July 25, 2008

OpenEMR Live Launched

GNU/Linux Medical Software News /

OpenEMR HQ announced the official launch of their OpenEMR Live fully hosted EMR solution earlier today in a conference call with developers, employees, and clients. The service, according to their website, removes the headache associated with running an in-house application server and the cost of keeping a full-time IT person on staff. It also reduces compliance issues, eases administrative burden, and provides data monitoring, faster response times, and full disaster recovery service should something go wrong.

OpenEMR HQ CMO, Michael Kesley, said this solution was specifically brought out by the company as part of their 'EveryClinic' program which seeks to create OpenEMR products to serve clinics and practices of all sizes regardless of financial constraints or staff availability.

"We believe that OpenEMR Live, will finally allow physicians and clinics with no technical knowledge to effectively implement OpenEMR within their practice without having the added expense of taking on a new, full-time IT person", Kesley said during the call.

OpenEMR HQ announced the availability of the OpenEMR OpenServer, which provides a fully configured OpenEMR in-house server to clients, early last week and reports that, since the announcement, they're seeing a sharp rise in the number of clinics contacting them in regards to implementing OpenEMR.

Hugh Greeley & Partners - New Healthcare Consulting Partnership

MSSPNexus Blog / Rita Schwab

Hugh Greeley, Todd Sagin MD, JD & John McGinty have formed a new healthcare consulting firm called Hugh Greeley & Partners. 

The company's website states:

In addition to addressing focused consulting needs, Hugh Greeley & Partners provides educational programs, leadership training, keynote addresses, retreat facilitation, mediation services, and mentorship relationships with individuals or organizations. Additional services include the provision of expertise to law firms engaged in healthcare litigation and external peer review resources to hospitals and medical staffs.

 

July 24, 2008

Google Health Video

HealthNex / Jack Mason

If anyone needed further proof that Healthcare 2.0, ehealth or whatever you want to call it is coming, one need only look at the major push that the good folks at Google are making on this front:

Intensive Data for Intensive Care of Premature Babies.

HealthNex / Jack Mason

I've been woefully inattentive to Healthnex of late -- for good reasons, all related to other avenues of IBM innovation projects -- but thought this bit of news warranted cranking up a post, even if its just a pointer to a story. Why? I think it underscores IBM's commitment (one of the three core values around which the company is supposed to operate) ... innovation that matters, to the company and the world. That ideal, which I didn't fully appreciate when I first joined IBM four years ago, is, I think, much more than a slogan or a nice bit of PR. In fact, itcontinues to be one of the most compelling reasons to be at IBM: the opportunity to do work that can make a real difference in real lives.





&&&&&IBM (NYSE: IBM) and the University of Ontario Institute of Technology (UOIT) announced today a first-of-a-kind research project to help doctors detect subtle changes in the condition of critically ill premature babies.

The project will see a group of internationally recognized researchers, led by Dr. Carolyn McGregor, a UOIT associate professor and Canada Research Chair in Health Informatics, use advanced stream computing software developed by IBM Research to work toward greatly enhancing the decision-making capabilities of doctors. The software ingests a constant stream of biomedical data, such as heart rate and respiration, along with environmental data gathered from advanced sensors and more traditional monitoring equipment on and around the babies.

(see rest of story on CNNMoney)

Poliner Decision Reversed by Fifth Circuit Court of Appeals

MSSPNexus Blog / Rita Schwab

The Poliner case generated much attention and concern when a jury awarded $366 million in damages to a Texas cardiologist who challenged a peer review action. (The damages were later reduced to $22 million.)

On July 23rd the Fifth Circuit Court of Appeals reversed the district court's decision, holding that the actions of the hospital and its Chair of Internal Medicine were protected under the Health Care Quality Improvement Act.  Horty Springer has posted the full text of the court's decision on their web site: Poliner v. Texas Health Systems.

Thanks to Nena Ickes, CPMSM, CPCS, from 3M Health Information Systems, for this breaking news tip. 

Previous MSSPNexus posts about Poliner

http://msspnexus.blogs.com/mspblog/2006/03/court_upholds_j.html

http://msspnexus.blogs.com/mspblog/2006/12/follow_your_byl.html

 

 

OrganizedWisdom Featured in BusinessWeek!

Health Wisdom Blog / Unity Stoakes

Bw_255x54_2 We're thrilled to be featured in BusinessWeek this week in an article titled: To Expand Your Business, Go Home. The subhead reads: Moving out of your brick and mortar offices and running your company soley online can cut expenses and boost productivity. Which is exactly what has happened in our experience as we build OrganizedWisdom.com.

We so excited because the piece highlights the way we are building our business, which we call Going Green Virtually.  I wrote a post about this (The 20 Benefits of Building A Green Start-up and Going Virtual) a couple of week's ago and we plan on sharing many more of our lessons learned and also some specific tips and advice based on our experience building OrganizedWisdom.

If you have advice or tips about your experience building a virtual business to get better results we hope you will share them with us in the comments! 

Podcast: The Value of Human Powered Search

Health Wisdom Blog / Unity Stoakes

Alt Search Engines Editor Charles Knight interviewed OrganizedWisdom and Kosmix yesterday for an enlightening discussion about the value of human powered search. It runs about 30 minutes long.

You can listen to the podcast here.

Do we really have the societal wisdom to put all healthcare data online?

Health Care Renewal / MedInformaticsMD

The following story on IT security is simply stunning in its layers of apparent ineptitude.



I further find at this link that this system administrator was once convicted in Kansas of aggravated robbery and served time.




Yet numerous constituents of the "
Health IT Ecosystem" (a title I use to describe the complex HIT environment, link) espouse the value of national healthcare and genetics databases to be stored by commercial companies such as Google and Microsoft, and/or the Federal Government.



This raises the question: in 2008, do we really have the levels of societal wisdom necessary to put all health care data online?



-- SS



One admin's missing password leaves San Francisco in a lockdown state



By Michael Hatamoto , BetaNews

July 18, 2008, 5:00 PM



A former San Francisco city computer network administrator remains in a Bay Area jail after pleading not guilty to four charges of computer tampering. Meanwhile, the city's computer network is in limbo.



Prior to his arrest, Terry Childs, 43, of Pittsburg, California, managed to manipulate the city's computer system, creating a password that has effectively locked out all other city network administrators. As an employee in the San Francisco Department of Technology Information Services, he helped create a new network used for the San Francisco FiberWAN (wide-area network), his former defender said.



