Showing posts with label HHS. Show all posts
Showing posts with label HHS. Show all posts

Sunday, August 05, 2018

Ill-informed, Mission-Hostile Health Care Leadership... in the White House and the US Department of Health and Human Services

Introduction - What Has Gone Wrong with the Leadership of Health Care Organizations

A major focus of Health Care Renewal has been problems in leadership and governance of health care organizations, which we believe became major causes of health care dysfunction.  For example, we have discussed how leadership is often ill-informed.  More and more people leading non-profit, for-profit and government health care organizations have had no training or experience in actually caring for patients, or in biomedical, clinical or public health research as professional managers largely supplanted health care professionals as leaders of health care organizations.  This is part of a societal wave of "managerialism."  Most organizations are now run by such generic managers, rather than people familiar with the particulars of the organizations' work.  Obviously health care and health policy decisions made by ill-informed people are likely to have detrimental effects on patients' and the public's health.

Through 2016, our examples of ill-informed leadership in health care tended to be executives of hospital systems (e..g.,in 2014, here, on the mishandling of a patient with Ebola in a hospital system led by generic managers; and in 2013, here, on a luxurious hospital led by a former hotel executive).  Others were top executives of pharmaceutical corporations (e.g., in 2011, here, on previous Pfizer CEOs).

We have also discussed mission-hostile management, which in many cases has been demonstrated by ill-informed leadership.

Physicians professional values require them to put the interests of their individual patients ahead of all else, including the physicians' self interest.  The AMA Principles of Medical Ethics, for example, includes


A physician shall, while caring for a patient, regard responsibility to the patient as paramount.

Similarly, in health policy and public health, the goal ought to be putting the health of patients as a group, and the public at large, ahead of other considerations.

However, we have often discussed how leaders of large health organizations seemed to put other considerations ahead of individual patients', patients' collectively, or the public's health.  Most of those examples of mission-hostile management involved putting organizational finances, or the leaders' own self-interest ahead of patients' and the public's health.  For example, in 2017 we discussed a New York hospital CEO who seemed to put revenue generation in support of his own very generous paycheck ahead of quality of care and patient safety (look here).  Also, the revered Mayo Clinic seemed to let patients with more remunerative commercial insurance coverage get attention before poor patients who have only government insurance, despite its stated mission "providing the best care to every patient" (look here).  Before November, 2016, our examples of mission-hostile management were mainly from hospitals and health systems, insurance companies, and pharmaceutical, biotechnology and device companies.

But since November, 2016, the most vivid cases we have found of ill-informed and/or mission-hostile management have come from the US federal government, run by the Trump regime. Note that Mr Trump himself has a bachelors degree in business administration, but no experience as a government leader prior to his election.

New cases continue to arise, while old cases continue to fester. In chronological order based on date of reporting,...

Taylor Weyeneth, Former Deputy Chief of Staff, Office of National Drug Control Policy 

We first discussed the hapless Mr Weyeneth in April, 2018.  At the time he was appointed to a position in the White House Office of National Drug Control Policy (ONDCP), Mr Weyeneth was 23, had recently finished his bachelor's degree, and had previously worked as a legal assistant.  He rose to be Deputy Chief of Staff, before he was moved to another job.

In June, 2018, the Washington Post published a long article on Mr Weyeneth's brief government career.  It noted how rapidly at first he rose through the ranks:

Weyeneth received six promotions in the campaign and administration. They culminated with his appointment as deputy chief of staff at the Office of National Drug Control Policy, where he oversaw veteran employees and helped steer an operation that was supposed to lead the fight against the opioid epidemic.

The main reason for his rise seemed to be politics, not any particular qualifications. The White House office of personnel:

wanted someone loyal to Trump and his policies in a position of authority, at a time when the office had lost most of its political appointees and had no leader, Weyeneth said.

Weyeneth had worked on the Trump campaign, starting as an intern, rapidly rising to coordinator of interns, then coordinator for national voter services.  He joined the Trump transition team in an administrative role which included '"helping staff with travel arrangements."  In these roles, he was tasked with determining political loyalty.  For the campaign he created "a list of Republican lawmakers and political figures who openly supported Trump."  For the transition team, he "helped compile a list of trusted politicians who could serve on the 'beachhead teams' that would flood federal agencies in the days and weeks after Trump's inaguration."  We had noted  here various ill-informed, and/or conflicted appointments to the beachhead teams that operated in the health care sphere.  Mr Weyeneth subsequently joined the beachhead team for the Treasury Department.  From there he jumed to the Office of National Drug Control Policy.  Then he became Deputy Chief of Staff, third in command of that agency.

There is nothing in his background to suggest he had any knowledge of medicine, health care, biomedical science, public health, or biomedical science, related or not to drug use.  He did seem to realize how unqualified he was for this job:

'This is more than I ever dreamed of,' Weyeneth recalled thinking, even as he worried about a possible backlash over his lack of qualifications: 'Have I reached too far? Is public opinion going to take over? Is this going to become an article?'
Thus he seemed to realize that he was a profoundly ill-informed leader.


Meanwhile, though, he seemed to have a role in spying on, and ensuring the political loyalty, if not the competence of Office of National Drug Control Policy career staff

The White House tasked him with reporting back on the ­ONDCP operations and the activities of its acting director, a career bureaucrat, Weyeneth said.

That would seem to be an example of mission-hostile management, since government employees are supposed to uphold the US Constitution and work for all the people, and those in health care have an obligation to put patients' and the public's health first.

 In any case, after the media discovered his lack of qualifications, he soon was gone.

Today, Weyeneth is doing temp work, including outdoor labor for a contractor at an intelligence agency.

Ximena Barreto, Former Deputy Director Of Communications, Office Of The Assistant Secretary For Public Affairs,, Department of Health and Human Services (DHHS)

We first discussed Ms Barreto in late April, 2018, here.  She was appointed to a responsible position of leadership in communications for DHHS.  Note that the mission of DHHS currently is:

to enhance the health and well-being of all Americans, by providing for effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.
Nonetheless, her previous experience was as an extreme right-wing political commentator who regularly impugned African-Americans and Muslims.  She had talked about hanging former Presidents Clinton and Obama, and accused the latter of being a "Muslim terrorist."

Thus she seemed likely to be a remarkably mission-hostile leader.  Furthermore, there is no evidence she had any background or experience in medicine, health care, biomedical science, public health, or health policy.  Instead, it appears that she was appointed for no reason other than her extreme political beliefs.

