DIR public meeting on future medical data interchange standards

On Friday, September 4th, I attended the DIR discussion meeting on Electronic transmission of medical reports and records. This was open to the public and announced through a DIR Newsline. The stated purpose was “The DWC will facilitate discussion regarding ideas to electronically transmit medical records reducing administrative costs and increasing efficiency.”

MOVE TO STRUCTURED DATA

The impression I formed was the meeting was intended to gather data from Stakeholders to develop new regulations mandating the use of standardized “structured data” to pass information between parties and the Administration. In other words, sending actual data back and forth, rather than just filing and serving paper or PDFs. The Administration is specifically interested in the area of medical treatment and reporting.

When using the term “structured data”, think of how EAMS changed the way you filed documents with the DWC. Rather than simply generating a form or pleading and delivering it to a District Office, EAMS forced you to either type or transmit to the DWC specifically identified data fields, along with your “unstructured” form or pleading document attachment. Through this process of collecting “structured data”, which are the data entry fields you now have to submit, the Administration can track and identify all sorts of trends within the industry, and use this important data to draft future regulations. It also saves the DWC staff from having to re-key that data into their database.

MEDICAL TREATMENT AND REPORTING

The specific target of the Administration at this point surrounds the processes for: Doctor’s First Report of Injury (DFR) –> Request For Authorization (RFA) –> Utilization Review (UR) –> Independent Medical Review (IMR) –>  PR2, PR3, & PR4.

Again, my impression is the Administration wants to TRACK trends and gauge the results of past regulatory changes in the area of medical treatment. The Administration’s role is, after all, to REGULATE our system. The benefit to stakeholders is computers will be able to make consistent and accurate decisions about how to respond to various incoming communications from other parties or claim participants, including the Administration itself.  Rather than having to depend upon a human to pay attention to an incoming communication from a PTP/Applicant/Claims Admin/Maximus/QME and respond appropriately and timely, stakeholders can all build software systems that can understand the incoming “structured data” and attachments, and either automatically respond, or at the very least ROUTE the communication to the appropriate human to manage the circumstance. Or, as appropriate, just tag the the communication in the system and file it away to be used at the appropriate time.  In all circumstances, the computer can update the stakeholder’s database to track the event and communication in the stakeholder’s workflow, which to me is a huge benefit.

So, moving towards a “structured data with attachments” approach could be win/win for the Administration and stakeholders – IF the new regulations are not overly complicated or time consuming to implement.

EVIDENCE OF A FRAMEWORK & DIRECTION

By the end of the meeting there seemed to be no clear framework or ideas for approaching the “problem”… at least none that the Administration was letting on about. They were apparently just wondering what everybody is doing now, and what we would LIKE to do in a more structured data system. However, I found it telling that in the beginning of the meeting the Administration pointed out that the Doctor’s First Report of Injury (DFR) is currently required to be filed/sent to the Administration, but the Administration was currently doing nothing with that important “starting point” document except filing it away. As somebody who has spent his life designing and implementing workflow and filing software solutions, it jumped out at me that the filing of a DFR needs to initiate a State-managed Identification Number and central repository, similar to the EAMS Case Number and filing system we have once an Application is submitted. Thus, by telling us all that they have the DFR but are not currently doing anything with it, my impression was that the Administration may have done a lot more internal discussion about this whole concept than they were letting on.  As the meeting went on, the vision I had was  to simply extend EAMS backwards to the DFR, and require stakeholders to file DFRs, RFAs, UR responses, etc. using an extension of the structured data definition and attachment process already described in the JetFile documentation, and used in the EAMS User Interface. At least, that’s what I would do.

STAKEHOLDER CONCERNS

I would say the most prevalent concern from stakeholders had to do with attachments and acknowledgements… not having the attachments WITH the structured data seems to be an issue, and not getting an acknowledgment back after a data transmission is another key concern.

QME PANEL REQUEST GOES ONLINE

Did you happen to catch this recent training video for the new online QME Request process put out by the DWC?: http://www.dir.ca.gov/dwc/MedicalUnit/OnlineQMEForm106/Faqs.html. The Medical Unit did a great training video for this here:  https://www.youtube.com/watch?v=F6gYjRx8sxo This is a great way for the Administration to collect structured data, but what’s missing is an “automation layer” like JetFile, so humans don’t have to re-type all the data on web forms to execute a critical step in the process.

CONCLUSION

There was lots of talk about national and even international Healthcare data standards, including HL7, X12, Clinical Document Archetecture (CDA, which is part of HL7), and more. I found the meeting lively and interesting, and my personal opinion is this is all a positive move for the industry. I think it would be great if the DWC would create a “claim” record in EAMS and issue some sort of claim number that could be used to identify that injured worker and particular claim when passing documents and data back and forth. I also think it would be a huge help to all Stakeholders if the DWC would expand upon the data dictionary already used by JetFile and include all the other important data elements in the RFA-UR-IMR-QME-IBR processes so that we could all use the same TERMS when passing data between ourselves and the DWC. It would also be very helpful if the State would combine the UAN lists into ONE consolidated UAN list and use a real identification ID so that all the entities that interact with the claim/case could be properly referenced and identified. And speaking of UANs, high on my Wish List is to have the DWC update existing UAN records when entities move, rather than create new duplicate records in the list. We should all be able to simply REFERENCE an entity on the State’s UAN database and consistently get the RIGHT entity, and have confidence that whenever that entity appears on a case or claim in EAMS, it will point to this exact Entity Record ID.  Something like THAT would allow us to start authenticating ROLES for Entities on cases, which could tighten up security and disclosure errors tremendously.

I think this meeting could be the start of something BIG, and I’m excited to see where this all ends up.