The FiberWAN network is responsible for controlling the city's e-mails, law enforcement records, payroll, and personal records. It controls 60 percent of the city's municipal data that also includes lawyer information and 311 information system.



In an interview today with the San Francisco Chronicle , Childs' attorney, Erin Crane, characterized his client as willing to cooperate, but may only turn over the password city officials need to operate their network after negotiations have concluded. Crane described Childs as more than the network's administrator -- indeed, as its architect.



Childs pleaded not guilty yesterday in San Francisco Superior Court, and is now being held in custody on $5 million bail. He will next face a bail hearing on Wednesday, July 23.



The public defender who initially defended Terry Childs, Mark Jacobs, removed himself from the case over suspected conflict of interest, after it was learned his own records were among those included in the files that Childs still holds hostage.



Specifically, Childs stopped authorized network users from accessing to parts of the network they should be authorized to use, and also enabled his own access to sections of the network to which he should have been restricted while he worked for the city, San Francisco district attorney spokespeople said.



Computer security experts have been quick to chastise the city for letting one person have access to the entire system, while recommending each person should only have access to a piece of the network. Aside from Childs, it's believed five or six people are expected to have accounts enabling universal access to everything in the network, though the identity or whereabouts of those individuals has not been made known.



In another mistake, the city apparently did not keep adequate system backups, which they could have used to restore the network and its passwords by now. Even so, it's unknown if there are any backups of the system and password, and if Childs also locked the administrator account from those backups.



There has been no data breach, no tampering with the system itself, and the only problem at the moment is that everyone is locked out, city officials confirmed.



San Francisco Mayor Gavin Newsom, city officials, and Cisco engineers are still trying to resolve network issues about five days after the initial incident. Earlier in the week, Mayor Newsom said it could take up to eight weeks to fully restore the network to working order, costing the city thousands of dollars in resources. But the eight week prediction is a worst-case scenario, in which an entirely new infrastructure would have to be built, and the current network dismantled.



During a press conference earlier in the week, Mayor Newsom described Childs as a "rogue employee" who became "a bit maniacal and full of himself."



The network restoration could happen much faster and easier with cooperation from Childs, who had said several times that he does not plan to help the city fix the network. After Childs' first court appearance, attorney Crane said this an entire issue was nothing but a misunderstanding, that the media and public had blown out of proportion.



Although the D.A. has not released the full criminal complaint against Childs, and what would have led him to do this, local Bay Area media outlets reported an alleged dispute between Childs and one of his managers. Unconfirmed reports indicate he was to be suspended on July 9 for alleged insubordination.



With little known details available out the case, the media, both professional admins and the general public have already formed their own opinion about the case, saying it's ludicrous that someone who has yet to hurt someone is being held on $5 million bail. Others, however, said effectively hijacking an entire city's computer network and holding it hostage is the wrong course of action, regardless of what grievances he has against his employers.



Even though Childs remains in police custody, he is still receiving paychecks from his $127,735 per year salary. Moving forward, the city of San Francisco hopes to work with Childs and his attorney to resolve the network issues in a timely matter, though specific talks are taking place behind closed



Another Piece of the Extended Puzzle - Proposed DOL Regulations Reach to General Prudence Rules

BNA Pension and Benefits Blog / Andrew Oringer

Issues relating to fees to service providers have become high-profile issues, with a proliferation of indirect-fee class actions and the inevitable follow-on press reports. These issues have given rise to a four-piece puzzle, with activity regarding (i) regulations under ERISA Section 408(b)(2), (ii) the rules governing Form 5500, Schedule C, (iii) the "404(c)" rules for covered plans with participant-directed investments, and (iv) a number of legislative proposals in Congress.

The issue is clearly front-burner for the DOL, which is trying to proceed with a coordinated new regime that would have a real impact on the quantity and quality of information available to participants. There has already been movement in the first two arenas, with proposed 408(b)(2) regulations and new rules for Form 5500, Schedule C, both of which have been controversial. Congress has proceeded, too, with the proposed Miller bill. The only theater that had remained dark was the one relating to the 404(c) rules.

Section 404(c) is the section that gives plan fiduciaries the opportunity to limit their liability in the case of plans which provide for participant-directed investments and which satisfy the regulatory Section 404(c) requirements. Thus, the DOL had broad discretion to impose such informational requirements as it saw fit under Section 404(c). Showing how much attention it is giving to the question of participant information, though, the DOL took this opportunity to expand the expected scope of its rulemaking and issue rules proposed to apply under ERISA's general prudence rules, whether or not the protection of Section 404(c) is sought. The general prudence rules, like the 404(c) rules, give the DOL a fairly free regulatory hand, as there is no clear limitation on the abilty to add regulatory color on what it means to be proceeding in accordance with general prudence-type considerations.  Thus, the new proposals would generally apply to all plans under which participants have the right to direct investments, even if the plan sponsor is willing to forego Section 404(c) relief. It is clear that that the DOL is making a concerted effort to establish a set of rules that will significantly change the nature of the information that is broadly available to participants in plans where they direct their own investments.

It remains to be seen whether the market will view the balance that has so far been struck by the DOL as being the right one. I expect the comment process regarding this particular piece of the puzzle to be extremely active in terms of submissions on all sides of the market, including participant-advocacy groups, employers, financial services organizations and administrators. One thing seems certain - the old rules, with a much more generic approach to the provision of information, seem eventually to be a thing of the past.

PMSI sale - the numbers

Managed Care Matters / Joe Paduda

In today's earnings announcement, AmerisourceBergen, parent company of work comp PBM/ancillary services firm PMSI, detailed the financial impact of the deal.

ABC carried PMSI on the books at about $260 million; by selling the property for $40 million (plus a $10 million contingency) ABC will be taking a $222 million hit as a result of the transaction. On an earnings per share basis the result is 1.37 per share, giving ABC a net loss of $108 million, or 67 cents per share.

Observers who are confused about the recent on-again, off-again status of the PMSI sale can be forgiven for that confusion; ABC has been somewhat schizophrenic about its dealings with PMSI. After putting PMSI on the market early this year, ABC announced last month that the company was not going to sell PMSI after the initial offers came in well under expectations. According to ABC's CEO David Yost, "We look to PMSI to be on track in the September quarter and into fiscal '09."