In fact, a CNN article from June 22 indicated that Ms Barreto listed her previous on-line career, which would have included some of the postings listed above, on her resume, and hence posited them as qualifications for her leadership position at DHHS.

A copy of Barreto's resume, obtained by CNN on Thursday through a Freedom of Information Act request, shows she listed her previous conspiratorial work on her resume as a qualification for the communication position.

The resume noted her work from June 2017 through the present on 'The Right View' and on the Halsey News Network -- YouTube shows she co-hosted where she said Islam was 'a cult and said the Republican Party shouldn't allow a Muslim to run for Congress.

Another portion of her resume noted her work as a writer for the conspiracy-driven website 'Borderland Alternative Media' from April 2017 to the present. Barreto notes in description the website was funded by 'Joe Biggs, ex-InfoWars journalist' who himself repeatedly pushed the false Pizzagate conspiracy.
So she too was a profoundly ill-informed leader.

By June, she had been suspended, and then demoted, but still seemingly held a responsible position at DHHS.  After her extreme reviews became public, on June 21, 2018, the Mediate website reported 

Health and Human Services official Ximena Barreto publicly apologized recently for her 'heated and hyper-passionate' tweets on race and far-right conspiracies, after they were reported on by CNN.

And,

After her apology, Barreto, who worked as a far-right media personality before joining HHS in December 2017, was allowed to keep her Trump administration job — albeit, with a demotion from her old deputy director of communications post.

In that capacity

She made her Twitter account private ..... But on that now-private account, she’s been unapologetic — recently calling the reports exposing her fringe views a 'smear campaign.'

Mediaite conducted an extensive review of her social media posts and found that the HHS appointee pushed the baseless Pizzagate conspiracy theory even more than previously reported. Her tweets include smearing former Clinton campaign chairman John Podesta as 'a pedophile,' accusing Democrats of hosting 'Pedophile dinners,' and claiming liberals abuse children during satanic rituals.

Remember, this is the former Deputy Director of Communications for DHHS who was still in a leadership position, albeit one whose nature was unclear.

The Department of Health and Human Services and Barreto were contacted repeatedly via email and phone for comment, but did not respond. After this reporter asked for comment, Barreto shut down her private Twitter account and deleted her tweet calling the CNN articles on her views a 'smear campaign.'

Further gory details of her previous online posting are describe in the Mediate article.

Despite all this, Ms Barreto hung onto her DHHS position for more than a month. On July 27, 2018, Politco finally reported:

Ximena Barreto — a Donald Trump political appointee who used social media to spread conspiracy theories about a supposed pizza shop sex ring and made other inflammatory remarks — was escorted from Health and Human Services Department headquarters Friday, according to an individual with knowledge of the situation.

Barreto resigned, the individual said. HHS did not immediately respond to a request for comment.

Gavin Smith, Former Deputy Director of Communications, DHHS; David Pasch, Digital Director, DHHS; Tim Clark, Former White House Liaison and Interim Director of  Communications, DHHS


The issue with Ximena Barreto was her activities prior to taking a leadership position at DHHS.  However, on June 29, 2018, Politico reported on several DHHS officials who had been publishing pointed political opinions on the internet while in office.  It opened with

One staffer publicly mocked senators who criticized Donald Trump as 'clueless' and 'crazy.' Another accused Hillary Clinton of having a campaign aide killed and employing pedophiles. A third wrote the 'shameful' press was trying to deny Trump his victories.

These are not faceless trolls but midlevel political appointees at the Health and Human Services Department who have helped shape the agency’s communications strategy — even while taking a page out of President Donald Trump’s playbook.

Politico summarized how this might be mission-hostile management.

The behavior evokes Trump’s taunts and gibes, suggesting that some officials feel empowered to mimic the president even while representing the government to millions of taxpayers and working alongside career federal employees.

Again, as noted above, DHHS is supposed to work for all the people, not just the political allies of the current administration.  Furthermore, because these activities were by people within the government, there was an immediate legal question.

It also raises questions about whether any officials are violating the Hatch Act, which is intended to ban most federal personnel from bringing politics into the workplace.
Further details about each individual case follow.

Gavin Smith

One official involved was "Gavin Smith, an HHS staffer who identifies himself as deputy communications director."  His interests focused on pursuing Republicans who had opposed Trump in some sense.  His offerings on Twitter included the following directed to Republican Senator Bob Corker, who has frequently disagreed with Trump:

Just saw where Crazy @BobCorker called the #TrumpTrain a 'cult! Let's be clear sir, we're not a cult — we're a movement that defeated Crooked @HillaryClinton and that's committed to ridding Washington of politicians like you. Good riddance — DC will be better off with you!
Other Tweets included:

'Well, we've always known he's clueless,' Smith said, retweeting a quote about Sen. Lindsey Graham, and in another tweet telling the Republican senator to 'delete your account.' Other Smith tweets mocked Mitt Romney as a “clown” and encouraged all living ex-presidents 'to finally pipe down and get on board with the will of the #American people to #MAGA!

'Getting your ass kicked once just wasn't enough for you, was it @JohnKasich? Lookin' forward to Round Two! #MAGA' Smith tweeted in response to reports that the Ohio governor was considering a 2020 presidential bid. Meanwhile, Smith has waded into politics in his home state of South Carolina, including sharing an article about him possibly challenging a sitting House representative and repeatedly weighing in on local issues.

'Perhaps the South Carolina legislature will finally listen to @TreasurerLoftis — or will they make yet another bad deal on behalf of the #SC taxpayers?' Smith wrote in December, referencing a failed energy project. 'Make no mistake legislators, we are watching you. Each and every one of you.'

Smith's pinned tweet, posted last Saturday and retweeted hundreds of times, features a photo of Smith behind a Trump-emblazoned podium and endorses South Carolina Gov. Henry McMaster for reelection.
Note that #MAGA stands for Trump's campaign slogan, not an official US government policy.

So Smith was again acting like his job was to promote Trump's politics, not patients' and the public's health.  So he was at least a mission-indifferent leader.

Smith's LinkedIn profile claimed he, unlike Ms Barreto, actually had a background in communications/ public relations.  His other positions ranged from managing in a real estate firm and a deli, and various political jobs.  A managerialist might have deemed him qualified.  However, he provides no evidence of any background or experience in medicine, health care, biomedical science, public health or health policy. Thus he was another ill-informed leader.

