Rising Costs to Access Your Own EMR Records…
The College of Family Physicians of Canada has released a statement of policy on November 28th. (http://www.cfpc.ca/position-statement-supports-access-EMR-data-quality-improvement-research/). The actual position statement is here (http://www.cfpc.ca/uploadedFiles/Health_Policy/CFPC_Policy_Papers_and_Endorsements/CFPC_Policy_Papers/CFPC-Position-Statement-Supporting-access-data-electronic-medical-records-EN.pdf).
This was released due to some EMR vendors starting to charge large fees just to access your OWN data outside of the EMR. This is because some vendors have come to the conclusion that they can use their control of your data to control your behaviour and make money off of it. (See our article on Who Controls your EMR (http://blogs.semrt.com/2017/03/who-really-controls-your-emr-data/))
You may want access to your own data for research purposes, quality care improvement, general statistics, or just to get a better idea of what is going on in your patient population. In any event – it the clinic’s data – NOT the vendor’s… They should have free and unfettered access to it! Right? Well – the answer is not quite so black and white…
The simple answer should be “Yes”. But it cannot be in our market right now. Mainly due to three reasons.
- Performance and Data Integrity Reasons
Accessing your EMR data can happen in two ways. The first is that you run your queries directly against the live EMR database. The second is that you run it against a backup or a copy of the database.
Live Data Access. Most vendors would not want to allow clinics to access their EMR database live using just any tool. This could lead to data changes that would not be trackable – and done without the controls in place in the EMR software. This may lead to data integrity issues that would be very hard to resolve. Let’s not even begin to talk about the patient safety issues that could be introduced!
Also of a concern for EMR vendors is that of performance of the EMR application itself. A poorly written query can adversely affect the performance of the EMR application, making it slow and non-responsive. Imagine a query run during the day that affects clinic operations! The vendor might end up getting all sorts of calls from clinics, due to a query run by one of the clinic’s own staff or contractors. This could be a customer support nightmare! And in many jurisdictions in the West, there are performance and uptime clauses in the contracts with the vendors that could see them incur additional costs for these sorts of incidents.
Copy/Extract of EMR Data. It would be far better to access a copy of, or an extract from, your live data. This would remove concerns about changing the data accidentally and impacting the data in the live EMR. It would also remove issues around performance concerns – as it would be accessing a totally different database, hopefully on a different database server. This would allow the clinic maximum flexibility. The questions are how to provide it and how much would it cost?
- Whether or not you have a Local or an ASP style installation of your EMR
We started a discussion on this over three years ago – about the unintended consequences of using an ASP EMR. (http://blogs.semrt.com/2014/04/un-intended-consequences-asp-emrs/). If you have moved everything to the ‘cloud’ (i.e. an ASP provider) – then you have trade-offs. You no longer have direct access to your EMR data. That data is stored in a remote server, usually under control of the EMR vendor. You no longer have to worry about backups, crashes, etc. – but you DO have to be concerned with access and control of your data. And as that data is your most important asset – it is something you should be aware of.
Now, if you have a local EMR – then you ‘could’ have direct access to your EMR database – but you still have to be concerned about the performance and data integrity issues above. And in some cases, as with Telus’s PSS Oracle based EMR, the EMR uses technology licenses that actually prohibits any other program but the EMR from accessing the data. (Note: Telus now has a Postgres version of their EMR that removes this restriction – but I am not sure at this point how commonly it is used). And some smaller EMR companies use uncommon databases like “4D” that are difficult to access in any event. Having said this, with a local EMR, you can normally make a copy of your database and use it for research purposes, perform queries after hours, do your own data extracts, etc.
In general, accessing ASP EMR data can truly be difficult. In regards to control and access, a locally installed EMR offers better and easier access to your data in most circumstances.
- Costs that would be incurred by the vendors
EMR Vendors are businesses – they cannot give away a service for free. They would go out of business. While clinics that use locally installed EMRs should normally be able to do their own backups and extractions (possibly with a little training from the EMR vendor) – ASP installed clinics do not have that option. A clinic cannot expect a vendor to do a special backup every week (or month?), encrypt it and make it available to the clinic for free. That service would take time. Now imagine if a 1000 clinics had the same request!! And right now the vendors have no processes in place to handle something like this.
So what is the Solution?
There is not magic wand here that will give the clinics instant access to their data with no costs. As noted above you are better off accessing a copy or an extract from your EMR data, then directly access the live database. So perhaps the vendors need to be able to provide a backup or an extract at a reasonable costs per clinic (NOT PER DOCTOR!) to be enable the use of the EMR data for research and better patient care. Perhaps it should be able to be run by the clinics themselves (for local installs at least!)? Perhaps this should be something that is part of any certification process? In order to sell an EMR in a province you have to demonstrate that your support easy and cost effective data access. This would help return control of the precious EMR medical data back to the physician where it rightfully belongs!
The next question is what is a reasonable cost? This is much harder to define right now, within the confines of a short article. I agree with the College that this should NOT be a profit center for the EMR vendors. It should be more of a cost recovery issue. A lot of this research is for the public good. Just accessing your data should not be cost prohibitive.
So, while I applaud the new statement of policy, I think it needs to be a little more nuanced in order to enable the vendors to really meet the needs of the clinics and allow meaningful and cost effective access to their own data.
Note: As part of full disclosure, TimeAcct is a company that specializes in EMR Data Access and Conversions. We have tools that allow clinics to combine data from multiple EMRs and report on that data.