Contrast this with Yost's announcement today - “We were very disappointed with PMSI’s performance in this quarter, and after re-evaluating our alternatives, we decided to sell the PMSI workers’ compensation business in order to focus our full attention on our pharmaceutical distribution and related businesses and allow H.I.G. to focus on the opportunities at PMSI."

ABC's impatience with the turnaround may have played a role, but from here it looks like the hammering Yost took over ABC's overall financial performance to date may have been more of a motivator.

HIG, the investment firm that bought PMSI does have some experience in this space with investments in Align Networks and Gould and Lamb. They have been quite successful in selling properties and generating rich returns for their investors, a history that bodes well for PMSI. And for the PMSI employees who add value, are flexible, focus on customers, and don't buy into the "we do it that way because that's the way we've always done it" nonsense.



Medicare Part D data available

Healthcare Economist / Jason Shafrin

For researchers interested in studying the Medicare prescription drug benefit, CMS has claims data for Medicare Part D.  Academy Health also has a useful powerpoint presentation giving some more information regarding Medicare Part D and what information is available as part of the CMS Medicare Part D claims data.

Attacking "Side Effects" with Logical Fallacies, Version 2

Health Care Renewal / Roy M. Poses MD

Side Effects by Alison Bass continues to generate controversy. As described by a reviewer in the New England Journal of Medicine,(1) the book

used the case of Paxil to expose the unsavory and self-serving relationships among members of the pharmaceutical industry, psychiatrists, and members of the FDA.


The reviewer concluded,

Bass's riveting and well-researched account of these disturbing ties should be widely read by members of the medical profession, many of whom continue to believe, despite all evidence to the contrary, that they are immune to the influence of drug companies.

We previously posted about how the book inspired one reviewer to unleash a series of logical fallacies in an apparent attempt to discredit Bass and Side Effects. Now a review by AJ Gelenberg has appeared in Health Affairs, the respected scholarly journal of health care and health policy research, which also employed its share of logical fallacies.(2)



Ad Hominem



One of Galenberg's main arguments was that Side Effects treated as black and white a story that is really about shades of gray. Furthermore, he alleged that "its hyperbole and 'villains-versus-heroes' style do no justice to a pressing public health issue." From there, he tried to discredit two of its "heroes."



One hero, a psychiatrist, admitted to a series of boundary violations with a patient that caused me to blanch. But no matter; he’s a good guy, and the author declares his intent to be pure. Another of her bigger-than-life heroes is Eliot Spitzer. The prepublication version of Bass’s book I read was written before Spitzer’s resignation as New York’s governor. I wonder if her heroes get redacted when their feet turn out to be made of clay.





Bass actually used a number of pages to address the allegations of malpractice made against the "hero" psychiatrist. But the psychiatrist's role in the book was the early raising of the hypothesis that selective serotonin uptake inhibitor (SSRI) anti-depressants may lead to suicidal ideation. Whether that hypothesis is true, and whether or not other people sought to manipulate or suppress evidence relevant to it were the real questions Side Effects addressed. The psychiatrist's conduct with a particular patient are irrelevant to their answers.



Similarly, although Elliot Spitzer did oversee the lawsuit against GlaxoSmithKline, the manufacturer of Paxil, his conduct years later that lead to his resignation as Governor of New York had nothing to do with this lawsuit or the issues it raised. Furthermore, Side Effects focused on how his staff investigated the relevant facts and pursued the lawsuit. Spitzer's role on the ground was minimal.



Thus, a single paragraph in Galentberg's Health Affairs review employed the ad hominem fallacy twice. This fallacy may be defined one "in which a claim or argument is rejected on the basis of some irrelevant fact about the author of or the person presenting the claim or argument. Typically, this fallacy involves two steps. First, an attack against the character of person making the claim, her circumstances, or her actions is made (or the character, circumstances, or actions of the person reporting the claim). Second, this attack is taken to be evidence against the claim or argument the person in question is making (or presenting)."



Guilt By Association



Later, Galenberg wrote,



I worry that Bass’s book can do harm with its broad-brush smear.



So,







Scientologists could find support for their cruel and misinformed agenda of laying waste an area of medical care that is tragically stigmatized.





Of course, anything written by anyone could be misinterpreted by someone else, or used in conjunction with yet more logical fallacies to provide erroneous support of an unrelated position. I submit that implying that Scientologists, not a group discussed or addressed in Side Effects, would be so involved was an attempt at asserting guilt by assocation. This may be defined as one "in which a person rejects a claim simply because it is pointed out that people she dislikes accept the claim."



Slippery Slope



Galenberg's worry noted above lead to a dire warning,



Worst of all, patients and their families could turn away from needed attention and further compound the neglect of psychiatric disorders.





Galenberg did not explain how Bass' book, devoted as it was to the case of the marketing and research of single drug, could undermine all of psychiatric care. Thus, this appears to be a slippery slope, defined as a fallacy "in which a person asserts that some event must inevitably follow from another without any argument for the inevitability of the event in question."



Conclusion



What Galenberg's review did not do is meaningfully address the facts presented in the book, and Bass' main interpretation of them. Side Effects argued that clinical research evidence specifically about the safety of SSRIs for children and adolescents, not adults was suppressed and manipulated. In fact, there is now considerable evidence that SSRIs may have risks for children and adolescents that were not appreciated until recently, and may not be very efficacious for younger patients. For example, the systematic review by Whittington et al included published and unpublished data from randomized controlled trials of SSRIs in children and adolescents.(3) Its abstact concluded "published data suggest a favourable risk-benefit profile for some SSRIs; however addition of unpublished data indicates that risks could outweigh benefits of these drugs (except fluoxetine) to treat depression in children and young people. The systematic review of published trials by Fergusson et al concluded there was "an association between suicide attempts and the use of SSRIs."(4)



Galenberg concluded on the regretful note,



I wish that Alison Bass had been more credible and responsible in presenting this dilemma and the underlying facts.



However, Galenberg never provided evidence or clear arguments that disputed the "underlying facts." Rather, this review, like the one by Herrmann, seemed at best to show the reviewer's distaste for Side Effects, rather than the source of that emotion.



Galenberg did allude in his review to his background,



I have consulted to the pharmaceutical industry, given lectures they have funded, and taken educational and research funds from them through my university.