The Politico article quoted one expert who suggested that Smith's Tweets might have been illegal

Government transparency experts said that some of Smith’s tweets could violate the Hatch Act’s prohibitions on executive branch employees engaging in partisan messages, pointing to February 2018 guidance released by the Office of Special Counsel.

'The Hatch Act prohibits federal employees from engaging in political activity, including posting on Twitter or Facebook, while on duty or in the federal workplace,' said Daniel Stevens of the Center for Accountability. 'If James posted comments regarding McMaster while in a federal building or during his work hours, he likely violated the Hatch Act.'

David Pasch

The article included a picture to illustrate how

David Pasch, who ran HHS’ digital communications until this month, regularly parked his car — with 'FAKENWS' vanity license plates — outside of agency headquarters.

Pasch also had a

Facebook profile photo also touts an image of him with the message 'fake news.'

Pasch's LinkedIn profile only included political jobs.  One was with an organization called  Generation Opporunity. A 2015 Politico article stated

Generation Opportunity, a libertarian-leaning group with ties to the Koch brothers, released a series of ads featuring 'Creepy Uncle Sam' to discourage young people from enrolling. But this season, the group is putting its energy into other issues like higher education and unemployment, said communications director David Pasch.

We had posted about the Creepy Uncle Sam ads as examples of stealth health care policy advocacy that encouraged bad decision making.  So Mr Pasch seemed to be a classically ill-informed leader, whose previous work on "Creepy Uncle Sam" suggests he was mission hostile as well.
 
And just to gild the lilly, while Pasch's disclosures of possible financial conflicts of interest per ProPublica are not too striking, an easy Google search revealed one possibly significant conflict of interest that he did not reveal, albeit on involving his spouse.  Per their marriage announcement in the New York Times from 2017,

The bride’s father is the chairman, president and chief executive of Sanderling Healthcare in Nashville. He was also the founder of REN Corporation-USA, a provider of dialysis services.

Tim Clark

The Politico article stated

Tim Clark, the agency's White House liaison who also served as HHS' interim communications chief this year, in 2016 sent tweets sharing allegations that Hillary Clinton's campaign paid people to incite violence at Trump's rallies, based on a hidden-camera video produced by Project Veritas' James O'Keefe. Democrats disputed the charge and distanced themselves from the individuals in the edited video.

'Wikileaks & O'Keefe video shows Hillary blatantly disregards election laws,' Clark tweeted in October 2016, while he was California director for the Trump campaign.'"Election must be free & fair.'

Clark also repeatedly used a #SpiritCooking hashtag to promote his pro-Trump tweets, referencing allegations about Clinton campaign chief John Podesta engaging in Satanic practices, based on an email forwarded to Podesta's brother Tony and obtained by WikiLeaks. The term 'spirit cooking' was used by artist Marina Abramović, who was hosting a dinner and invited the Podestas, and in November 2016 said the term was "taken completely out of my context ... it was just a normal dinner."

Clark's Twitter account is now private.
Clark seems likely to have been mission-hostile because of his apparent hostility to various groups within the US population whom he was obligated to serve while at DHHS.

Because he has a very common name, searching did not reveal much specific information about Clark's background, but a subsequent article on July 13, in Politico that noted his and Smith's departure, stated, 

Clark was the California chairman of Trump's campaign and became the health department's chief liaison with the White House, a crucial gatekeeper for the agency's policies and staffing. Clark worked to hire and protect a number of Trump campaign veterans who were allowed to remain on the job after their social media posts became public, according to multiple sources inside the agency.

These included Ms Barreto. I found nothing to suggest Mr Clark had any experience or expertise in medicine, health care, biomedical science, public health, or health policy.  So he was an ill-informed leader as well

Again, per the July 13 article, Clark and Smith have left DHHS.

Summary

So our knowledge of cases of ill-informed and mission-hostile leadership of health care agencies within the US government increases.  As we stated in April,

We have noted, most recently here, how the current Trump administration has been appointing many people without any qualifications in biomedical science, health care, or public health to leadership positions in health and public health agencies.  Obviously health care and health policy decisions made by ill-informed people coule have detrimental effects on patients' and the public's health.

Worse, it now seems that some ill-informed appointments have more nefarious purposes, including the subversion of the mission of these health related agencies.  The group of leaders discussed above seem to be hostile to the notion that health care and public health should serve all people, regardless of their religious beliefs, race, ethnicity, or sex.

Furthermore, they seem to be undermining fundamental principles of US government enshrined in the Constitution, including prohibiting the government from establishing a religion or preventing the free expression of any religion, and equal application of the laws and provision of due process to all people, again regardless of their religious beliefs, race, ethnicity or sex.

We have been writing about health care dysfunction since 2003, and publishing this blog since 2004.  A major concern all along has been how threats to health care professionals' core values generate  health care dysfunction.  Up through 2016, these threats came principally from large private health care organizations.  While the US government was not always as good at defending these values as it could have been, at least it rarely presented its own set of active threats.  Under Trump, that situation has been changing for the worse.  This is obviously hugely dangerous, (and made more so by the regime's threats to other core values of US society, to US law, and the US Constitution.)

To prevent the decline and fall of US health care, and maybe the entire US experiment in representative democracy, health care professionals, academics, patients and citizens concerned about health care will have to join up with the larger populace to defend our core values while they still have any force.   

Friday, April 11, 2014

Healthcare IT Amateur Kathleen Sebelius Resigns - Good Riddance

The Secretary of the U.S. Department of Health and Human Services (HHS) is resigning.

Press reports say she is resigning in large part due to the Exchange Website debacle.   This from the New York Times:

Health Secretary Resigns After Woes of HealthCare.gov
http://www.nytimes.com/2014/04/11/us/politics/sebelius-resigning-as-health-secretary.html?_r=0

... Officials said Ms. Sebelius, 65, made the decision to resign and was not forced out [Yeah, right - SS]. But the frustration at the White House over her performance had become increasingly clear, as administration aides worried that the crippling problems at HealthCare.gov, the website set up to enroll Americans in insurance exchanges, would result in lasting damage to the president’s legacy.

It's not as if there's no literature out there on how to create good health IT.  Doing so is not a state secret.  Simple (and free, unlike the hundreds of millions spent on incompetent beltway-bandit 'consultants') Google searches on the term "healthcare IT failure" or similar return ample resources that could have prevented the "lasting damage to the president's legacy."

