Tim Thompson, Director
Information Technology DivisionC. Martin Harris, MD
Chief Information Officer
Managing year 2000 (Y2K) compliance
in the medical practice
Abstract
It is the responsibility of every medical
practice to examine the year 2000 compliance of all medical devices, facilities, and
computer systems that it uses, and whether external business partners are also taking
appropriate steps in this area. You need a plan, and you need to start right now.
Problems arising from the transition from the year 1999 to the year 2000 (Y2K) will
affect all medical practices. The impact will vary depending on the degree of automation
used in each organization. However, before you dismiss this issue because you believe you
have little automation in your office, you would do well to take a closer look at your
practice—and at the companies with which you do business. To ensure business
continuity and patient safety, the Y2K issue must not be taken lightly or, worse yet,
ignored. This issue, unlike many others, cannot be put off and considered at a later date.
This article gives examples of what to look for and what to ask of those you count on
to run a typical medical office practice.
False assumptions abound
Many false assumptions surround the Y2K issue, such as:
- "This issue is simply too large of a project for my size group."
- "Vendors and others on whom I rely will address the issue."
- "I do not have a computer in my office,so I am fine."
- "Someone will come out with a ‘silver bullet’ fix to resolve the
issue."
- "I have not been notified that I have a problem, therefore I am compliant."
- "I have not had a problem yet, so I should not be at risk."
These assumptions represent wishful thinking. The problem is real, and you ignore it at
your own risk. Every medical practice has the responsibility to ensure that it will be
able to carry on business as usual come January 1, 2000.
Areas to review
Four primary areas need to be reviewed to determine the compliance status of a
practice: medical equipment, facilities, software and computer systems, and business
partners.
Medical equipment
Many devices used in patient care employ a date calculation to do their jobs.
Y2K-related problems may be more apparent in some medical devices than in others. If a
machine displays a date or uses a date to calculate a result, it should be checked for
compliance.
Do not assume, however, that a machine does not use a date calculation just because it
does not display a date. Some medical devices that do not display a date use a date
routine to determine maintenance schedules or perform a calculation to determine the dose
of a medication or the amount of energy delivered to a patient.
For example, some defibrillators use a date calculation to determine the need for
maintenance. If a program in the machine detemines it has not received maintenance in the
recommended time frame, it displays a warning suggesting preventive maintenance is
required. If this warning is ignored for a prolonged time the machine may stop working
until maintenance is performed.
Another example of a device that could experience a Y2K problem is a visual field
analyzer, which is used for vision testing. These devices utilize the date for printing
test results in a chronological format. When dates before and after January 1, 2000 are
listed, the test results could be arranged in an incorrect chronological order. In
addition, some machines create a baseline based on the date of the first test, to serve as
a reference to evaulate later test results. If the computer fails to properly recognize
the year a test is performed, the wrong reading may be used as the baseline result.
If you cannot easily ascertain the risk of a Y2K problem for a particular piece of
equipment, contact the vendor to have it tested. Test procedures may be available from the
vendor or manufacturer.
If you lease your medical equipment, it may be worth the time to review your lease
agreement and call your representative to determine the obligation of the leasing company
or vendor as it relates to Y2K compliance. Likewise, if the medical equipment is under a
maintenance agreement, you might be able to get Y2K testing procedures and upgrades from
your maintenance vendor.
Facilities
This broad category includes all devices used in operating the facility and your
practice, other than medical equipment. Examples include security systems, fax machines,
telephone systems, elevators, and heating, ventilation, and air-conditioning systems. The
issues and logic that apply to failures in this equipment are much like those in medical
equipment.
If you own your building or are obligated to maintain your facility within a lease, you
will need to ascertain its Y2K compliance yourself. Start by taking an inventory of all
items. As with your medical equipment, you should contact your vendors, leasing agents,
and maintenance providers for Y2K compliance information and testing procedures. If you
lease your facility and equipment, contact the landlord and request a statement ensuring
the compliance of the facility. Without a functioning building your practice will be
unable to operate.
Software and computer systems
Software and computer systems make up the most complex category to consider. If you
have automated any portion of your practice, such as scheduling or billing, your practice
has likely become dependent on computer systems. To ensure the continuity of these
functions, you need a plan for testing these systems for Y2K problems and, if necessary,
for fixing them.
