Can i get propecia without a prescription

The Supreme Court upheld the Affordable can i get propecia without a prescription Care Act today in a 7-2 ruling. The court dismissed a challenge to the law, noting that the states and individuals who were trying to overturn the ACA did not have standing. This is the third time the ACA has can i get propecia without a prescription survived challenges in the Supreme Court. In 2012, the ruling was 5-4, and in 2015, the ruling was 6-3. These cases have all had varying arguments and merits, but it’s noteworthy that although the court has become more conservative over the last decade, the justices have increasingly favored the ACA.

In this year’s case, some legal analysts had speculated that the court might overturn the can i get propecia without a prescription ACA’s individual mandate but allow it to be severed from the rest of the ACA. That approach would have upheld the ACA as well, but the court simply dismissed the whole case. (This thread from Nicholas Bagley is a great summary, if you’re interested in the specifics.) So nothing has can i get propecia without a prescription changed. The ACA remains intact, and the general consensus is that it’s here to stay. Is this decision the end of legal challenges to the ACA?.

That can i get propecia without a prescription doesn’t mean the Affordable Care Act won’t continue to face legal challenges — a case that’s currently under consideration in Texas takes aim at the ACA’s requirement that health plans fully cover the cost of certain preventive care. But that case does not seek to overturn the ACA itself, and it appears unlikely that the Supreme Court would take up any other case that might aim to do so. What does this decision mean for consumers?. There was a collective can i get propecia without a prescription sigh of relief this morning among people who are enrolled in Medicaid under the ACA’s expanded eligibility guidelines, as well as those who purchase their own individual/family health insurance and rely on the ACA’s premium tax credits, cost-sharing reductions, guaranteed-issue rules and coverage for pre-existing conditions, and essential health benefits. According to a recent analysis by Charles Gaba, more than 10% of all Americans are covered under Medicaid expansion, ACA-compliant individual/family health plans, and Basic Health Programs, all of which stem directly from the ACA.

As we’ve explained during prior legal and legislative challenges to the ACA, the law provides can i get propecia without a prescription a vast array of additional consumer protections that extend to most Americans in one way or another. But the people who are most likely to feel a sense of relief today are those enrolled in coverage that either wouldn’t exist or wouldn’t be accessible to them without the ACA. The anxiety about losing health coverage is no longer hanging over these Americans. Premium subsidies will continue to be available, and the subsidy enhancements provided by the American Rescue Plan will continue to be in effect throughout 2022 can i get propecia without a prescription – and possibly longer, if Congress acts to extend them. If you’ve been on the fence about enrolling in individual/family coverage during the special enrollment period that’s currently ongoing in nearly every state, you can now enroll with confidence.

And the same is true about signing up for 2022 coverage when open enrollment starts in November. And although today’s ruling was on a lawsuit that hinged around the individual mandate and penalty, can i get propecia without a prescription nothing has changed about the ACA’s requirement that most people maintain health insurance. There continues to be no federal penalty for not having health insurance, as has been the case since 2019. (If you’re in California, Massachusetts, New Jersey, Rhode Island, or the District of Columbia, there’s still a penalty for going without health insurance.) What does the can i get propecia without a prescription decision mean for health insurers?. Insurers that offer individual/family health insurance have been displaying increasing confidence in the ACA for the last few years.

After fleeing the marketplaces/exchanges in 2017 and 2018, insurers started to join or rejoin the marketplaces in 2019. That trend continued in can i get propecia without a prescription 2020 and 2021, and we’re already seeing more insurer participation in the initial 2022 rate proposals that have been submitted by insurers in several states. The case that the Supreme Court dismissed today was initially filed in early 2018, so the legal threat to the ACA has been in the background throughout those three years of increasing insurer participation in the ACA-compliant insurance market. Although insurance companies — and the actuaries who set premiums — tend to be quite averse to uncertainty, the individual market has proven to be profitable for insurers in recent years (after being unprofitable in the early years of ACA can i get propecia without a prescription implementation). Insurers’ increasing willingness to offer plans in the marketplace is testament to that, despite the uncertainty that the lawsuit created over the last few years.

Now that there’s no longer a pending legal threat to the ACA, we might see even more insurers opting to join the marketplaces or expand their existing coverage areas. What does the can i get propecia without a prescription decision mean for states?. Although many states have enacted laws designed to protect consumers in case the ACA had been overturned, there’s no getting around the fact that they rely heavily on federal funding that’s provided under the ACA. Without that funding, most states would not have been able to maintain the ACA’s Medicaid expansion or affordability provisions for self-purchased health insurance. There’s no longer a can i get propecia without a prescription threat to the funding, which might make states more likely to push forward with additional consumer protections tied to the ACA.

Among the most obvious is Medicaid expansion in the 13 states that have not yet accepted federal funding to expand Medicaid eligibility under the ACA. The American Rescue Plan provides two years of additional can i get propecia without a prescription federal funding to states that newly expand Medicaid. So far, Oklahoma is the only state making use of that provision, and the state had already planned to expand Medicaid this year as a result of a ballot measure that Oklahoma voters passed last year. To be fair, the other 13 states have rejected Medicaid expansion year after year, including during the 2020 and 2021 legislative sessions that took place during a global propecia. Without a change to the makeup of their can i get propecia without a prescription legislatures, most are likely to continue to do so.

But now that the Supreme Court has upheld the ACA yet again, states that newly expand Medicaid can do so without a lingering worry that the federal funding might be eliminated. It’s also possible that more states might consider reinsurance programs that make use of the ACA’s 1332 waiver provisions. But that would also depend can i get propecia without a prescription on whether the American Rescue Plan’s subsidy enhancements are extended beyond 2022. Reinsurance programs make coverage more affordable for people who don’t receive premium subsidies. Before the ARP eliminated the “subsidy cliff” for 2021 and 2022, the lack of affordability for households earning a little more than 400% of the poverty level was a very real can i get propecia without a prescription problem.

But that’s not currently an issue, as those households qualify for subsidies if the benchmark plan would otherwise cost them more than 8.5% of their income. If Congress extends that provision, reinsurance programs would help very few enrollees (and they can also harm subsidized enrollees in some areas, since they reduce the size of premium subsidies). State legislatures will need to keep an eye on how this plays out at the federal level, but without an extension of the ARP’s subsidy structure, we can expect to see more states pursuing 1332 waivers for reinsurance programs in the next can i get propecia without a prescription few years. Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens can i get propecia without a prescription of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.

Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.The American Rescue Plan Act (or American Rescue Plan), signed into law by President Biden on March 11, provided many types of relief to Americans from the economic ravages of the hair loss treatment propecia. Among them, the American Rescue Plan (ARP) put the “affordable” in “Affordable Care Act” for millions of Americans. Did ARP make coverage can i get propecia without a prescription more affordable at all income levels?. The American Rescue Plan increased premium subsidies at all income levels for health plans sold in the ACA marketplaces, reducing the percentage of income that enrollees have to pay for the “benchmark” plan in their area – that is, the second-cheapest Silver plan. The Supreme Court upholds the Affordable Care Act.