Way to go, Ms. Ex-Secretary.  Another health IT amateur bites the dust, as my early computer mentor, Philadelphia's George Washington High School math instructor Fred Holzwarth (http://www.historicbuckscounty.org/nths/HISTORIA/PDF/Historia_Nov2005.pdf) would have said.

However, even worse ... far worse ...

Under this Secretary of the Department of Health and Human Services, the principal watchdog agency over medicine and medical device safety under her aegis, the FDA, found that:

... products with health management heath IT functions, includes software for health information and data management, medication management, provider order entry, knowledge management, electronic access to clinical results and most clinical decision support software.

Products with health management health IT functions are of sufficiently low risk and thus, if they meet the statutory definition of a medical device, FDA does not intend to focus its oversight on them.

Thus, patients are condemned to injury and death, probably at ECRI Deep Dive study levels [1], for the foreseeable future (see my post on that FDA decision at my April 9, 2014 post "FDA on health IT risk: reckless, or another GM-like political coverup?" at http://hcrenewal.blogspot.com/2014/04/fda-on-health-it-risk-reckless-or.html).

This is especially outrageous at the time massive investigations are ongoing about the 13 deaths caused by apparent coverups of a faulty General Motors ignition switch.

It was your FDA agency, Ms. Ex-Secretary.  You own that decision.

Good Riddance, indeed.  

The person at this link: http://hcrenewal.blogspot.com/2011/06/my-mother-passed-away.html would certainly agree, if she were alive; she is not thanks to the very devices your FDA just perversely found to be of "sufficiently low risk."

-- SS

Note:

[1]  In 9 weeks in 36 PSO-member hospitals, 171 IT mishaps sufficient to cause harm were voluntarily reported; 8 injuries occurred, some severe, and 3 deaths may have been the result.  See http://hcrenewal.blogspot.com/2013/02/peering-underneath-icebergs-water-level.html.

Wednesday, March 12, 2014

Regulation of HIT by federal independent agency vs. federal executive agency / Open criminal probe of GM recall

In the FY2014 HHS budget-in-brief document (PDF at http://www.hhs.gov/budget/fy2014/fy-2014-budget-in-brief.pdf) on page 115, there's this:


Patient Safety and Health IT Usability
Patient safety and usability continue to be a focus for
ONC. Working with federal partners AHRQ and FDA,
ONC will create the foundation for a patient
safety program that will be launched in FY 2014
called “The Patient Safety Plan”. The Plan seeks
to ensure that health IT is safely designed and
implemented, medical staff are properly
informed and trained to use their health IT
systems, and a surveillance system is established
to monitor health IT related patient safety events
and ensure that unsafe conditions are corrected.

I believe the health IT industry now realizes some form of regulation is inevitable after, for example, revelations from medical malpractice insurers that a significant number of lawsuits involve the effects of health IT (see for instance my post "Malpractice Claims Analysis Confirms Risks in EHRs" at http://hcrenewal.blogspot.com/2014/02/patient-safety-quality-healthcare.html).

I also believe that industry and its pundits have pushed for the most favorable regulation possible.  This involves pushing for regulation by agencies with the least agency independence as possible, as I bring out below. 

HHS along with its member branches FDA, AHRQ and ONC are executive departments of the US government  The legislation that governs the way such departments and agencies may propose and establish regulations is the Administrative Procedure Act of 1946 (http://en.wikipedia.org/wiki/Administrative_Procedure_Act).

First, it seems the executive branch is attempting to concentrate more power within itself over health IT through proposals like in the FY2014 HHS document.

I also point out that that HHS (and its offices such as ONC, FDA etc.) are federal executive departments.  http://en.wikipedia.org/wiki/United_States_federal_executive_departments. These are not entirely independent of presidential control:

"The heads of the federal executive departments, known as secretaries of their respective department, form the traditional Cabinet of the United States, an executive organ that serves at the disposal of the president and normally act as an advisory body to the presidency."

In other words, the leaders serve at the pleasure of the President.

This is as opposed to the executive department cousin, the federal independent agency, such as the NRC (Nuclear regulatory commission) and NTSB (national transportation safety board) that are independent agencies (http://en.wikipedia.org/wiki/Independent_agencies_of_the_United_States_government):

Independent agencies of the United States federal government are those agencies that exist outside of the federal executive departments (those headed by a Cabinet secretary). More specifically, the term may be used to describe agencies that, while constitutionally part of the executive branch, are independent of presidential control, usually because the president's power to dismiss the agency head or a member is limited.

It is no secret the administration is determined to push as rapid as possible rollout of health IT, come hell or high water, via HITECH, its coming penalties and other measures.  Its predecessor administration was a bit more genteel and circumspect in this regard.

It is clear to me that, in the current political environment, regulation by a federal executive agency is minimalist and will likely be politically ineffective, due to fear of its leadership of being dismissed if they upset the upper echelons.  

I note that Jeffrey Shuren, a physician and attorney, director of FDA CDRH already stated in 2010 that "health IT is a political hot potato" as a reason that FDA "has largely refrained from enforcing our regulatory requirements."  See my April 2011 post "FDA Decides Regulating Implantable Defibrillator Medical Devices a 'Political Hot Potato'; Demurs" at http://hcrenewal.blogspot.com/2011/04/fda-decides-regulating-implantable.html for links to source.

I believe it would be better to place the authority for health IT regulation under the aegis of a federal independent agency, whether an existing one or one created for that purpose, so that its leaders are more independent of executive branch control.

-----

I predict that without meaningful regulation, this is where the health IT industry will find itself in a few years.
http://www.reuters.com/article/2014/03/11/us-autos-gm-recall-probe-idUSBREA2A1RZ20140311

Reuters - Federal prosecutors are examining whether General Motors is criminally liable for failing to properly disclose problems with some of its vehicles that were linked to 13 deaths and led to a recall last month, according to a source familiar with the investigation.

The New York-based probe is in its early stages, and the source did not elaborate on the legal theory behind the potential criminal liability.

.. Federal investigators are reviewing information about how GM handled reports of problems with ignition switches that first came to light 10 years ago, according to the source.

The federal probe by the U.S. attorney in Manhattan adds to a growing list of U.S. authorities examining the recall, which GM announced in February. The National Highway Traffic Safety Administration (NHTSA) previously opened an investigation into whether GM reacted swiftly enough in its recall.

Earlier on Tuesday, Reuters reported that a U.S. Senate committee chairman is seeking a hearing on the issue. The U.S. House Energy and Commerce Committee also ordered GM and NHTSA to turn over information about GM's ignition switch problems.