He did not specify the companies for which he worked, the topic or purpose of the consultations, the nature of the lectures he gave, or the research he pursued. However, a quick search revealed that one of his colleagues in such research pursuits was Dr Martin Keller, one of the "villains," to use Galenberg's term, in Bass' book. (For example, see this article by Keller et al from 2007.[5]) The disclosures in that study included,



Dr. Gelenberg is a consultant to Eli Lilly, Pfizer, Best Practice, AstraZeneca, Wyeth, Cyberonics, Novartis, Forest, and GlaxoSmithKline; has stock options with Vela Pharmaceuticals; and has received research grants (to the University of Arizona) from Novartis.



Thus, this seems to be yet another in our series of cases of confused defenses of financial entanglements among industry and academics. Such confusion seems likely to appear in arguments made by people who themselves may have relevant conflicts of interest. As Joe Collier said, " people who have conflicts of interest often find giving clear advice (or opinions) particularly difficult."(6)



I would submit that Dr Gelenberg's review perhaps unintentionally supports the argument that physicians' and academics' financial entanglements with organizations with vested interests in promoting products, services, or ideologies should not merely be disclosed and managed, but should be materially reduced, if not eliminated.





References



1. Friedman RA. Side effects: a prosecutor, a whistleblower, and a bestselling antidepressant on trial. N Engl J Med 2008; 358: 2852. Link
here.



2. Gelenberg AJ. Warning: Side Effects may include distorted vision. Health Aff 2008; 27: 1193-4. Link
here.



3. Whittington CJ, Kendall T, Fonagy P, Cottrell D, Cotgrove A, Boddington E. Selective serotonin reuptake inhibitors in childhood depression: systematic review of published version unpublished data. Lancet 2004; 363: 1341-1345.



4. Kirsch I, Deacon BJ, Medina-Huedo TB, Scoboria A, Moore TJ, Johnson BT. Initial severity and antidepressant benefits: meta-analysis of data submitted to the Food and Drug Administration. PLoS Med 5(2): e45 . Link
here.



5. Keller MB, Trivedi MH, Thase ME, Shelton RC, Kornstein SG, Nemeroff CB, Friedman ES, Gelenberg AJ et al. The prevention of recurrent episodes of depression with venlafaxine for two years (PREVENT) study: outcomes from the 2-year and combined maintenance phase. J Clin Psychiatr 2007; 68: 1246-1256. Link
here.



6. Collier J. The price of independence. Br Med J 2006; 332: 1447-9. Link here.

Physicians: Health Cost Elephants in the Room?

mediinovationblog / Richard L. Reece, MD

Call it what you will - gaming, flat of the curve medicine, perverse fee-for-service incentives, doing more to make more, inappropriate testing or treatment to maximize income, defensive medicine, self-referral, or, on the flip side, enlightened self-interest.



Whatever you call it, a bevy of critics are saying the elephant in the room causing excessive health costs are “ungoverned” doctors in small practices, large practices, and academic medical centers are ordering tests, doing operations, mindlessly over-using technology, referring to themselves, buying unneeded technologies, cutting deals -- all to maximize income rather than practicing “quality” medicine to make patients better or to enhance outcomes. These critics tend to inhabit office suites of payers far removed from action on the ground and from what drives doctors and their patients.



I run across these critics often when I write of health reform. Their comments, generally nonspecific or sotto voce so as not to be overhead, run along these lines,” We’r to blame for these high costs.” “We’re the villains.” “What else can you do in a system like this when Medicare and health plans keep ratcheting down your reimbursements.?” Or, “It’s just plain greed.”



Now I am not one to sit in judgment of my fellow physicians. We all do things for a reason, and all of us take steps to stabilize our revenues. There are a lot of factors at work here, including high education debts and escalating, escalating overhead, and whole new set of suggested (expesnive) solutions – protocols, evidence-based medicine, P4P, and, of course, that ceaseless pressure to install EMRs at your own expense in the name of quality.



And the solutions are myriad as well;



• Place doctors on salary to remove financial incentives.

• Slash pay gaps between specialists and primary care doctors and produce more of the latter, who cost less.

• Make all pricing and costs transparent and public.

• Bundle hospital and doctor bills so consumers can know in advance what to expect.

• Place computers at doctors’ fingertips so they can compare, share, and judge what works.

• Use “systems engineering” to redesign the whole system to ensure the best care at the best time for the right reason.

• Encourage doctors to join large groups with enough data infrastructure so outside payers and inside physicians can oversee each other.



There are, of course, two main schools of thought:



• One, let government take care of everything – pricing, regulations, monitoring of quality, and auditing, punishment, and rewards for physicians who play the government game.

• Two, wait for the storm of changes now moving through the marketplace - retail clinics (now numbering about 1000), worksite clinics (perhaps 500), and high deductible health plans (15% of employees now belong), and outrage over high costs to induce competition and bring costs down.



I happen to think “the system” and “American culture” dictates how physicians and patients behave. Each rests on believes in individualism, choice, and freedom to chose what technology and treatment options to pursue. In short, free enterprise.



\It may be that pay-for-performance programs, initiated and monitored by government, as in England, where 25% of physician income, is tied to quality, is a partial answer, but that approach is easier said than done, and doctors may exclude patients from P4P targets to increase income, a practice know as “gaming.”



In the long run, savvy informed patients spending their own premium monies, may the best safeguard against excess care.

Williams' Health Wonk Review

Managed Care Matters / Joe Paduda

Colleague David Williams has a new take, fresh look and punchy style in his edition of Health Wonk Review.

His version is a fast read, too.

Amerigroup Settles

Health Care Renewal / Roy M. Poses MD

Another addition to the cavalcade of settlements, from the Virginian-Pilot,



Amerigroup Corp., which faced $334 million of damage awards and court-imposed penalties from a Medicaid fraud suit in Chicago, said Tuesday that it will pay the U.S. government and state of Illinois $225 million to settle the civil case.



As part of an agreement struck with federal and state agencies, the Virginia Beach-based health insurer said it also will pay $9 million in legal fees, but it will not admit any wrongdoing.



However, Amerigroup said it also will enter into a corporate-integrity agreement with the inspector general of the Department of Health and Human Services, the federal agency that provides part of the funding for state Medicaid programs.



The suit's plaintiffs - a former Amerigroup employee, the state of Illinois and the federal government - said in federal court in Chicago that Amerigroup and its Chicago-area health care plan defrauded state and federal agencies by discouraging pregnant women and individuals with special needs from enrolling.