What it means for can i get propecia without a prescription policyholders. At incomes up to 150% of the Federal Poverty Level ($19,140 for an individual, $39,300 for a family of four), the benchmark plan is free, and from 150% up to 200% FPL ($25,520 for an individual, $52,440 for family of four), benchmark Silver costs no more than 2% of family income. Silver plans at these income levels come with strong cost-sharing reduction (CSR) that reduces deductibles and out-of-pocket costs can i get propecia without a prescription. Weaker CSR is available up to 250% FPL. At the other end of the income scale – 400% FPL or higher ($51,040 for an individual, $104,800 for a family of four) – no citizen or legally present noncitizen who lacks access to other affordable insurance (e.g., from an employer or Medicare) will pay more than 8.5% of income for benchmark Silver.

The ARP removed the ACA’s notorious subsidy can i get propecia without a prescription cliff, which denied subsidies to applicants with incomes over 400% FPL. In the in-between income brackets, the percentage of income required for a benchmark Silver plan has also been sharply reduced. See this post for illustrations of how ARP will reduce premiums for people at various income levels. The American Rescue can i get propecia without a prescription Plan also effectively made free high-CSR Silver plans free to anyone who received any unemployment insurance compensation in 2021 and lacked access to other affordable insurance. The ARP subsidy boosts are temporary, running through 2022.

But Democrats are can i get propecia without a prescription widely expected to make them permanent in subsequent legislation. That’s the first and most basic item on their healthcare agenda, fulfilling a core promise President Biden made during the 2020 campaign. ARP subsidies make it a great time to buy new health coverage The ARP subsidy increases should induce millions of uninsured Americans who have been under the impression that health insurance is unaffordable to take a second look. According to estimates by the Kaiser Family Foundation (KFF), as of 2020, only can i get propecia without a prescription about half of those who were eligible for marketplace subsidies and in need of insurance were enrolled. KFF estimates that 11 million uninsured Americans are eligible for premium subsidies in the marketplace – including 3.5 million with incomes over 400% FPL who were ineligible prior to the ARP.

How affordable can i get propecia without a prescription is affordable?. According to KFF, 6 million uninsured people are eligible for free plans. It’s true that for most of these (4.7 million), the free plan would be Bronze, with deductibles averaging in the $7,000 range. But for many of those eligible for free Bronze plans, can i get propecia without a prescription Silver – and in some cases Gold plans – are available at very low cost or even no cost at all. For solo enrollees in the 150-200% FPL income range (topping out at $25,520), benchmark Silver (with strong CSR) can’t cost more than $43 per month.

In many cases, the cheapest Silver plan costs considerably less than the benchmark. And in about can i get propecia without a prescription 20% of all U.S. Counties, the cheapest Gold plan is cheaper than the cheapest Silver. That’s a valuable discount at incomes above 200% FPL, where CSR, which attaches only to Silver plans, is weak (in the 200-250% can i get propecia without a prescription FPL income range) or not available (at incomes above 250% FPL). Biden administration opens the doors and sounds the horn Prior to the American Rescue Plan’s passage – beginning on February 15 – the Biden administration opened an emergency special enrollment period (SEP), extending until August 15 in the 36 states that use the federal ACA exchange, HealthCare.gov.

The 15 state-run exchanges (including Washington, D.C.) followed suit, though the terms and length of the state SEPs vary somewhat. (See SEP can i get propecia without a prescription deadlines for each exchange here.) The SEP offered by HealthCare.gov and in most states is akin to the annual open enrollment period. Anyone who lacks insurance can enroll. Normally, a person seeking coverage outside of open enrollment has to apply for a personal SEP and document a qualifying “life change,” such as loss of employer-sponsored insurance. After the ARP’s passage, HealthCare.gov further opened the SEP to enable current enrollees to switch plans – for example, to upgrade from Bronze to Silver in light of the enriched subsidies can i get propecia without a prescription.

The Center for Medicare and Medicaid Services (CMS) also earmarked $50 million to advertise the SEP. The upgraded subsidies, retroactive to January 1, went live on HealthCare.gov on April 1, and on can i get propecia without a prescription state-based marketplaces in subsequent weeks. All in all, doors to coverage for the uninsured were flung significantly wider this spring – and remain open. Many consumers are capitalizing on the SEP and ARP The emergency SEP and upgraded subsidies are having an impact. On May 6, CMS announced that new plan selections from February 15 through April 30 in 36 HealthCare.gov states was just shy can i get propecia without a prescription of 940,000 – almost quadruple enrollment in the same period in 2019, the last “normal” year.

(In 2020, the propecia also stimulated increased enrollment, totaling 391,000 in the same time period.) A large percentage of new enrollees were apparently low-income and accessing free or near-free Silver plans with strong CSR, as the median deductible for new enrollees was just $50. As of June 5, SEP enrollment in HealthCare.gov states had topped can i get propecia without a prescription 1 million, and marketplace coverage is now at an all-time high. Including the 15 state-based marketplaces raises the SEP enrollment total this spring to 1.5 million, according to Charles Gaba’s estimate. The percentage of subsidy-eligible potential enrollees who actually do enroll may now be closer to 60% than the roughly 50% that KFF estimates indicate in 2020. How might enrollment can i get propecia without a prescription be boosted further?.

But millions still aren’t on board Despite the substantial gains achieved in recent months, some 10 million of the still-uninsured are likely eligible for marketplace subsidies, and another 6 to 7 million eligible for Medicaid, according to KFF estimates. Since the ACA’s programs were first implemented in 2014, many of the uninsured have claimed that they found coverage unaffordable, While some may have balked at subsidized premiums and available plans’ out-of-pocket costs, a lack of knowledge about what’s on offer has always been a major factor. In 2020, only 32% of people can i get propecia without a prescription surveyed by KFF knew that the ACA was still law. The Trump administration didn’t make it easier for consumers, cutting federal funding for enrollment assistance by nonprofit “navigators” by 84%, from a peak of $63 million in 2016 to $10 million by 2018, and cutting advertising by 90%. Navigator organizations, established by the ACA to be nerve centers in a constellation of nonprofit assistor groups, have operated on shoestrings since fall 2017, can i get propecia without a prescription cutting back on outreach events, offices throughout their states, and in-person as opposed to phone or video assistance.

The Biden administration threw a quick $2.5 million to navigators this spring – which doesn’t go far – and has allocated $80 million for navigators in the 36 states using HealthCare.gov for 2022. (Navigator funding is drawn from user fees charged to participating insurers, so the 15 states that run their own exchanges have their own funding base for enrollment assistance). A KFF analysis suggests that the $80 million allocation for 2022 may be too can i get propecia without a prescription modest. Trump administration underspending of the user fee revenue has left some $1.2 billion available to the Biden administration to boost enrollment efforts. Promising strategies to boost enrollment Going forward, further innovation might boost marketplace enrollment.