The problems in some instances allowed the engine and other components, including front airbags, to turn off while the vehicle was traveling at high speed. More than 1.6 million older vehicles are affected.

The failure is believed to be caused when weight on the ignition key, road conditions or some other jarring event causes the ignition switch to move out of the "run" position, turning off the engine and most of the car's electrical components mid-drive, with sometimes catastrophic results.

GM has recommended that owners use only the ignition key with nothing else on the key ring.

.. The House committee examining the GM issue, led by Michigan Republican Fred Upton, gave the company and NHTSA until March 25 to turn over information about their responses to consumers' complaints about the problem.

The committee has asked GM officials to provide a briefing no later than March 18 on how GM has responded to reports of incidents since 2003 and its interaction with NHTSA since then on problems related to the ignition defect.

Upton led the 2000 investigation into Firestone tire failures on Ford Motor Co vehicles, resulting in the TREAD Act that requires automakers to report complaints of defects to the NHTSA.

That law also makes it a crime to intentionally mislead the agency about defects that lead to serious accidents.

... The person familiar with the criminal probe declined to discuss whether prosecutors were considering liability under the TREAD Act.

 In fact, there is no good reason the health IT sector has been excluded from such actions, through an unprecedented regulatory accommodation this single healthcare sector has enjoyed for decades - namely, that of no true regulation at all.
 


Sure, let's regulate a potentially proven dangerous healthcare technology, health IT (a glamor child of this administration) by a federal executive agency that serves "at the disposal" of the President ... instead of a federal independent agency, with ... uh ...better independence.  Great idea!

-- SS

3/12/14 Addendum:

Note this report of possible delays by the Department of Transportation on disclosure of GM ignition defects, by its National Highway Traffic Safety Administration branch, that caused fatalities and where disclosure could have (and finally now has) resulted in huge legal problems for GM.  GM is a company that was a centerpiece of the administration's economic interventions in recent years:

Did the Obama White House Protect GM?

Liz Peek
The Fiscal Times
March 12, 2014
http://www.thefiscaltimes.com/Columns/2014/03/12/Did-Obama-White-House-Protect-GM

Did the Obama administration purposefully hide problems with GM cars? Were they panicked that a massive recall of GM products would undermine one of President Obama’s most self-congratulatory campaign themes – that he “saved” Detroit’s auto industry?

This is a tale of two car companies: GM, shining star in President Obama’s reelection galaxy, and Toyota, which became political fodder.

The House Energy and Commerce Committee announced two days ago that it would undertake an investigation into why it took GM until quite recently to address a decade of complaints about stalling problems with several car models, and why the National Highway Traffic Safety Administration did not demand a recall of the troubled lines earlier on[Because they were afraid to? - ed.]  Reports of unexpected stalling in Chevy Cobalts began to trickle in as early as 2003 when 7 incidents were relayed to NHTSA, according to The New York Times ...

Read the whole article.

The Department of Transportation is ... you guessed it ... a federal executive agency, not a federal independent agency.

-- SS


The Fiscal Times
March 12, 2014
Did the Obama administration purposefully hide problems with GM cars? Were they panicked that a massive recall of GM products would undermine one of President Obama’s most self-congratulatory campaign themes – that he “saved” Detroit’s auto industry?
This is a tale of two car companies: GM, shining star in President Obama’s reelection galaxy, and Toyota, which became political fodder.
The House Energy and Commerce Committee announced two days ago that it would undertake an investigation into why it took GM until quite recently to address a decade of complaints about stalling problems with several car models, and why the National Highway Traffic Safety Administration did not demand a recall of the troubled lines earlier on.  Reports of unexpected stalling in Chevy Cobalts began to trickle in as early as 2003 when 7 incidents were relayed to NHTSA, according to The New York Times.
- See more at: http://www.thefiscaltimes.com/Columns/2014/03/12/Did-Obama-White-House-Protect-GM#sthash.Ed9FH0ZD.dpuf
National Highway Traffic Safety Administrationsuspected of causing many deaths:  "Did the Obama White House Protect GM?", The Fiscal TimesMarch 12, 2014, http://www.thefiscaltimes.com/Columns/2014/03/12/Did-Obama-White-House-Protect-GM.Note that the Department of Transportation is ... you guessed it ... a federal executive department.
Did the Obama White House Protect GM?
Did the Obama White House Protect GM?

Monday, December 09, 2013

But Don't Worry, Your Health Information is Secure: the Enforcers are Themselves Incompetent and Broke

Another in my "But Don't Worry, Your Health Information is Secure" series (see http://hcrenewal.blogspot.com/search/label/medical%20record%20privacy) ... a promise blindly made by the healthcare information technology hyper-enthusiasts.

The Office of the Inspector General for HHS just issued a report finding that the Office of Civil Rights (OCR), which is charged with enforcing the HIPAA/HITECH law, had itself failed to adequately protect the security of the health information it handled. Specifically OIG found that OCR “focused on system operability to the detriment of system and data security.”

From “The Office for Civil Rights Did Not Meet All Federal Requirements in Its Oversight and Enforcement of the Health Insurance Portability and Accountability Act Security Rule”, p. ii (Nov. 2013).  http://oig.hhs.gov/oas/reports/region4/41105025.asp

Summary:

The Office for Civil Rights (OCR) did not meet certain Federal requirements critical to the oversight and enforcement of the Health Insurance Portability and Accountability Act Security Rule (Security Rule). OCR had not assessed risks, established priorities, or implemented controls for its Federal requirements to provide for periodic audits of covered entities to ensure their compliance with Security Rule requirements. In addition, OCR's Security Rule investigation files did not contain required documentation supporting key decisions made because management had not implemented sufficient controls, including supervisory review and documentation retention, to ensure investigators follow investigation policies and procedures for properly initiating, processing, and closing Security Rule investigations. Further, OCR had not fully complied with Federal cybersecurity requirements for its information systems used to process and store investigation data because it focused on system operability [I presume they mean 'interoperability' - ed.] to the detriment of system and data security.

We recommended that OCR (1) assess the risks, establish priorities, and implement controls for its HITECH auditing requirements; (2) provide for periodic audits in accordance with HITECH to ensure Security Rule compliance at covered entities; (3) implement sufficient controls, such as supervisory reviews and documentation retention, to ensure policies and procedures for Security Rule investigations are followed; and (4) implement the National Institute of Standards and Technology Risk Management Framework for systems used to oversee and enforce the Security Rule. In its comments on our draft report, OCR generally concurred with our recommendations and described the actions it has taken to address them. In specific comments on our second recommendation, however, OCR explained that no funds had been appropriated for it to maintain a permanent audit program and that funds used to support audit activities previously conducted were no longer available.