During a trial in October 2006, the jury found in favor of the plaintiffs and awarded damages of $48 million. That was tripled to $144 million because the suit had been filed under state and federal 'whistle blower' statutes, which required that any damages be trebled. The judge also imposed $190 million of fraud-related penalties on the company.



We first posted about the jury's finding against Amerigroup here. At that time it was reported that "jurors saw a videotape in which one executive said he always sought out 'the healthies' when signing up patients for the HMO. Jurors also saw a number of e-mails in which company officials spoke positively about limiting the number of pregnant women enrolled."



A health insurer who tried to only insure "the healthies" defeats the purpose, doesn't it?



This case adds to the impression that many leaders of health care organizations put short-term financial gains ahead of honesty and patient welfare. Furthermore, what negative incentives for such practices currently exist do not seem to deter them. After all, a fine or settlement paid years later can just be written off as a cost of doing business. Furthermore, although such a payment may have a (minimal) effect on the company's bottom line, it has no real effect on the people whose decisions and actions lead to the problem.



A physician who does something unethical can lose his or her license and practice. An executive of a health care company who does something unethical usually suffers no penalty. In my humble opinion, one solution would be to require state licenses for executives of insurance companies and managed care organizations, as well as other health care organizations whose actions affect the public health and safety (e.g., pharmaceutical, biotechnology and device companies; hospitals, hospital systems, and academic medical centers; medical schools; etc). Such licenses could be challenged, and could be lost, given due process, for findings of unethical conduct. That might provide sufficient negative incentives to reduce the epidemic of unethical behavior by health care organizational leaders.

Health Wonk Review At Health Business Blog

Health Affairs Blog / Jane Hiebert-White

Today Health Business Blog hosts the Health Wonk Review, which sums up the best of health policy blogging–from questions about future of managed care, Medicare, and health reform to nursing staff ratios, physician planning and more. Copyright © 2008 Health Affairs Blog. This Feed is for personal non-commercial use only. All material published on Health Affairs [...]

PMSI sold, MSC/Express Deal closes

Managed Care Matters / Joe Paduda

PMSI, the workers comp PBM and ancillary services provider, will announce today that it has been sold to investment firm HIG. Sources within PMSI indicate the stock deal is worth $50 million, of which $10 million is contingent on achieving certain performance measures. Current management will likely remain in place after the deal closes in about 60 days.

The timing of this transaction is coincident with Express Script's announcement of the closing (sub req) of their acquisition of MSC's Pharmacy Benefit Management business. Express Scripts is now poised to become one of, if not the largest workers comp PBMs.

These deals are the latest in a series of financial transactions and potential transactions involving work comp PBMs. Cypress Care was recapitalized by investor Brazos Private Equity in November, 2006; Fiserv sought to sell its third party biller/PBM business early last year; Coventry purchased First Script as part of the Concentra transaction, and MSC itself was purchased by Monitor Clipper early in 2005.

PMSI has been struggling of late, losing the Hartford's business (while retaining SRS (Hartford's TPA)) to ESI and CNA late last year to Coventry. While PMSI's parent company, Amerisource Bergen, was somewhat of a distant parent and may not have provided the attention and resources necessary for PMSI to maintain its historical leadership position, there's no question HIG's focus and attention will be intense and constant. Private equity management can be quite helpful; it can also be overbearing and short-sighted. And sometimes all three - which may be exactly what PMSI needs to recover its leadership position.

At risk of being accused of burying the lead, here's what has me puzzled. Sources indicate Express looked closely at PMSI - recently . Yet they plunked down $248 million for MSC's pharmacy business, when they could have paid a fifth of that for all of PMSI (which includes a robust ancillary services division).

PMSI has been somewhat damaged goods lately due to customer losses, yet MSC was in a similar position less than two years ago after it lost its largest PBM customer, Liberty Mutual, to rival Progressive Medical (PM had half of Liberty and was awarded MSC's portion).

From here, it looks like a pretty good deal - although PMSI's financials have been pretty bad lately, $50 million is a very good deal for one of the top two companies in a growing market.

Medicine meets Wiki

The Health Care Blog / Matthew

By Jane Sarasohn-Kahn There's a new wiki in the health social media town, Medpedia. Among the most popular online sources for health information is Wikipedia. Millions of people search Wikipedia daily for insights into medical conditions, drugs, and procedures. Medpedia...

Sharing more than they intended -- future doctors on Facebook

The Health Care Blog / Matthew

By Sarah Arnquist The Facebook/MySpace generation is now graduating from medical school, and their profiles along with much embarrassing personal information has been indexed in cyberworld for many to see. The Associated Press wrote an interesting story about how researchers...

Communication 101: Shedding power imbalances to protect patients

The Health Care Blog / Matthew

By Katie Fiebelkorn Westman Katie Fiebelkorn Westman is a registered nurse at an acute care hospital in the Minnesota Twin Cities. She is working toward a clinical nurse specialist degree, focusing on improving patient care quality. The Joint Commission’s recent...

California kids may face triple whammy, leading to more uninsured

The Health Care Blog / Matthew

By Sarah Arnquist After years of seeing decreasing numbers of uninsured children, California is poised to go the other direction. For years, child enrollment in private health insurance plans decreased as companies scaled back on health care costs by increasing...

THCB UPDATE

The Health Care Blog / Matthew

If you haven't had a chance to sign up for THCB UPDATE yet, you really should. You'll get a helpful reminder email from us a few times a week when important posts go up on the site. In the two...

Health Wonks unite

The Health Care Blog / Matthew

The bi-weekly review of the best from health bloggers is up over at Health Business Blog.

The math is wrong

The Health Care Blog / Matthew

By Paul Levy I have great respect for Jim Stergios and the Pioneer Institute he heads. The Institute has been an important force in Massachusetts public policy debates for many years. But I think Jim has the wrong policy prescription...

CCR Symposium: Current and Future Uses for Health Data Exchange

The Health Care Blog / Matthew

The Massachusetts Medical Society will hold a symposium next month called the "Current and Future Uses for Health Data Exchange." Adam Bosworth, former VP of Google Health and CEO of his new start-up, Keas, Inc., will be the keynote speaker....

Health Wonk Review

Neil Versel / Neil

I submitted my Kolodner podcast to Health Wonk Review, and the latest rundown of the healthcare blogosphere is up at the Health Business Blog, hosted by David Williams. Kudos to David for his succinctness. Now I'm no longer scared to volunteer to host one of these. Just not in the next couple of weeks, as I'm off to Italy on Saturday evening for the third week of the Rockefeller Foundation's "Making the eHealth Connection" conference series.



