Policy versus implementation

[Lewis Lorton <llorton@jobe.shell.portal.com>]

   Dear Denise Nagel
  
  In a previous note you said:
  "We can have privacy with computers if we have the policy decisions that
  accomplish this."
  
  There are 2 issues which occur to me:
  1) One cannot make reasonable policy without knowledge of implementation and
  the costs, both real and social.  In any complex policy construction which
  balances many competing interests, making policy must be an iterative
  process;  tentative policy decisions which require technology should be
  assessed for feasability and costs by the implementers at each stage.  It is
  probably true that technology can do almost anything, but the costs for any
  particular issue may be so high as to overwhelm any benefit.
  
  2) In the discussions, I hear suggestions for inclusion that stray well
  beyond policy into areas that are untenable, both for technical and
  administrative reasons.   I hear people very intent on having their way
  completely and happily oblivious to the actual effect of their suggested
  implementations upon the practice of healthcare.  In the zeal to protect
  some unknown aggrieved party against possible injury, they do real injury to
  a larger population by diverting resources into administration and out of
  direct care.  
  
  EXAMPLE
  The current legislation requires the certification of all healthcare
  facilities that gather and store data.  There are current estimates that
  there are  30,000 or more facilities that might have to be certified (in
  order to comply with the certification requirement.)   If each facility had
  only one person who spent only 5 days preparing for and undergoing
  certification and the certifying agent spent 2 days on site, the result
  would be 150,000 person days for the health facilities and 60,000 person
  days for the certifying agency.  A total of over 1000 person/years of work
  for this incredibly understated program. 
  
  Maneuver the numbers any way you wish - just balance the costs to health
  care against what suggestions you make.
  It is a complete abnegation of responsibility to try to influence policy
  without understanding; it is easy and comfortable to fight for some abstract
  "right" - it is much more difficult to understand the issues, to balance the
  requirements and costs and actually make the "right" decision.
   
  The interaction between technology and requirements is much too complex to
  be dealt with as a whole in one letter.  I would suggest that issues be
  brought up and the technologists could respond and make a discussion of
  facts rather than just agenda. 
  
     
  Lewis Lorton, Executive Director
  Healthcare Open Systems and Trials
  HOST@sso.org
  444 North Captol, NW
  Suite 414
  Washington, DC 20001
  tel   202/434-4771   fax  202/434-4766  
  
  Home page
  http://host.scra.org
  
  Program Home Pages
  Healthcare Information Infrastructure Technology Program -- http://hiit.scra.org
  Healthcare Information Technology Enabling Community Care --
  http://hitecc.scra.org
  
  DIRECT ADDRESS
  llorton@shell.portal.com
  10096 Hatbrim Terrace
  Columbia,  21046
   direct 410-715-1181     direct fax 410-992-7060