The enforcers are themselves negligent, incompetent and broke.  And hospitals are expected to keep electronic protected health information secure?

I comment no further.  What more could I possibly write?

-- SS

Dec. 9, 2013 Addendum:

This woman would probably agree that this is a problem

Dec. 9, 2013
http://www.thestar.com/news/gta/2013/11/28/disabled_woman_denied_entry_to_us_after_agent_cites_supposedly_private_medical_details.html

Disabled woman denied entry to U.S. after agent cites supposedly private medical details

A Toronto woman is shocked after she was denied entry into the U.S. because she had been hospitalized for clinical depression.

Ellen Richardson went to Pearson airport on Monday full of joy about flying to New York City and from there going on a 10-day Caribbean cruise for which she’d paid about $6,000.

But a U.S. Customs and Border Protection agent with the Department of Homeland Security killed that dream when he denied her entry.

“I was turned away, I was told, because I had a hospitalization in the summer of 2012 for clinical depression,’’ said Richardson, who is a paraplegic and set up her cruise in collaboration with a March of Dimes group of about 12 others.

The Weston woman was told by the U.S. agent she would have to get “medical clearance’’ and be examined by one of only three doctors in Toronto whose assessments are accepted by Homeland Security. She was given their names and told a call to her psychiatrist “would not suffice.’’

At the time, Richardson said, she was so shocked and devastated by what was going on, she wasn’t thinking about how U.S. authorities could access her supposedly private medical information.

“I was so aghast. I was saying, ‘I don’t understand this. What is the problem?’ I was so looking forward to getting away . . . I’d even brought a little string of Christmas lights I was going to string up in the cabin. . . . It’s not like I can just book again right away,’’ she said, referring to the time and planning that goes into taking a trip as a disabled person.

Richardson said she’d had no discussion whatsoever with the agent at the airport about her medical history or background.

Read the whole thing.

-- SS

Wednesday, September 18, 2013

EMR Defects That Injure and Kill, and Litigation: A Hospital Is Paying a Huge Hourly Rate for This?

At my Oct. 2011 post "A Diary of EHR-Initiated Tragedy" I wrote that:

... I've realized that these past posts, when integrated for an upcoming investigation, tell a story that is probably not uncommon in hospitals today. They form a sort of Diary of EHR-Initiated Tragedy.

Sadly, this Diary was my account of my own mother's EHR-related injuries.

There is a new chapter brewing.

In the latest objections to the Complaint against the hospital and its agents, the retained defense attorney proffered this argument:

(ii) Plaintiff's Software Design Defect Claims are Preempted by the Federal HITECH Act.

• To the extent Plaintiff attempts to bring a common law product liability claims against defendant hospital for required use of EMR software, such a claim is barred due to Federal Preemption of this area with the passage of the Health Information Technology for Economic and Clinical Health (HITECH) Act. 42 U.S.S. 201, 300 et seq.

• Specifically, the design, manufacture, specification, certification and sale of EMR in the United States is a highly regulated industry under the jurisdiction of the Department of Health and Human Services (HHS). The HHS draws its statutory authority to design and certify EMR as safe and effective under the HITECH act as amended. Id. [See note below - ed.]

• The Supremacy Clause of the United States Constitution, article VI, clause 2, preempts and state law that conflicts with the exercise of federal power. Fid. Fed. Sav. & Loan Ass'n v. de la Cuesta, 458 U.S. 141m 102 S. Ct. 3014 (1982). "Pre-emption may be either express or implied, and 'is compelled whether Congress' command is explicitly stated in the statute's language or implicitly contained in its structure and purpose." Matter of Cajun Elec. Power Co-Op., Inc., 109 F.3d 248, 254 (5th Cir. 1997) citing Jones v. Rath Packing Co., 430 U.S. 519, 525 (1977).

• In this case, to impose common law liability upon defendant hospital for using certified EHR technology, which was in compliance with federal law and regulations for Health Information Technology, would directly conflict with Congress' statutory scheme for fostering and promoting the implementation and use of EHR.

In other words, the HITECH Act gives hospitals free license to implement clinical information technology poorly with impunity, based on cases in banks, power companies and meat-packing plants, and HHS certification means HHS has found HIT is safe and effective.

[Note]: On "... The HHS draws its statutory authority to design and certify EMR as safe and effective under the HITECH act as amended." HHS does not design or certify EMRs. Is that assertion just made up out of thin air?

Regarding "to the extent Plaintiff attempts to bring a common law product liability claims against defendant hospital for required use of EMR software", that's just made up. There is no requirement for the use of EMR software.

On HIT "certification" implying safety and effectiveness, not exactly. "Certification" is entirely irrelevant. I had previously written here that:

"Certification" of health IT is not validation of safety, usability, efficacy, etc., but a pre-flight checklist of features, interoperability, security and the like. The certifiers admit this explicitly. See the CCHIT web pages for example. ("CCHIT Certified®, an independently developed certification that includes a rigorous inspection of an EHR’s integrated functionality, interoperability and security.")

Health IT "certification" is not like Underwriters Laboratories (UL) certification of appliances. ("Independent, not-for-profit product safety testing and certification organization ... With more than a 116-year proven track record, UL has been defining safety from the public adoption of electricity to new breakthroughs that help protect our future. UL employees are committed to safeguarding people, places and products in new and innovative ways for today’s borderless world.")

"Highly regulated industry?" I guess that's why the Institute of Medicine just completed a report that concluded that health IT safety is unacceptable, that regulation is lacking, and that the health IT industry best get its act together voluntarily, or FDA will have to step in:

... the push [by the Administration] is occurring so far without any agency really ‘watch dogging’ the safety of health IT — the software, hardware and systems that record and manage patients’ health information. These expensive devices by and large have not gone through any regulatory checks for safety in the way that food, drugs and other medical technology must; most of that oversight is handled by the FDA. But at the moment, no one is required to report instances of harm caused by health information devices and no government agency currently monitors their safety.... The current state of safety and health IT is not acceptable; specific actions are required to improve the safety of health IT. The first eight recommendations are intended to create conditions and incentives to encourage substantial industry-driven change without formal regulation. However, because the private sector to date has not taken sufficient action on its own, the committee believes a follow-up recommendation is needed to formally regulate health IT. If the actions recommended to the private and public sectors are not effective as determined by the Secretary of HHS, the Secretary should direct the FDA to exercise all authorities to regulate health IT.