Maryland, which has a state-based marketplace, has pioneered an enrollment jump-start tied to tax filing, whereby the uninsured whose reported income and insurance status indicate they are eligible for can i get propecia without a prescription subsidized coverage can check a box on their tax return and receive information about their likely eligibility for “free or low cost coverage.” Colorado will debut a similar program next year. On a national level, aligning the annual open enrollment period with tax filing season and porting information on the tax return to a marketplace application could streamline the enrollment process. Tax preparers could be a powerful resource to encourage enrollment can i get propecia without a prescription and assist in the often complex application process. Integrating enrollment with tax preparation could also take some of the diceyness out of the income estimate that determines subsidy size. Switching the OE period would entail a messy transition, as plans not resetting on January 1 as in the past would create problems with deductibles and out-of-pocket caps.

An alternative would be can i get propecia without a prescription to mirror Maryland and offer the uninsured an easy-to-obtain SEP at tax time. The ARP hasn’t helped everyone It should be acknowledged that the ARP did not ease the plight of poor and near-poor uninsured people in the 12 states that to date have refused to enact the ACA Medicaid expansion (or, in the case of Wisconsin, enact a more limited expansion). As first enacted, the ACA offered Medicaid to all citizens and most legally present can i get propecia without a prescription non-citizens whose household income was below 138% FPL. In 2012, the Supreme Court made that expansion optional for states. In states that refused to expand eligibility – including high-population states Texas and Florida – most adult residents with incomes below 100% FPL are eligible neither for Medicaid nor for marketplace subsidies.

The ARP provided can i get propecia without a prescription new financial enticements for the holdout states to implement the expansion, but offered no immediate relief to an estimate 2 million people in this “coverage gap.” The ARP also did not fix the “family glitch,” which puts health coverage out of reach for several million Americans. If an employee has access to a comprehensive employer-sponsored health plan that meets the ACA affordability standard for single coverage, the other family members are not eligible for subsidies in the exchange — regardless of how much they have to pay to join the employer-sponsored plan. Bottom line While more remains to be done to make affordable coverage more universally available, comprehensive and easy to obtain, it’s fair to say that most Americans who lack coverage at present can find a health plan (marketplace or Medicaid) that’s worth having at a price they can afford. If you are uninsured, check out your options on HealthCare.gov or your state exchange can i get propecia without a prescription or use this site’s free quote tool. You can also get a subsidy estimate by using this ACA subsidy calculator.

More likely than not, you will be pleasantly can i get propecia without a prescription surprised. Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid. His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D.

In English literature from the University of Rochester..

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hair loss treatment has evolved rapidly how can i get propecia into a propecia with global impacts. However, as the propecia has developed, it has become increasingly evident that the risks of how can i get propecia hair loss treatment, both in terms of rates and particularly of severe complications, are not equal across all members of society. While general risk factors for hospital admission with hair loss treatment include age, male sex and specific comorbidities (eg, cardiovascular disease, hypertension and diabetes), there is increasing evidence that people identifying with Black, Asian and Minority Ethnic (BAME) groupsi have disproportionately higher risks of being adversely affected by hair loss treatment in the UK and the USA. The ethnic disparities include overall numbers of cases, as well as the relative numbers of critical care admissions and deaths.1In the area of mental health, for people from BAME groups, even before the current propecia there were already significant mental health inequalities.2 These inequalities have been increased how can i get propecia by the propecia in several ways.

The constraints of quarantine have made access to traditional face-to-face support from mental health services more difficult in general. This difficulty how can i get propecia will increase pre-existing inequalities where there are challenges to engaging people in care and in providing early access to services. The restrictions may also reduce the flexibility of care offers, given the need for social isolation, limiting non-essential travel and closure of routine clinics. The service impacts are compounded by constraints on the use of non-traditional or alternative routes to care and support.In addition, there is growing evidence of specific mental health consequences from significant hair loss treatment , with increased rates of not only post-traumatic stress disorder, anxiety and depression, but also specific neuropsychiatric symptoms.3 Given the higher risks of mental illnesses and complex care needs among ethnic minorities how can i get propecia and also in deprived inner city areas, hair loss treatment seems to deliver a double blow.

Physical and mental health vulnerabilities are inextricably linked, especially as a significant proportion of healthcare workers (including in mental health services) in the UK are from BAME groups.Focusing on mental health, there is very little hair loss treatment-specific guidance on the needs of patients in the BAME group. The risk to staff in general healthcare (including mental healthcare) is a particular concern, and in response, the Royal College of Psychiatrists and NHS how can i get propecia England have produced a report on the impact of hair loss treatment on BAME staff in mental healthcare settings, with guidance on assessment and management of risk using an associated risk assessment tool for staff.4 5However, there is little formal guidance for the busy clinician in balancing different risks for individual mental health patients and treating appropriately. Thus, for example, an inpatient clinician may want to know whether a patient who is older, has additional comorbidities and is from an ethnic background, should be started on one antipsychotic medication or another, or whether treatments such as vitamin D prophylaxis or treatment and venous thromboembolism prevention should be started earlier in the context of the hair loss treatment propecia. While syntheses of the existing guidelines are available about hair loss treatment and mental health,6 7 there is nothing specific about the healthcare needs of patients from ethnic minorities during the propecia.To fill this gap, we propose three core actions that may help:Ensure good information and psychoeducation packages are made available to those with English as a second language, and ensure health beliefs and knowledge are based on the best evidence available how can i get propecia.

Address culturally grounded explanatory models and illness perceptions to allay fears and worry, and ensure timely how can i get propecia access to testing and care if needed.Maintain levels of service, flexibility in care packages, and personal relationships with patients and carers from ethnic minority backgrounds in order to continue existing care and to identify changes needed to respond to worsening of mental health.Consider modifications to existing interventions such as psychological therapies and pharmacotherapy. Have a high index of suspicion to take into account emerging physical health problems and the greater risk of serious consequences of hair loss treatment in ethnic minority people with pre-existing chronic conditions and vulnerability factors.These actions are based on clinical common sense, but guidance in this area should be provided on the basis of good evidence. There has how can i get propecia already been a call for urgent research in the area of hair loss treatment and mental health8 and also a clear need for specific research focusing on the post-hair loss treatment mental health needs of people from the BAME group. Research also needs to recognise the diverse range of different people, with different needs and vulnerabilities, who are grouped under the multidimensional term BAME, including people from different generations, first-time migrants, people from Africa, India, the Caribbean and, more recently, migrants from Eastern Europe.

