information overload (too much paper mail, e-mail, so many web sites and so little time). Many messages compete for our attention and go unread. So when we advocate health information liquidity, and it comes, we need to be careful what we wish for!

As a patient, father and grandfather, I want clinicians to be helped, not burdened, by availability of my family’s information. So I’d like to know: what do they consider helpful? To starting think through this question, let’s consider a real world scenario rather than abstractions: myself as a patient (I consent to this disclosure of my health information).

Over the past year, as a relatively healthy person who took four sick days from work, I had the following medical encounters:

• one ER visit followed by an additional day of hospital care for a “transient global amnesia” attack, which hopefully won’t recur
• Two PCP visits: one routine annual physical, plus one following up the hospitalization
• One Neurologist office visit following up the hospitalization
• Two dermatology visits with minor procedures performed
• One GI visit, related to a procedure performed in 2008
• I also had dental and chiropractic visits

That’s 7 medical visits. The hospital has an EHR, and my PCP is starting to use one, but I don’t know about the others. Let’s hypothesize that they all are meaningful users of EHRs. Then they would have produced at least 16 electronic clinical documents: 7 clinical summaries and one discharge summary for the next provider, 7 electronic copies of health information and one discharge instructions document for me. I’m not counting other MU information exchanges such as e-prescriptions, immunization registry updates (one flu shot), nor reportable labs or surveillance. Here I’ll just focus on the clinical documents, realizing that much more information can also be exchanged (results for lab, EEG, EKG, CT, Echo; consult notes, etc.). If 2011 and 2012 are like 2010, then by 2013 I’d have 24 or more electronic clinical documents available to other providers. People with serious or chronic illnesses could have far more. So what should my providers in 2013 look at? All 24 documents? How would they decide what’s important and relevant? Most of these documents will be partly duplicative but may not list exactly the same problems, procedures, allergies, etc. To what extent does this additional information (and the effort to digest it) save time or work elsewhere? As far as I know, these aren’t simple questions with simple answers, but I’d be interested in your thoughts.

At a minimum in 2013 I’d expect the hospital to send (push) electronically a discharge summary and/or a CCD to my PCP and the Neurologist, who will then read them. The Direct Project has received a lot of attention because it has clear applicability to common scenarios like discharges, referrals, and consults. But that’s a drop in the bucket compared to all patient’s electronic health information, so there remains a big challenge about what to do with the rest of it.

As reported in the recent PCAST report, p.15, lack of liquidity and interoperability produces this problem: “In effect, the patient has fragmented into disconnected facts and clusters of symptoms. To prevent the most basic medical errors, some facts are elicited over and over again, to the frustration of patients and healthcare providers alike: ‘Do you have any drug allergies? Have you had any surgeries? Are you taking aspirin or blood thinners?’ This frustrating repetition works, albeit inefficiently, if the patient is cognitively intact and well informed, but not all patients fit that description, especially in the event of a serious or acute illness. Health providers need views of the patient that are less fragmented than at present.” And so along comes information liquidity to remedy the fragmentation – or does it? PCAST report p. 23 says: "A first point to convey is that in virtually all of our use cases, the “user” of the data does not need to be, and indeed should not be, scanning through the entire health record. Instead, the user needs to be looking at an application layer that accesses and presents a limited amount of information from a given health record or set of records."

That “application layer” has slowly been emerging in pockets of HIT, perhaps because the information exchange is still a trickle, not a flood yet. Do clinicians trust a layer to limit the information they see? What’s the right balance between too much and too little? Though I’m a standards advocate, I’m not sure we’re ready for standards in this area, but we do need research, innovation, real-world implementation testing, evidence of what works and what doesn’t, sharing of experiences, policies, and guidance. In my third and final movement of this series, I’ll talk about some promising research and projects underway to improve the usability and benefits of the information that flows. Despite what I said about the challenges, I’m optimistic that we (collectively) will figure this out.

In the meantime, while you await the finale of this symphony, Happy Holidays and Merry Christmas to you!