As to the assertion that "to impose common law liability upon defendant hospital for using certified EHR technology, which was in compliance with federal law and regulations for Health Information Technology, would directly conflict with Congress' statutory scheme for fostering and promoting the implementation and use of EHR", let's repeat:
There are no federal laws and regulations for Health Information Technology.

The technology is unregulated. I could design an EMR tonight and put it up for sale tomorrow. It might not qualify for federal incentives if it were not "certified" by an ONC-Authorized Testing and Certification Body (ONC-ATCB), but if I could find a buyer willing to use it, there are no laws or regulations preventing that. From the ONC FAQ here:

... In order to qualify for Medicare and Medicaid EHR incentive payments, providers must use EHR technology that has been certified by an Office of the National Coordinator for Health Information Technology-Authorized Testing and Certification Body (ONC-ATCB, or ATCB). The temporary certification program provides assurances that the EHR technology adopted by health care providers is technically capable of supporting their efforts to achieve meaningful use.

As to imposition of such a common law liability "conflicting with a Congressional scheme for promoting EHR's", that is simply irrelevant.

I note the assertion is also defamatory towards Congress, implying Congress is fine with hospitals deploying health IT with reckless abandon, and should be permitted to do so with legal impunity for the sake of their "scheme."
There's also a claim made that the defendant hospital is not on the hook for EHR defects in their installed systems, because they "don't sell or manufacture the product."

They do, however, modify, customize, maintain, and test it for proper functioning in situ (the latter if they are acting responsibly, especially since the technology is experimental and not tested/approved by FDA, not even undergoing "fast track" 510(k) approval). It should also be noted that the latter 510(k) process does not confer freedom from user liability even when it is obtained.

Even to my non-legally-trained mind, I believe the duties that hospitals owe patients include these, especially with a non-FDA approved experimental technology known to cause risk, injury and death but at a magnitude that is not known:

  • The duty to make a reasonable inspection of equipment it uses in the treatment of patients and remedy any defects discoverable by such inspection.
  • The duty to provide equipment reasonably suited for the use intended.

Finally, as it turns out, the ED EHR in question was not "certified" when my mother became injured. It was not "certified" until many months later.

Additionally, the hospital in question made its buy decision and did its implementation several years before HITECH (enacted as part of the American Recovery and Reinvestment Act of 2009) was even a twinkle in the Administration's eye.

If I were paying handsomely for legal counsel such as outlined above, I'd cringe.

Sadly, while legal obstructionism continues (as I am finding is common regarding health IT-related litigation), more patients are being injured and killed.

-- SS

Thursday, November 29, 2012

Cybernetik Über Alles Again: HHS and Sebelius - Hospitals And Their Computers Have More Rights Than Patients

A Nov. 29, 2012 New York Times article by Reed Abelson entitled "Medicare Is Faulted on Shift to Electronic Records" observes that:

The conversion to electronic medical records — a critical piece of the Obama administration’s plan for health care reform — is “vulnerable” to fraud and abuse because of the failure of Medicare officials to develop appropriate safeguards, according to a sharply critical report to be issued Thursday by federal investigators [the report from HHS OIG is here - ed.] ... Medicare, which is charged with managing the incentive program that encourages the adoption of electronic records, has failed to put in place adequate safeguards to ensure that information being provided by hospitals and doctors about their electronic records systems is accurate. To qualify for the incentive payments, doctors and hospitals must demonstrate that the systems lead to better patient care, meeting a so-called meaningful use standard by, for example, checking for harmful drug interactions. [I note that meeting EHR "meaningful use" standards does not necessarily signify better care; the "standards" are experimental - ed.]

Hospitals and doctors are lying about their EHR efforts, in order to gain incentive payments, it seems.

In an article "IG says program is 'vulnerable' to abuse, better oversight needed", Fred Schulte at the Center for Public Integrity notes:

... the Centers for Medicare and Medicaid Services has since paid out more than $3.6 billion to medical professionals who made the switch without verifying they are meeting the required quality goals, according to a new federal audit to be released today

Observes the CEO of the American Health Information Management Association:

“We’ve gone from the horse and buggy to the Model T, and we don’t know the rules of the road. Now we’ve had a big car pileup,” said Lynne Thomas Gordon, the chief executive of the American Health Information Management Association, a trade group in Chicago. 

More Horse and Buggy than Model T.  At least the Model T was reasonably dependable. 

Also mentioned is this:

House Republicans echoed these concerns in early October in a letter to Kathleen Sebelius, secretary of health and human services. Citing the Times article, they called for suspending the incentive program until concerns about standardization had been resolved. “The top House policy makers on health care are concerned that H.H.S. is squandering taxpayer dollars by asking little of providers in return for incentive payments,” said a statement issued at the same time by the Republicans, who are likely to seize on the latest inspector general report as further evidence of lax oversight. Republicans have said they will continue to monitor the program.

In her letter in response, which has not been made public, Ms. Sebelius dismissed the idea of suspending the incentive program, arguing that it “would be profoundly unfair to the hospitals and eligible professionals that have invested billions of dollars and devoted countless hours of work to purchase and install systems and educate staff.”


I was taught "first, do no harm."  Fairness to patients injured and killed by this technology in its present "Horse and Buggy" state (buggy being a particularly apropos term) seems not a matter of particularly high concern to HHS.   A suspension of incentives would slow the adoption rate down, necessary in order to "get the bugs" out of the technology before mass deployment and develop safety, validation and surveillance standards (currently non-existent), as I wrote in my Oct. 24, 2012 "Letter To U.S. Senators and Representatives Who've Sought HHS Input On EHR Problems."

This is despite the fact that FDA, IOM and others have indicated the level of harm is not known, due to systematic impediments to diffusion of that knowledge (see IOM statements in the midsection of my post on health information technology hyper-enthusiasm at this link, and an internal FDA memo on HIT safety at this link). 

HHS seems to care not about health and human services, or at best to be severely misguided.  "Cybernetik Über Alles" seems their current credo.

-- SS

Wednesday, October 24, 2012

Letter To U.S. Senators and Representatives Who've Sought HHS Input On EHR Problems

Several members of Congress have written HHS demanding meetings on health IT issues such as upcoding, test overutilization, misuse of incentive programs, and other factors as here.