Application of a race equality impact assessment to all research questions and methodology has recently been proposed as a first step in this process.2 At this early how can i get propecia stage, the guidance for assessing risks of hair loss treatment for health professionals is also useful for patients, until more refined decision support and prediction tools are developed. A recent Public Health England report on ethnic minorities and hair loss treatment9 recommends better recording of ethnicity data in health and social care, and goes further to suggest this should also apply to death certificates. Furthermore, the report recommends more participatory and experience-based research to understand causes and consequences of pre-existing multimorbidity and hair loss treatment , integrated care systems that work well for susceptible and marginalised groups, culturally competent health promotion, prevention and occupational risk assessments, and recovery strategies to mitigate the risks of widening inequalities as we come out of restrictions.Primary data collection will need to cover not only hospital admissions how can i get propecia but also data from primary care, linking information on mental health, hair loss treatment and ethnicity. We already have research and specific guidance emerging on other risk factors, such as age and gender.

Now we also need to focus on an equally important how can i get propecia aspect of vulnerability. As clinicians, we need to balance the relative risks for each of our patients, so that we can act promptly and proactively in response to their individual needs.10 For this, we need evidence-based guidance to ensure we are balancing every risk appropriately and without bias.Footnotei While we have used the term ‘people identifying with BAME groups’, we recognise that this is a multidimensional group and includes vast differences in culture, identity, heritage and histories contained within this abbreviated term..

hair loss treatment has evolved rapidly into a propecia can i get propecia without a prescription with global impacts. However, as the propecia has developed, it has become increasingly evident that the risks of hair loss treatment, can i get propecia without a prescription both in terms of rates and particularly of severe complications, are not equal across all members of society. While general risk factors for hospital admission with hair loss treatment include age, male sex and specific comorbidities (eg, cardiovascular disease, hypertension and diabetes), there is increasing evidence that people identifying with Black, Asian and Minority Ethnic (BAME) groupsi have disproportionately higher risks of being adversely affected by hair loss treatment in the UK and the USA. The ethnic disparities include overall numbers of cases, as well as the relative numbers of critical care admissions and deaths.1In the area of mental health, for people from BAME groups, even before the current propecia there were already significant mental health inequalities.2 These inequalities have been increased by the can i get propecia without a prescription propecia in several ways.

The constraints of quarantine have made access to traditional face-to-face support from mental health services more difficult in general. This difficulty will increase pre-existing inequalities where there are challenges to engaging people in care and in providing can i get propecia without a prescription early access to services. The restrictions may also reduce the flexibility of care offers, given the need for social isolation, limiting non-essential travel and closure of routine clinics. The service impacts are compounded by constraints on the use of non-traditional or alternative routes to care and support.In addition, there is growing evidence of specific mental health consequences from significant hair loss treatment , with increased rates of not only post-traumatic stress disorder, can i get propecia without a prescription anxiety and depression, but also specific neuropsychiatric symptoms.3 Given the higher risks of mental illnesses and complex care needs among ethnic minorities and also in deprived inner city areas, hair loss treatment seems to deliver a double blow.

Physical and mental health vulnerabilities are inextricably linked, especially as a significant proportion of healthcare workers (including in mental health services) in the UK are from BAME groups.Focusing on mental health, there is very little hair loss treatment-specific guidance on the needs of patients in the BAME group. The risk to staff in general healthcare (including mental healthcare) is a particular concern, and in response, the Royal College of Psychiatrists and NHS England have produced a report on the impact of hair loss treatment on BAME staff in mental healthcare settings, with guidance on assessment and management of risk using an associated risk can i get propecia without a prescription assessment tool for staff.4 5However, there is little formal guidance for the busy clinician in balancing different risks for individual mental health patients and treating appropriately. Thus, for example, an inpatient clinician may want to know whether a patient who is older, has additional comorbidities and is from an ethnic background, should be started on one antipsychotic medication or another, or whether treatments such as vitamin D prophylaxis or treatment and venous thromboembolism prevention should be started earlier in the context of the hair loss treatment propecia. While syntheses of the existing guidelines are available about hair loss treatment and mental health,6 7 there is nothing specific about the healthcare needs of patients from ethnic minorities during the propecia.To fill this gap, we propose three core actions that may help:Ensure good information and psychoeducation packages are made available to those with English as a second language, and ensure health beliefs and knowledge are based on the can i get propecia without a prescription best evidence available.

Address culturally grounded explanatory models and illness perceptions to allay fears and worry, and ensure timely access to can i get propecia without a prescription testing and care if needed.Maintain levels of service, flexibility in care packages, and personal relationships with patients and carers from ethnic minority backgrounds in order to continue existing care and to identify changes needed to respond to worsening of mental health.Consider modifications to existing interventions such as psychological therapies and pharmacotherapy. Have a high index of suspicion to take into account emerging physical health problems and the greater risk of serious consequences of hair loss treatment in ethnic minority people with pre-existing chronic conditions and vulnerability factors.These actions are based on clinical common sense, but guidance in this area should be provided on the basis of good evidence. There has already been a call for urgent can i get propecia without a prescription research in the area of hair loss treatment and mental health8 and also a clear need for specific research focusing on the post-hair loss treatment mental health needs of people from the BAME group. Research also needs to recognise the diverse range of different people, with different needs and vulnerabilities, who are grouped under the multidimensional term BAME, including people from different generations, first-time migrants, people from Africa, India, the Caribbean and, more recently, migrants from Eastern Europe.

Application of a race can i get propecia without a prescription equality impact assessment to all research questions and methodology has recently been proposed as a first step in this process.2 At this early stage, the guidance for assessing risks of hair loss treatment for health professionals is also useful for patients, until more refined decision support and prediction tools are developed. A recent Public Health England report on ethnic minorities and hair loss treatment9 recommends better recording of ethnicity data in health and social care, and goes further to suggest this should also apply to death certificates. Furthermore, the report recommends more participatory and experience-based research to understand causes and consequences can i get propecia without a prescription of pre-existing multimorbidity and hair loss treatment , integrated care systems that work well for susceptible and marginalised groups, culturally competent health promotion, prevention and occupational risk assessments, and recovery strategies to mitigate the risks of widening inequalities as we come out of restrictions.Primary data collection will need to cover not only hospital admissions but also data from primary care, linking information on mental health, hair loss treatment and ethnicity. We already have research and specific guidance emerging on other risk factors, such as age and gender.

Now we also need to focus on an equally important aspect of vulnerability can i get propecia without a prescription. As clinicians, we need to balance the relative risks for each of our patients, so that we can act promptly and proactively in response to their individual needs.10 For this, we need evidence-based guidance to ensure we are balancing every risk appropriately and without bias.Footnotei While we have used the term ‘people identifying with BAME groups’, we recognise that this is a multidimensional group and includes vast differences in culture, identity, heritage and histories contained within this abbreviated term..

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Start Preamble Food and Drug Administration, HHS cure propecia side effects. Notice of availability. The Food and Drug Administration (FDA) is announcing the availability of a revised draft cure propecia side effects guidance for industry entitled “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act” (“revised draft guidance”). This revised draft guidance, when finalized, will describe how FDA intends to apply certain provisions of the Federal Food, Drug, and Cosmetic Act (FD&C Act) to human drug products compounded by State-licensed pharmacies that are not outsourcing facilities and distributed for use within a hospital or health system.