I do expect to blog some from the conference and do expect to submit some stories to my regular outlets while I'm there, so I won't be completely incommunicado. I'm just not volunteering for any extra work until I get back on Aug. 5 (I'm not going all the way to Italy without taking a few sightseeing days for myself) and wrap up a few other lingering assignments. So there.



Thanks again, David, for a good HWR. However, I don't get your "Manumussionaries" comment about my post. I see there's a Healthcare Manumission blog on the list, but I still need further explanation.

Health Wonk Review at the Health Business Blog: July 24, 2008

Health Business Blog / David E. Williams of the Health business blog

Welcome to the latest edition of the Health Wonk Review at the Health Business Blog.

Bitter pills

  • Pyrrhic victory. Expansion of the Americans with Disabilities Act has coincided with a decline in employment levels among the disabled. Workers Comp Insider.
  • No way. Thanks to lobbyists, health care reform has no chance in Congress. Oh, and by the way there’s also no hope of tackling any of the other crises facing the US, including obesity, energy, education, the environment, poverty, and infrastructure replacement. The Health Care Blog.
  • Down with the ANA. The American Nurses Association is a big-time loser. All talk and nothing to show for it. Home of the Brave.
  • Managed care to the electric chair? The health insurance industry association should change its name to America’s Risk Selection Companies and drop the pretense that its members actually manage care. Managed Care Matters.
  • RUC off! How come the proceduralist-dominated RBRVS Update Committee (RUC) is allowed to dictate Medicare reimbursement and why do private insurers slavishly follow CMS’s lead? Health Care Renewal.
  • The Medicare monster. If things keep going the way they are right now, Medicare is going to gobble us up. Health Business Blog.

Capitalist contentment and conceit

  • Keeping the faith. Some nursing homes maximize profits by keeping nursing staff levels low and treating sanctions for fraud and poor quality as a cost of doing business. That doesn’t mean we need minimum nurse staffing ratios, though. Take that, ANA! Healthcare Economist.
  • Ode to high prices. Sure drugs are expensive. But don’t forget all the wonderful innovations the drug companies bring and how terrible the VA is. Healthcare Manumission.
  • No right to health care. Everyone has access to medical care in the US. And who says health care is a right anyway? Amateur Economists.
  • No right to police protection either. Who needs cops when we have the Second Amendment? And who needs government-sponsored health care instead of good old fashioned self-reliance? Patient Power.
  • Take that you bleeding heart, poutine-eating, multi-cultural, igloo-dwelling, took-wearing beer swillers! Why would anyone want to languish on the waiting list in Canada dying of a brain tumor when they could simply get on the plane to Arizona and be cured? InsureBlog.

Sunny side up

  • Make mine Medicare. Medicare reform is possible and can lead to reform of the whole system. HealthBeatBlog.
  • The bus pass cure. How a $23 bus pass can save almost $1400 –and other tales of IHI-induced bliss. The New Health Dialogue Blog.
  • There’s no management like disease management. Sky-high ROI from disease management? Seven reasons why it’s possible. Disease Management Care Blog.
  • Brain food. There’s hope for us yet as computerized cognitive assessments catch on. SharpBrains.

Plain old policy

Thanks for reading. Health Care Policy and Marketplace Review hosts the next edition.

Providence Health & Services Agrees To $100,000 Voluntary Settlement of Potential HIPAA Violation

Health Care Law Blog / Bob Coffield

The U.S. Department of Health and Human Services (HHS) issued a press release last Thursday that it had entered into a Resolution Agreement with Seattle-based Providence Heath & ServicesHealth Insurance Portability and Accountability Act of 1996 (HIPAA) privacy and security rules. The agreement calls for Providence to pay a voluntary settlement of $100,000 and implement a detailed corrective action plan to ensure against future theft or loss of electronic patient health information (ePHI).



The incidents giving rise to the agreement involved two Providence entities, Providence Home and Community Services and Providence Hospice and Home Care. On or about December 30, 2005, data contained on several computer backup disks and tapes was stolen from the unattended car of a Providence employee. In addition to the theft of disks and tapes, several laptop computers were stolen from Providence employees on September 29, 2005, December 7, 2005, February 27, 2006, and March 3, 2006. The laptops, disks and tapes involved in those thefts contained the unencrypted records of more than 386,000 patients of Providence.



Under the terms of the Resolution Agreement, Providence agrees to pay $100,000 by check or electronic funds to HHS. Providence also agrees to enter into and abide by the terms of the Corrective Action Plan that is incorporated into the agreement. The Corrective Action Plan is effective for three years and requires that Providence submit copies of its written policies and procedures to HHS for approval. The Corrective Action Plan outlines nine categories of minimum content required in the policies and procedures. Specifically, the Corrective Action Plan requires that Providence to:

  • Conduct a risk assessment of potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI when it is created, received, maintained, used or transmitted off-site;
  • Implement a risk management plan that incorporates security measures sufficient to reduce the risks and vulnerabilities identified by the risk assessment to a reasonable and appropriate level; and
  • Implement several physical and technical safeguards, including encryption, to ensure the protection of ePHI whenever it is stored or transported off-site by any portable device or electronic media.
The Corrective Action Plan also requires Providence train and monitor its workforce so that all employees are familiar with the policies and procedures. Providence is also required to submit to HHS both a one-time Implementation Report and Annual Reports for three years detailing its compliance to the policies and procedures under the Resolution Agreement.



Initially, HHS officials received more than 30 complaints about the stolen tapes and disks after Providence, pursuant to state notification laws, informed patients of theft. Providence also reported the stolen media to HHS. Providence faced a pending class action lawsuit alleging that the health system failed to safeguard the data as required by HIPAA and violated Oregon’s Unfair Trade Practices Act. The proposed class action was dismissed in November, 2007. The incident was also investigated by the Oregon Attorney General’s Office resulting in an Assurance of Voluntary Compliance Agreement requiring Providence to provide credit monitoring services, credit restoration services, implement security program enhancements and pay $95,764 into the Consumer Protection and Education Revolving Account.



Providence settlement and corrective action plan sends a signal that OCR and CMS are taking a stronger position against privacy and security incidents. The settlement should prompt providers who are required to comply with HIPAA to reexamine their privacy and security policies, procedures, employee training protocols and ongoing monitoring of compliance.