However, what was largely left out was the issue of safety.

I've written this letter to the congresspeople who've written to HHS secretary Sebelius (PDF available at this link):


October 24, 2012

To:

Sens. Coburn, Burr, Roberts and Thune
Reps. Ellmers, Camp, Herger, Upton and Pitts
United States Congress
Washington, DC

Re:  HITECH and healthcare information technology

Dear Senators and Representatives,

I applaud your recent inquiries to HHS regarding critical issues related to healthcare information technology (EHRs, physician order entry, decision supporting systems, etc.)  Issues such as the possible role of these systems in upcoding and Medicare overbilling, test overutilization, abuse of incentives, etc. must be addressed.

However, you did not address an issue probably more important to the public, indeed to us all as patients – that of health information technology safety.

Congress must be made aware that health IT exists in two forms:  good health IT and bad health ITBad health IT reduces safety, creates close calls, injures, kills, raises costs, and sacrifices information privacy and confidentiality, among other ill effects.

Congress must also be made aware that unfortunately due to systemic impediments to free flow of information about health IT systems and lack of FDA or other independent industry regulation, bad health IT is rarely removed from the marketplace or fixed. 

FDA and its director of the Center for Devices and Radiological Health (CDRH), Jeffrey Shuren MD JD, testified to HHS in Feb. 2010 that “under the Federal, Food, Drug, and Cosmetic Act, health information technology software is a medical device”, but that FDA has “largely refrained from enforcing our regulatory requirements with respect to HIT devices.” 

To clarify about the two types of health IT:


Good Health IT provides a good user experience, enhances cognitive function, puts essential information as effortlessly as possible into the physician’s hands, keeps eHealth information secure, protects patient privacy and facilitates better practice of medicine and better outcomes.

Bad Health IT is ill-suited to purpose, hard to use, unreliable, loses data or provides incorrect data, causes cognitive overload, slows rather than facilitates users, lacks appropriate alerts, creates the need for hypervigilance (i.e., towards avoiding IT-related mishaps) that increases stress, is lacking in security, compromises patient privacy or otherwise demonstrates suboptimal design and/or implementation.


The Agency for Healthcare Research and Quality (AHRQ) recently reported that the highest prevalence of medical technology safety issues was related to EHR systems.  Even worse, there is a lack of reporting transparency. Harms are known of, but the magnitude admittedly unknown due to systematic impediments to reporting transparency, collection and analysis, as noted by FDA in a 2010 internal memo and IOM itself in its 2012 report on health IT safety.  This is unprecedented in modern medicine, violates patient’s rights, and under no circumstances should be considered acceptable.

I personally know of adverse patient outcomes including death related to bad health IT that are unreported (even in a state that mandates reporting of medical incidents and serious events), as do numerous colleagues. 

The Institute of Medicine has just released a Discussion Paper written by experts in health information technology entitled “Comparative User Experiences of Health IT Products: How User Experiences Would Be Reported and Used"  (http://www.iom.edu/Global/Perspectives/2012/~/media/Files/Perspectives-Files/2012/Discussion-Papers/comparative-user-experiences.pdf). The recommendations in this paper need to be put into place, and Congressional awareness of the issues and official inquiry as to when this will happen is essential. 

This paper’s recommendations will not happen without the oversight of Congress.  As stated in the paper itself, “Some medical and IT leaders have invested their reputations, and their organization’s time and money, in the software [implementation] program; complaints that expose large problems may not be appreciated or carried forward.” 

Some claim safeguards are already in place in the form of HHS certification of health IT. 

Unfortunately, the HHS health IT certification guidelines do not have sufficient depth nor the correct focus to distinguish between bad health IT and good health IT.  Certification for MU does not look at real-world testing for safety, reliability and usability, for instance, under real loads, in actual clinical settings, and is not very thorough.

On the other hand,  NASA, the pharmaceutical industry (via FDA's regulation of pharmaceutical research and manufacturing IT) and others dependent on mission-critical software have rigorous validation procedures to check for such factors, e.g., NASA’s "Certification Processes for Safety-Critical andMission-Critical Aerospace Software" that includes rigorous testing to distinguish bad IT from good IT, and remediate or abandon the former.

p. 6-7:  In order to meet most regulatory guidelines, developers must build a safety case as a means of documenting the safety justification of a system. The safety case is a record of all safety activities associated with a system throughout its life. Items contained in a safety case include the following:

• Description of the system/software
• Evidence of competence of personnel involved in development of safety-critical software and any safety activity
• Specification of safety requirements
• Results of hazard and risk analysis
• Details of risk reduction techniques employed
• Results of design analysis showing that the system design meets all required safety targets
Verification and validation strategy
• Results of all verification and validation activities
• Records of safety reviews
• Records of any incidents which occur throughout the life of the system
• Records of all changes to the system and justification of its continued safety


These processes need to be put in place regarding healthcare IT as well, but will take much time and regulatory push on the industry to occur.  In the absence of truly rigorous testing, though, transparency is essential.

The aforementioned IOM Discussion Paper outlines the creation of a nationwide post-marketing surveillance process and transparency on health IT usability problems, safety issues, billing fraud promotion, etc. is essential.  It recommends:

¨        “Flight simulator”-like, thorough laboratory evaluation of test scenarios;
¨        Point-of-use reporting by doctors and nurses on their experiences;
¨        Third party–administered doctor and nurse surveys about their experiences with EHR systems;
¨        Direct clinician-to-public reporting; and
¨        A formalized system of hazards reporting from EHR systems.

These measures are essential if the technology is to achieve the benefits of which it is theoretically capable, but not presently achieving despite the hundreds of billions of dollars being spent.

In conclusion, I ask you to add to your inquiries the subject of health information technology safety.  That includes the need for HHS to develop a robust, transparent national reporting system for safety problems created by the technology, and a system to ensure that bad health IT is either fixed in a timely manner or removed from the marketplace.

Sincerely,

Scot Silverstein, MD

-----------------------------------------------------------------
Scot M. Silverstein, MD
Adjunct faculty in Healthcare Informatics and IT (Sept. 2007-present)
Assistant Professor of Healthcare Informatics and IT, and Director, Institute for Healthcare Informatics (2005-7)

Drexel University
College of Information Science and Technology
3141 Chestnut St., Philadelphia, PA 19104-2875

Email:  sms88 AT drexel DOT edu


I hope this letter has some beneficial effect.

-- SS