First, it addresses the requirement that compounding be based on the receipt of a valid prescription order for an identified individual patient. Second, it addresses the cure propecia side effects provision concerning compounded drug products that are essentially copies of a commercially available drug product. This draft guidance revises the draft guidance issued in 2016 entitled, “Hospital and Health System Compounding Under the Federal Food, Drug, and Cosmetic Act” (“draft guidance”). FDA is revising the draft guidance to address stakeholder feedback and provide further clarification on policies regarding hospital and health system compounding.

This revised cure propecia side effects draft guidance is not final nor is it in effect at this time. Submit either electronic or written comments on the revised draft guidance by December 6, 2021 to ensure that the Agency considers your comment on this revised draft guidance before it begins work on the final version of the guidance. Submit electronic or written comments on the proposed collection of information in the revised draft guidance by December 6, 2021. You may submit comments cure propecia side effects on any guidance at any time as follows.

Electronic Submissions Submit electronic comments in the following way. Start Printed Page 55848 • Federal eRulemaking Portal. Https://www.regulations.gov. Follow the instructions for submitting comments.

Comments submitted electronically, including attachments, to https://www.regulations.gov will be posted to the docket unchanged. Because your comment will be made public, you are solely responsible for ensuring that your comment does not include any confidential information that you or a third party may not wish to be posted, such as medical information, your or anyone else's Social Security number, or confidential business information, such as a manufacturing process. Please note that if you include your name, contact information, or other information that identifies you in the body of your comments, that information will be posted on https://www.regulations.gov. If you want to submit a comment with confidential information that you do not wish to be made available to the public, submit the comment as a written/paper submission and in the manner detailed (see “Written/Paper Submissions” and “Instructions”).

Written/Paper Submissions Submit written/paper submissions as follows. • Mail/Hand Delivery/Courier (for written/paper submissions). Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852.

For written/paper comments submitted to the Dockets Management Staff, FDA will post your comment, as well as any attachments, except for information submitted, marked and identified, as confidential, if submitted as detailed in “Instructions.” Instructions. All submissions received must include the Docket No. FDA-2016-D-0271 for “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act.” Received comments will be placed in the docket and, except for those submitted as “Confidential Submissions,” publicly viewable at https://www.regulations.gov or at the Dockets Management Staff between 9 a.m. And 4 p.m., Monday through Friday, 240-402-7500.

• Confidential Submissions—To submit a comment with confidential information that you do not wish to be made publicly available, submit your comments only as a written/paper submission. You should submit two copies total. One copy will include the information you claim to be confidential with a heading or cover note that states “THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION.” The Agency will review this copy, including the claimed confidential information, in its consideration of comments. The second copy, which will have the claimed confidential information redacted/blacked out, will be available for public viewing and posted on https://www.regulations.gov.

Submit both copies to the Dockets Management Staff. If you do not wish your name and contact information to be made publicly available, you can provide this information on the cover sheet and not in the body of your comments and you must identify this information as “confidential.” Any information marked as “confidential” will not be disclosed except in accordance with 21 CFR 10.20 and other applicable disclosure law. For more information about FDA's posting of comments to public dockets, see 80 FR 56469, September 18, 2015, or access the information at. Https://www.govinfo.gov/​content/​pkg/​FR-2015-09-18/​pdf/​2015-23389.pdf.

Docket. For access to the docket to read background documents or the electronic and written/paper comments received, go to https://www.regulations.gov and insert the docket number, found in brackets in the heading of this document, into the “Search” box and follow the prompts and/or go to the Dockets Management Staff, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852, 240-402-7500. You may submit comments on any guidance at any time (see 21 CFR 10.115(g)(5)).

Submit written requests for single copies of this revised draft guidance to the Division of Drug Information, Center for Drug Evaluation and Research, Food and Drug Administration, 10001 New Hampshire Ave., Hillandale Building, 4th Floor, Silver Spring, MD 20993-0002. Send one self-addressed adhesive label to assist that office in processing your request or include a fax number to which the revised draft guidance may be sent. See the SUPPLEMENTARY INFORMATION section for information on electronic access to the revised draft guidance. Start Further Info With regard to the revised draft guidance.

Tracy Rupp, Center for Drug Evaluation and Research, Food and Drug Administration, 10903 New Hampshire Ave., Bldg. 51, Silver Spring, MD 20993, 301-796-3100. With regard to the proposed collection of information. Domini Bean, Office of Operations, Food and Drug Administration, Three White Flint North, 10A-12M, 11601 Landsdown St., North Bethesda, MD 20852, 301-796-5733, PRAStaff@fda.hhs.gov.

End Further Info End Preamble Start Supplemental Information I. Background FDA is announcing the availability of a revised draft guidance for industry entitled “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act.” Pharmacies located within a hospital, or standalone pharmacies that are part of a health system, frequently provide compounded drug products for administration within the hospital or health system. Some of these compounders seek to compound under section 503A of the FD&C Act (21 U.S.C. 353a) and others have registered with FDA as outsourcing facilities and are subject to section 503B of the FD&C Act (21 U.S.C.

353b). Section 503A of the FD&C Act describes the conditions that must be satisfied for human drug products compounded by a licensed pharmacist in a State-licensed pharmacy or Federal facility, or by a licensed physician, to be exempt from the following three sections of the FD&C Act. Section 501(a)(2)(B) (21 U.S.C. 351(a)(2)(B)) (concerning current good manufacturing practice (CGMP) requirements).

Section 502(f)(1) (21 U.S.C. 352(f)(1)) (concerning the labeling of drugs with adequate directions for use). And Section 505 (21 U.S.C. 355) (concerning the approval of drugs under new drug applications or abbreviated new drug applications).

This revised draft guidance proposes policies for FDA's application of certain provisions of section 503A of the FD&C Act to human drug products compounded by State-licensed pharmacies that are not outsourcing facilities and distributed for use within a hospital or health system. First, the revised draft guidance addresses the requirement that compounding be based on the receipt of a valid prescription order for an identified individual patient. Second, it addresses the provision concerning compounded drug products that are essentially copies of a commercially available drug product. This revised draft guidance does not apply to human drug products compounded by outsourcing facilities under section 503B of the FD&C Act, compounded drug products that are not distributed for use within a hospital or health system, or drug products compounded for use in animals.

In the Federal Register of April 18, 2016 (81 FR 22610), FDA announced the availability of a draft guidance for industry entitled, “Hospital and Health System Compounding Under the Federal Food, Drug, and Cosmetic Act” Start Printed Page 55849 (“draft guidance”). The draft guidance proposed new policies for the application of section 503A of the FD&C Act to drug products compounded by licensed pharmacists or physicians in State-licensed hospital or health system pharmacies. In particular, the draft guidance described certain circumstances under which FDA generally would not intend to take action if a hospital or health system pharmacy distributed compounded drug products without first receiving a patient-specific prescription or order. The comment period on the initial draft guidance ended on July 18, 2016.