Networks should be considered first. If you can access information
from more than one device (personal computer or terminal), you probably have a network,
which is driven by a combination of hardware and software. To adequately validate your
network for compliance you, will likely need a network technician. This person should test
all components, including switching equipment, routers, hubs, servers, network software,
and each workstation that requires access to the network, including hardware and operating
systems.
Personal computers. If you use a single or stand-alone personal
computer, you can disregard the network-related issues, but you must still confirm the
compliance of your hardware and operating system. A number of commercially available
programs can do this. A good deal of information is also available on the Internet from
software vendors.
Application software should be validated next, especially the programs
you use for scheduling, billing, and medical records. Each program should be tested by
entering a variety of year 2000 dates in each function that the program performs. For
example, try to schedule a patient for a return visit in January 2000, or put a reminder
for a follow-up call in February 2000 on your accounts-receivable system.
However, these are only two of potentially hundreds of date-related scenarios to be
tested with each software application. The software vendor should be contacted and asked
to provide test scripts for your specific software.
Moreover, simply confirming that the application functions with a year 2000 date is
just one of many date tests that should be performed. Others dates with potential problems
include:
- 9/9/99 (some systems are programmed to respond differently when encountering a field
with all nines)
- 12/31/99 (the last day of 1999)
- 1/1/00 (the first day of 2000)
- 2/29/00 (2000 is a leap year)
- 3/1/00 (the first day after 2/29/00)
- 12/31/00 (the first year end)
- 2/29/04 (the next leap year date)
- 3/1/04 (the first day after 2/29/04).
If errors or failures occur in the testing of an application, the software needs to be
updated with a corrective software "patch." Many practice management systems are
installed without the original programming code, in which case all changes must be made by
the software vendor. The major application vendors should have software patches scheduled
for release or available to make their products Y2K-compliant.
If your application was custom-written for your practice rather than purchased
"off the shelf," or if the vendor is no longer in business but you have access
to the source code, the alternative is to have a programmer test the system and fix it to
bring it into compliance. If none of the above are possible options, you may need to
replace the application.
External business partners
No man is an island, and no medical practice is either. To function, most practices
rely on a number of external partners, such as health maintenance organizations, other
payers, suppliers of medical equipment and supplies, banks, accountants, billing services,
hospitals, ambulatory surgery centers, utility companies, and other medical practices. You
cannot control how they run their own businesses, but if they have a problem, you have a
problem too.
Most business organizations have already implemented a Y2K remediation program. As part
of that effort, they provide summary information of their projects and progress towards
reaching compliant status. Request-ing this information should help the owners of a
medical practice assess their risk with an individual business partner.
Legal ramifications
While moving through the Y2K project, it is essential to maintain proper documentation
during all phases. Legal cases based on Y2K issues are likely to occur. In fact,
litigation related to the Y2K initiative is estimated to equal the cost of the repair:
$400 to $600 million nationally.
It is in your best interest to document the diligent efforts that you are making to
avoid Y2K problems. Legal counsel should be involved early in the process to help avoid
pitfalls. Documentation of the overall plan and specific remedies should be maintained in
case an unexpected failure occurs with a system that has been "repaired."
Get started now
When considering a problem the size of Y2K, it is important to separate the project
into manageable components. The categories listed above are just one method of
compartmentalizing the project initiatives. The important thing at this point is to get
started—not to worry about the specific method.
Medical practices will not be in a position to address all components of the year Y2K
project themselves. Fortunately, many resources are available. For example, consider your
local hospital. Hospitals face issues similar to those faced by medical practices, and
many have a team dedicated to the Y2K effort, which may be able to help you. Other sources
are software consultants, biomedical engineering contractors, healthcare software vendors,
and computer vendors. As in purchasing any service, it is important to find a reputable
partner. Spend time talking to the consultants and develop a comfort level with their
work. It is important to get a list of previous clients and a customer reference list.
The important thing to remember is—get started now.
Suggested web sites
American Hospital Association. Year
2000 resource center.
Food and Drug Administration.
Year 2000 impact on biomedical equipment.
Michigan Electronic Library.
Health information resources. Y2K-Year 2000 resources for health care.
National Institutes of Health. Year 2000
working group.
John D. Clough, M.D., editor-in-chief
Linda K. Hengstler, editor and publisher
Phillip E. Canuto, executive editor
Ray Borazanian, managing editor |