BETA Healthcare Group Partners with Advanced Practice Strategies to Improve Perinatal Safety

Health Business Blog / David E. Williams of the Health business blog

In addition to my consulting work (and blogging) I’m chairman of the board of Advanced Practice Strategies, a leading medical risk management company. The company recently signed a strategic partnership with BETA Healthcare Group (BHG), the largest provider of hospital malpractice coverage in California. I’ve reprinted the press release from BHG’s website here:

Alamo, CA, July 7, 2008 –As part of a large scale commitment to improving perinatal safety, BETA Healthcare Group (BHG) announced today a strategic partnership with Advanced Practice Strategies (APS), a leader in patient safety education. BHG is very proud to support its member hospitals financially in purchasing APS’s online courses which focus on the key drivers of obstetrical claims.

“BHG and APS share a commitment to improving patient safety and offering clinicians the best tools available for protecting patients and this makes it a great partnership,” said Tom Wander, CEO of BETA Healthcare Group. “Our organization has adopted a framework for improving perinatal care within our member hospitals and we believe that the extraordinary quality of APS education makes it the foundation for our program’s success.”

BHG member hospitals will earn significant reductions in their hospital malpractice premiums when they demonstrate their labor and delivery staff’s competence in fetal monitoring interpretation, use of common nomenclature, and participation in routine strip review.  APS courses address these issues directly and focus on the primary drivers of obstetrical malpractice claims –fetal assessment and monitoring, management of shoulder dystocia and operative vaginal delivery.

In addition, BHG’s participation spearheads an initiative in California by a number of hospitals and hospital systems to improve obstetrical outcomes and reduce malpractice

claims through education.  APS is helping to organize a group purchase of this education throughout the state. Because BHG is the largest provider of hospital malpractice coverage in California, representing over 1,200 labor and delivery clinicians in 35 hospitals, its participation is also helping to provide significant cost savings for the rest of the state’s hospitals.

“We have dedicated ourselves to helping healthcare organizations work toward the uniform practice and teamwork that reduces error. We are, therefore, very proud to be supporting BHG’s vision for improved care,” said Dennis Ferrill, CEO of APS.  “Also, it should not be overlooked that with BHG’s leadership, and the added participation of physician insurers, they are sparking system-wide change and improvement and making it easier for smaller organizations to participate in this education as well.”

To learn more about BETA Healthcare Group call (925) 838-6070 or log onto the company’s website, www.betahg.com.

To learn more about APS and its offering, please contact Shara Cohen at 617-367- 0553 [or email her].

July 23, 2008

Study of Medical Bloggers

eHealth / John Sharp

A study by a fellow from the Robert Wood Johnson Foundation has published a study of medical bloggers. Out of 271 blogs by medical professionals, individual patients could be identified in 42% and many describe negatively. Some even showed identifiable photos of patients. The conclusions state that while blogging provides and opportunity for sharing a professional narrative, these violations of privacy need to be addressed.

One wonders if there are similar privacy and confidentiality violations within social networking sites for medical professionals. Some basic groundrules need to be established. One good model is Clinical Cases blog which takes pains to deidentify patient information including Xrays.



Technorati: Web 2.0

Get on board

Neil Versel / Neil

Is it me, or is this the week for changing organizational boards?



Actually, not all the board news was about new members, nor did some of the changes just happen, but I seem to be getting a bunch of announcements or application solicitations this week.



Today, HIMSS announced that its new elected officers and board members took office July 1. Yes, the announcement was dated today:





Advancing the Adoption of Health IT, New HIMSS Board Members Take Office

Chuck Christian and Liz Johnson assume top positions on Board of Directors for the Healthcare Information and Management Systems Society



CHICAGO (July 23, 2008) – Focused on improving the delivery of patient care through health IT and management systems, new officers and elected members of the HIMSS Board of Directors took office on July 1.



Charles E. Christian, FCHIME, FHIMSS, and Liz Johnson, RN, MSN, FHIMSS, began their terms as chair and vice chair, respectively. They replace Chair John Wade, FCHIME, FHIMSS, and Vice Chair Victoria Bradley, DNP, RN, CPHIMS, FHIMSS.



HIMSS Board Chair: Mr. Christian is the director of information systems and CIO of Good Samaritan Hospital, a 100-year-old, free-standing acute care community hospital in southwest Indiana. He is serving his 19th year in this role and his 37th year in healthcare.



...



HIMSS Board Vice Chair: Ms. Johnson is vice president of applied clinical informatics for Tenet HealthSystem. She is responsible for the strategic vision and the tactical plan for all clinical systems used throughout Tenet’s 57 provider organizations. Under her leadership, Tenet has developed and is implementing a comprehensive clinical informatics vision and strategy. Ms. Johnson speaks nationally and internationally on clinical applications and their strategic use as a tool for enhanced patient safety.



...



Chair-Elect and Vice Chair-Elect: In recent elections by the board, Barry Chaiken, MD, MPH, FHIMSS, was selected as chair-elect, and Ms. Johnson was reelected as vice chair-elect.



Dr. Chaiken has more than 20 years of experience in medical research, continuous quality improvement, risk management and patient safety. As founder of his own company, he worked on quality improvement studies and clinical investigations for the National Institutes of Health, the Framingham Heart Study, and Boston University Medical School. Dr. Chaiken is board certified in General Preventive Medicine and Public Health as well as Health Care Quality Management.



New Board Members: Four new board members began their three-year terms on July 1.



David S. Finn is vice president and CIO/privacy and information security officer at Texas Children's Hospital in Houston. Holly D. Miller, MD, MBA, FHIMSS, is the vice president and CMIO at University Hospitals in Cleveland, Ohio. Carol R. Selvey, MHSA, FHIMSS, is principal of The Revere Group, headquartered in Chicago. Charlene S. Underwood, MBA, FHIMSS, is director of government and industry affairs at Siemens Medical Solutions in Malvern, Pa.



New Nominating Committee Members: The following individuals began their two-year term on the Nominating Committee: Kathleen Covert Kimmel, RN, MHA, CHE, FHIMSS, vice president, nursing informatics, McKesson, Louisville, Colo.; Donald Levick, MD, MBA, CPHIMS, physician liaison, information services, Lehigh Valley Hospital, Allentown, Pa.; and Janet K. Stanek, FACHE-designate, RHIA, CPHIMS, FHIMSS, vice president, support services, and CIO, Stormont-Vail Healthcare, Topeka, Kan.