FDA received approximately 76 comments on the draft guidance. FDA is issuing a revised draft guidance with certain changes made in response to received comments or on its own initiative. For example, the prescription requirement enforcement policy described in the revised draft guidance does not consider whether the drug products are distributed only to healthcare facilities that are located within a 1-mile radius of the compounding pharmacy (“1-mile radius policy”). Instead, the Agency is proposing a two-part, risk-based compliance policy.

In addition, the revised draft guidance proposes new policies for hospital and health system pharmacies regarding the provision in section 503A of the FD&C Act which states that to qualify for the exemptions under section 503A of the FD&C Act, among other conditions, a drug product must be compounded by a licensed pharmacist or physician who does not compound regularly or in inordinate amounts any drug products that are essentially copies of a commercially available drug product. FDA is issuing this revised draft guidance to address stakeholders' feedback, reflect additional Agency consideration of the proposed policies, and enable the public to further review and comment before finalization. This revised draft guidance is being issued consistent with FDA's good guidance practices regulation (21 CFR 10.115). The revised draft guidance, when finalized, will represent the current thinking of FDA on “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act.” It does not establish any rights for any person and is not binding on FDA or the public.

You can use an alternative approach if it satisfies the requirements of the applicable statutes and regulations. II. Paperwork Reduction Act of 1995 Under the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3501-3521), Federal Agencies must obtain approval from the Office of Management and Budget (OMB) for each collection of information they conduct or sponsor.

€œCollection of information” is defined in 44 U.S.C. 3502(3) and 5 CFR 1320.3(c) and includes Agency requests or requirements that members of the public submit reports, keep records, or provide information to a third party. Section 3506(c)(2)(A) of the PRA (44 U.S.C. 3506(c)(2)(A)) requires Federal Agencies to provide a 60-day notice in the Federal Register concerning each proposed collection of information before submitting the collection to OMB for approval.

To comply with this requirement, FDA is publishing notice of the proposed collection of information set forth in this document. We are consolidating the information collection in the revised draft guidance with the information collections and approvals under OMB control number 0910-0800. With respect to the following collection of information, FDA invites comments on these topics. (1) Whether the proposed collection of information is necessary for the proper performance of FDA's functions, including whether the information will have practical utility.

(2) the accuracy of FDA's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used. (3) ways to enhance the quality, utility, and clarity of the information to be collected. And (4) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques, when appropriate, and other forms of information technology. Human Drug Compounding Under Sections 503A and 503B the Federal Food, Drug, and Cosmetic Act OMB Control Number 0910-0800—Revision This notice solicits comments on certain information collections found in the revised draft guidance entitled “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act” (“revised draft guidance”).

This guidance, when finalized, will support implementation of the copies provisions of the 1997 Food and Drug Administration Modernization Act (FDAMA) (Pub. L. 105-115) discussed in section 503A of the FD&C Act, which were maintained by the 2013 Drug Quality and Security Act (DQSA) (Title I of Pub. L.

113-54). For efficiency of Agency operations, we are revising OMB control number 0910-0800 to include information collections relating to the copies policies for hospital and health system pharmacies that are not outsourcing facilities, as proposed in the revised draft guidance document. As proposed in section III.B of the revised draft guidance, among other conditions, we generally would not intend to take action against a hospital or health system pharmacy that is not an outsourcing facility for compounding a drug product regularly or in inordinate amounts that is essentially a copy of a commercially available drug product, if the compounded drug product is administered only to patients within the hospital or health system and the pharmacy obtains from the prescriber a statement that. (1) Specifies a change between the compounded drug product and the commercially available drug product.

(2) indicates that the compounded drug product will be administered only to patients for whom the change produces a significant difference from the commercially available drug product. And (3) describes the intended patient population for the compounded drug product. In addition, the revised draft guidance specifies that the statement would be maintained in the hospital or health system pharmacy to address routine orders for patients for whom the change produces a significant difference, and a statement would be on file for each prescriber that covers each drug product that is compounded. As provided in section III.B of the revised draft guidance, except for the policy proposed above regarding the documentation of a prescriber's determination of significant difference, we propose to apply the policies described in the guidance, “Compounded Drug Products That Are Essentially Copies of a Commercially Available Drug Product Under Section 503A of the Federal Food, Drug, and Cosmetic Act” (“503A copies guidance”) to drug products compounded by hospital and health system pharmacies that are not outsourcing facilities.

As described in section III.B.2 of the 503A copies guidance, and proposed in the revised draft guidance to apply to hospital and health system pharmacies, if a compounder intends to rely on a prescriber determination of significant difference to establish that a compounded drug is not essentially a copy of a commercially available drug product, the compounder should ensure that the determination is documented on the prescription. If a prescription Start Printed Page 55850 does not make clear that the prescriber made the determination required by section 503A(b)(2) of the FD&C Act, or a compounded drug is substituted for the commercially available drug product, the compounder can contact the prescriber and if the prescriber confirms it, make a notation on the prescription that the compounded drug product contains a change that makes a significant difference for the patient. The notations should be as specific as those described in the 503A copies guidance, and the date of the conversation with the prescriber should be included on the prescription. With respect to the determination of significant difference described above, we estimate that, annually, a total of approximately 3,075 hospital or health system pharmacies (table 1) will obtain a prescriber determination of significant difference.

This estimate represents approximately half of the hospitals in the United States, including those that are in health systems. Of these, we estimate that approximately half (1,538) will have hospital or health system pharmacies that will follow the policy in the revised draft guidance, obtaining a statement of significant difference for the intended patient population, and approximately half (1,537) will have hospital or health system pharmacies that will follow the policy with respect to prescriber determination of significant difference in the 503A copies guidance, documenting the notation on the individual patient prescription. This estimate assumes that most pharmacies in smaller hospitals and health systems will follow the policy in the 503A copies guidance because a prescriber determination of significant difference will not be routinely needed and can be most efficiently managed on a patient-by-patient basis. On the other hand, this estimate assumes that most pharmacies in larger hospitals and health systems will follow the policy in the revised draft guidance because the need for a prescriber determination of significant difference is more routinely necessary and, therefore, most efficiently managed with a statement of significant difference that is maintained in the hospital or health system pharmacy to address routine orders for patients for whom the change produces a significant difference.

We estimate that, annually, approximately 1,538 hospital or health system pharmacies following the policy in the revised draft guidance will obtain approximately 30 statements of significant difference for compounded drug products, for a total of approximately 46,140 statements (table 1, row 1). We estimate that the consultation between the hospital or health system pharmacy and the prescriber to obtain the statement of significant difference will require approximately 5 minutes per statement (table 1, row 1). We estimate that, annually, approximately 1,537 hospital or health pharmacies following the policy in the 503A copies guidance will consult a prescriber to determine whether the prescriber has made a determination that the compounded drug product has a change that produces a significant difference for a patient as compared to the comparable commercially available drug and that the compounders will document this determination on approximately 76,850 prescription orders for compounded drug products (table 1, row 2). We estimate that the consultation between the compounder and the prescriber and adding a notation to each prescription that does not already document this determination will take approximately 3 minutes per prescription order (table 1, row 2).

