Re: Policy versus implementation

[ahlewis@scsn.net]

  Does anyone wish to assert that there are no costs involved in 
  implementing the bill?  Let us hear what those costs are, including 
  (here's the challenge) the non-financial costs.  Very seriously, 
  does anyone propose that there are no such costs?  How shall we 
  measure those that are not financial in nature?  
  
  In Mr. Lorton's EXAMPLE below, there is no mention of the cost of 
  *not* certifying.  That cost might be more difficult to quantify, 
  but that should only make us more concerned about its magnitude.
  
  Another thought is to simply reduce one of the multipliers in the 
  (purely financial part of) the calculation.  Who says we must allow 
  so many "facilities that gather and store data?"  I am not on the 
  inside, but that is only one of many assumptions that we should 
  examine, and perhaps challenge.  Why always limit privacy?  Why not 
  impose some limits elsewhere, perhaps on the industry?  The 
  healthcare industry is not healthcare. 
  
  "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."
  
  Likewise, it is a complete abnegation of responsibility to create & 
  try to pass legislation of immense import without waiting for and 
  attempting to create public understanding.  Bring it all out in the 
  open, put it before the people, and let us take our time as a nation 
  to understand, as Mr. L wants us to do.  Who knows, perhaps the 
  voters, after hearing all about the issues of medical privacy, will 
  contact their elected representatives and demand that this bill be 
  passed in exactly its present form.  There's no reason to rush, is 
  there?
  
  
  Alan Lewis
  Private citizen
  
  <---- Begin Included Message ---->
  Date: Sun, 28 Jan 1996 17:48:17 -0500 (EST)
  From: Lewis Lorton <llorton@jobe.shell.portal.com>
  Reply-To: llorton@jobe.shell.portal.com
  Sender: med-privacy@essential.org
  Subject: Policy versus implementation
  
  
   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
  
  
  <---- End Included Message ---->