New Advisory Board Members: Two individuals began their terms on the Advisory Board: Michael J. McGill, PhD, Internet2, Health Sciences; Howard A. Burde, Esq., Blank Rome LLP.



et al.



The HIMSS Electronic Health Records Vendors Association also recently seated a new board. Justin Barnes, vice president of marketing and government affairs at Greenway Medical Technologies is now chairman, while Andy Ury M.D., Seattle-based chief medical officer of McKesson Physician Practice Solutions, is vice chairman.



The immediate past chair of the EHRVA, Don Schoen, CEO and president of MediNotes, was elected to the group's executive committee. Others chosen for the committee include: Charlie Jarvis, assistant VP for healthcare industry services and legislative affairs at NextGen Healthcare Information Systems; Michele McGlynn, strategic manager in government and industry affairs for Siemens Medical Solutions; Charles Parisot, manager for architecture and standards at GE Healthcare; Rick Reeves, R.Ph., senior clinical manager of corporate development at Computer Programs and Systems Inc. (CPSI) in Mobile, Ala.; and Steve Tolle, Phoenix-based VP of product management for Allscripts.



Meanwhile, the AHIC Successor search team announced it was soliciting nominations for the board of the private-sector successor organization to the American Health Information Community panel that advises the secretary of Health and Human Services.



Nominations are being accepted through Aug. 4 at http://www.ahicsuccessor.org/hhs/ahic.nsf/nominator.htm.Of note, former Centers for Medicare and Medicaid Services Administrator Mark McClellan, M.D., in his current role as director of the Engelberg Center for Health Care Reform at the Brookings Institution, is leading the effort to establish the AHIC Successor.

"Director of Clinical Informatics"-- without clinical or informatics backgrounds

GNU/Linux Medical Software News /

I'm interested in receiving examples of "Director of Clinical Informatics", "VP of Informatics" or similar Job Descriptions that are lacking a requirement for clinical or informatics education or experience (as opposed to traditional management information systems backgrounds). I want to compile a set of examples to serve as a reference on this practice, and possibly to link to outcomes at some future date.

Podcast: Dr. Robert Kolodner on the national HIT strategy

Neil Versel / Neil

I love the annual Association of Medical Directors of Information Systems (AMDIS) Physician-Computer Connection. It's a chance to hear some of the smartest and most accomplished people in healthcare, namely medical informaticists, in a small, informal setting. This year's event, held last week in beautiful, laid-back Ojai, Calif., featured an appearance by Robert Kolodner, M.D., the national coordinator for health information technology.



After Dr. Kolodner's presentation—more of a Q&A with his peers in medical informatics—he graciously sat down for an audio interview with me. Here is the result.



Podcast details: Robert Kolodner, M.D., on the national health IT strategy. Recorded July 16, 2008, in Ojai, Calif. MP3, stereo, 64 kbps, 14.3 MB, running time 31:24.



0:40 Background on
national health IT strategic plan toward interoperable electronic health records

3:35 Goals of the plan

4:08 Distinction between "health" and "healthcare"

5:25 Explanation of "patient centeredness"

6:20 Physicians’ role in promoting patient centeredness

7:30 IT’s role

8:50 Population health

10:40 Why physicians should care about national IT strategy

12:55 Making the issue personal

13:35 Financial incentives for technology adoption

14:37 Incremental advances

16:18 Medicare e-prescribing incentives as one step in a series of improvements

17:30 Convincing healthcare organizations to cooperate

18:08 Greater public awareness about electronic health information

18:32 Privacy and security concerns, and coming framework

20:50 Convincing doctors to share data

22:10 Trial National Health Implementation Network implementations

22:55 Where physician IT leaders can make a difference

24:06
AHIC successor

25:25 Complexity of healthcare in the U.S. and abroad

27:18 Profound workflow changes from IT and maximizing skills of healthcare professionals

29:06 Possible effects of 2009 administration change

30:15 Health IT’s fundamental role in healthcare reform

Podcast interview with Allison Guimard, CEO of Alijor (transcript)

Health Business Blog / David E. Williams of the Health business blog

This is a transcript of my recent podcast interview with Alijor CEO Allison Guimard.

David E. Williams:  This is David Williams, co-founder of MedPharma Partners and author of The Health Business Blog. I am speaking today with Allison Guimard. She is CEO of online health care directory Alijor, which connects patients with physicians and other health care providers.

Allison, thanks for being with me today.

Allison Guimard:  Thanks for having me David.

David:  Allison, what is Alijor?

Allison:  Alijor is an online health care community that is working to connect patients with various types of health care providers. One of the biggest things it is based on is enabling patients to search for a doctor based on cost.

David:  How does somebody go about it? What is the experience like for a patient?

Allison:  You visit Alijor.com and then enter your geographic area. We have quick links to click on. You will click on your geographic area and you will select the specialty that you are searching in. Then, it will basically organize all the data for you.

You are able to organize it from lowest price to highest price and so on. You are able to see the initial consultation cost, the follow up cost, and the procedure cost. In the very near future you will be able to organize it based on various types of procedures. So, you can be even more specific for various kinds of plastic surgery, for various kinds of dermatology and things like that.

The other experience we offer is that patients can go on and actually post their medical problems. If you are looking for back surgery you can go on and go to orthopedic surgery and type in that you have back problems and you are looking for a back surgeon. And then doctors can actually get on and respond to you and tell you their price. It is very consumer oriented, which is nice for patients.

David:  One problem in health care is the lack of transparency on pricing. That sounds like something that you are addressing. There can also be questions where you don’t know exactly what you need before you go in. So, when you talk about the pricing information, how useful does it end up being for a patient? Or is the price often different or is it hard to figure out exactly what they need ahead of time?

Allison:  It is a great question; a question we actually get a lot. We try to get doctors to give us their average price. For example, if you are going to get some sort of plastic surgery, it is going to vary based on the person and the patient and the issues they have. So, we try to get the doctors to consider their lowest and highest costs and then average it out so that patients know.

So yes, it can definitely vary, but in the end, it is pretty close is what we have been told.

David:  When a patient posts their information it looks like they can put a basic message on there. Is there a structured questionnaire as well? What is your thinking behind what the patient posts?

Allison:  It is pretty structured. You have to put your geographic area. You have to put your insurance and a couple other pieces of information. We actually provide a really good amount of space for people to insert anything they want to about their medical problems.

We have actually never had complaints about how much space there