The average burden per consultation and notation for pharmacies following the significant difference policy in the 503A copies guidance, compared to pharmacies following the significant difference policy in the revised draft guidance, is estimated to be less (3 minutes) because the significant difference determination described in the 503A copies policy is specific to one patient, whereas the statement of significant difference in the revised draft guidance describes the intended patient population. In addition, as described in section III.B.3 of the 503A copies guidance, and proposed in the revised draft guidance to apply to hospital and health system pharmacies, if the drug product was compounded because the approved drug product was not commercially available because it was on the FDA drug shortage list, the prescription or a notation on the prescription should note that it was on the drug shortage list and note the date the list was checked. We estimate that a total of approximately 4,613 hospital or health system pharmacies will document this information on approximately 922,600 prescription orders for compounded drug products (table 1, row 3). We estimate that checking FDA's drug shortage list and documenting this information will require approximately 2 minutes per prescription order (table 1, row 3).

With respect to maintaining records of the statement of significant difference proposed in section III.B of the revised draft guidance, we estimate that a total of approximately 1,538 hospital or health system pharmacies will maintain approximately 46,140 statements of significant difference (table 2, row 1). We estimate that maintaining the records will require approximately 2 minutes per record (table 2, row 1). With respect to maintaining records of the significant difference determination, as provided in section III.B.5 of the 503A copies guidance, we estimate that a total of approximately 1,537 hospital or health system pharmacies will maintain approximately 76,850 records (table 2, row 2). We estimate that maintaining records will require approximately 2 minutes per record (table 2, row 2).

Also with respect to maintenance of records, as described in section III.B.5 of the 503A copies guidance, and proposed in the revised draft guidance to apply to hospital and health system pharmacies, compounders under section 503A should maintain records of (1) the frequency in which they have compounded drug products that are essentially copies of commercially available drug products and (2) the number of prescriptions that they have filled for compounded drug products that are essentially copies of commercially available drug products. We estimate that a total of approximately 3,075 hospital or health system pharmacies will maintain approximately 61,500 records of prescriptions that they have filled for compounded drug products that are essentially copies of commercially available drug products (table 2, row 3). We estimate that maintaining the records will require approximately 2 minutes per record (table 2, row 3). We estimate the burden of this collection of information as follows.

Start Printed Page 55851 Table 1—Estimated Annual Third-Party Disclosure Burden 1ActivityNumber of respondentsNumber of disclosures per respondentTotal annual disclosuresAverage burden per disclosureTotal hoursConsultation between the hospital or health system pharmacy and the prescriber to document the statement of significant difference (revised draft guidance)1,5383046,140.08 (5 minutes)3,691Consultation between the hospital or health system pharmacy and prescriber and the notation on the prescription documenting the prescriber's determination of significant difference (503A copies guidance)1,5375076,850.05 (3 minutes)3,843Hospital or health system pharmacy checking FDA's drug shortage list and documenting on the prescription that the drug is in shortage (503A copies guidance)4,613200922,600.03 (2 minutes)27,678Total35,2121  There are no capital costs or operating and maintenance costs associated with this collection of information. Table 2—Estimated Annual Recordkeeping Burden 1ActivityNumber of recordkeepersNumber of records per recordkeeperTotal annual recordsAverage burden per recordkeepingTotal hoursRecords of the statement of significant difference (revised draft guidance)1,5383046,140.03 (2 minutes)1,384Records of documentation of significant difference (503A copies guidance)1,5375076,850.03 (2 minutes)2,306Records of frequency and number of prescriptions filled for compounded drug products that are essentially a copy (503A copies guidance)3,0752061,500.03 (2 minutes)1,845Total5,5351  There are no capital costs or operating and maintenance costs associated with this collection of information. IV. Electronic Access Persons with access to the internet may obtain an electronic version of the revised draft guidance at either https://www.fda.gov/​Drugs/​GuidanceComplianceRegulatoryInformation/​Guidances/​default.htm or https://www.regulations.gov.

Start Signature Dated. October 4, 2021. Lauren K. Roth, Associate Commissioner for Policy.

End Signature End Supplemental Information [FR Doc. 2021-21970 Filed 10-6-21. 8:45 am]BILLING CODE 4164-01-PStart Preamble Centers for Medicare &. Medicaid Services, Health and Human Services (HHS).

Notice. The Centers for Medicare &. Medicaid Services (CMS) is announcing an opportunity for the public to comment on CMS' intention to collect information from the public. Under the Paperwork Reduction Act of 1995 (the PRA), federal agencies are required to publish notice in the Federal Register concerning each proposed collection of information (including each proposed extension or reinstatement of an existing collection of information) and to allow 60 days for public comment on the proposed action.

Interested persons are invited to send comments regarding our burden estimates or any other aspect of this collection of information, including the necessity and utility of the proposed information collection for the proper performance of the agency's functions, the accuracy of the estimated burden, ways to enhance the quality, utility, and clarity of the information to be collected, and the use of automated collection techniques or other forms of information technology to minimize the information collection burden. Comments must be received by October 19, 2021. When commenting, please reference the document identifier or OMB control number. To be assured consideration, comments and recommendations must be submitted in any one of the following ways.

1. Electronically. You may send your comments electronically to http://www.regulations.gov. Follow the instructions for “Comment or Submission” or “More Search Options” to find the information collection document(s) that are accepting comments.

2. By regular mail. You may mail written comments to the following address. CMS, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention.

Document Identifier/OMB Control Number. __, Room C4-26-05, 7500 Security Boulevard, Baltimore, Maryland 21244-1850. To obtain copies of a supporting statement and any related forms for the proposed collection(s) summarized in this notice, you may make your request using one of following. 1.

Access CMS' website address at website address at https://www.cms.gov/​Regulations-and-Guidance/​Legislation/​PaperworkReductionActof1995/​PRA-Listing.html. Start Further Info William N. Parham at (410) 786-4669. End Further Info End Preamble Start Supplemental Information Contents This notice sets out a summary of the use and burden associated with the following information collections.

More detailed information can be found in each collection's supporting statement and associated materials (see ADDRESSES). CMS-10280 Home Health Change of Care Notice CMS-1557 Survey Report Form for Clinical Laboratory Improvement Amendments (CLIA) and Supporting Regulations CMS-3070G-I ICF/IID Survey Report Form and Supporting Regulations Under the PRA (44 U.S.C. 3501-3520), federal agencies must obtain approval from the Office of Management and Budget (OMB) for each collection of information they conduct or sponsor. The term “collection of information” is defined in 44 U.S.C.

3502(3) and 5 CFR 1320.3(c) and includes agency requests or requirements that members of the public submit reports, keep records, or provide information to a third party. Section 3506(c)(2)(A) of the PRA requires federal agencies to publish a 60-day notice in the Federal Register concerning each proposed collection of information, including each proposed extension or reinstatement of an existing collection of information, before submitting the collection to OMB for approval. To comply with this requirement, CMS is publishing this notice. Information Collection 1.

Type of Information Collection Request. Extension of a currently approved collection. Title of the Information Collection. Home Health Change of Care Notice.

Use. The purpose of the Home Health Change of Care Notice (HHCCN) is to notify original Medicare beneficiaries receiving home health care benefits of plan of care changes. Home health agencies (HHAs) are required to provide written notice to Original Medicare beneficiaries under various circumstances involving the reduction or termination of items and/or services consistent with Home Health Agencies Conditions of Participation (COPs). The home health COP requirements are set forth in § 1891[42 U.S.C.

1395bbb] of the Social Security Act (the Act). The implementing regulations under 42 CFR 484.10(c) specify that Medicare patients receiving HHA services have rights. The patient has the right to be informed, in advance about the care to be furnished, and of any changes in the care to be furnished. The HHA must advise the patient in advance of the disciplines that will furnish care, and the frequency of visits proposed to be furnished.

The HHA must advise the patient in advance of any change in the plan of care before the change is made.” Notification is required for covered and non-covered services listed in the plan of care (POC). The beneficiary will use the information provided to decide whether or not to pursue alternative options to continue receiving the care noted on the HHCCN. Form Number. CMS-10280 (OMB control number.

0938-1196). Frequency. Yearly. Affected Public.

Private Sector (Business or other for-profits, Not-for-Profit Institutions). Number of Respondents. 11,157. Total Annual Responses.

12,385,108. Total Annual Hours. 824,848. (For policy questions regarding this collection contact Jennifer McCormick at 410-786-2852.) 2.

Type of Information Collection Request. Extension of a currently approved collection. Title of Information Collection. Survey Report Form for Clinical Laboratory Improvement Amendments (CLIA) and Supporting Regulations.

Use. The form is used to report surveyor findings during a CLIA survey. For each type of survey conducted (i.e., initial certification, recertification, validation, complaint, addition/deletion of specialty/subspecialty, transfusion fatality investigation, or revisit inspections) the Survey Report Form incorporates the requirements specified in the CLIA regulations. Form Number.

CMS-1557 (OMB control number. 0938-0544). Frequency. Biennially.

Affected Public. Private sector (Business or other for-profit and Not-for-profit institutions, State, Local or Tribal Governments and Federal Government). Number of Respondents. 15,975.

Total Start Printed Page 46855Annual Responses. 7,988. Total Annual Hours. 3,994.

(For policy questions regarding this collection contact Kathleen Todd at 410-786-3385). 3. Type of Information Collection Request. Revision of a currently approved collection.

Title of Information Collection. ICF/IID Survey Report Form and Supporting Regulations. Use. The information collected with forms 3070G, CMS-3070H and CMS-3070I is used by the surveyors from the State Survey Agencies (SAs) to determine the level of compliance with the ICF/IID Conditions of Participation (CoPs) necessary to participate in the Medicare/Medicaid program and to report any non-compliance with the ICF/IID CoPs to the Federal government.

These forms summarize the survey team characteristics, facility characteristics, client population, and the special needs of clients. These forms are used in conjunction with the CMS regulation text and additional surveyor aids such as the CMS interpretive guidelines and probes. The CMS-3070G-I forms serves as coding worksheets, designed to facilitate data entry and retrieval into the Automated Survey Processing Environment Suite (ASPEN) in the State and at the CMS regional offices. Form Number.

CMS-3070G-I (OMB control number. 0938-0062). Frequency. Reporting—Yearly.

Affected Public. Business or other for-profits and Not-for-profit institutions. Number of Respondents. 5,758.

Total Annual Responses. 5,758. Total Annual Hours. 17,274.

(For policy questions regarding this collection contact Caroline Gallaher at 410-786-8705.) Start Signature Dated. August 17, 2021. William N. Parham, III Director, Paperwork Reduction Staff, Office of Strategic Operations and Regulatory Affairs.

End Signature End Supplemental Information [FR Doc. 2021-17908 Filed 8-19-21. 8:45 am]BILLING CODE 4120-01-P.

Start Preamble Food and Drug Administration, Read More Here HHS can i get propecia without a prescription. Notice of availability. The Food and Drug Administration (FDA) is announcing the can i get propecia without a prescription availability of a revised draft guidance for industry entitled “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act” (“revised draft guidance”). This revised draft guidance, when finalized, will describe how FDA intends to apply certain provisions of the Federal Food, Drug, and Cosmetic Act (FD&C Act) to human drug products compounded by State-licensed pharmacies that are not outsourcing facilities and distributed for use within a hospital or health system.

First, it addresses the requirement that compounding be based on the receipt of a valid prescription order for an identified individual patient. Second, it addresses the can i get propecia without a prescription provision concerning compounded drug products that are essentially copies of a commercially available drug product. This draft guidance revises the draft guidance issued in 2016 entitled, “Hospital and Health System Compounding Under the Federal Food, Drug, and Cosmetic Act” (“draft guidance”). FDA is revising the draft guidance to address stakeholder feedback and provide further clarification on policies regarding hospital and health system compounding.

This revised draft guidance is not final nor is it in effect at this can i get propecia without a prescription time. Submit either electronic or written comments on the revised draft guidance by December 6, 2021 to ensure that the Agency considers your comment on this revised draft guidance before it begins work on the final version of the guidance. Submit electronic or written comments on the proposed collection of information in the revised draft guidance by December 6, 2021. You may submit comments on can i get propecia without a prescription any guidance at any time as follows.

Electronic Submissions Submit electronic comments in the following way. Start Printed Page 55848 • Federal eRulemaking Portal. Https://www.regulations.gov. Follow the instructions for submitting comments.

Comments submitted electronically, including attachments, to https://www.regulations.gov will be posted to the docket unchanged. Because your comment will be made public, you are solely responsible for ensuring that your comment does not include any confidential information that you or a third party may not wish to be posted, such as medical information, your or anyone else's Social Security number, or confidential business information, such as a manufacturing process. Please note that if you include your name, contact information, or other information that identifies you in the body of your comments, that information will be posted on https://www.regulations.gov. If you want to submit a comment with confidential information that you do not wish to be made available to the public, submit the comment as a written/paper submission and in the manner detailed (see “Written/Paper Submissions” and “Instructions”).

Written/Paper Submissions Submit written/paper submissions as follows. • Mail/Hand Delivery/Courier (for written/paper submissions). Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852.

For written/paper comments submitted to the Dockets Management Staff, FDA will post your comment, as well as any attachments, except for information submitted, marked and identified, as confidential, if submitted as detailed in “Instructions.” Instructions. All submissions received must include the Docket No. FDA-2016-D-0271 for “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act.” Received comments will be placed in the docket and, except for those submitted as “Confidential Submissions,” publicly viewable at https://www.regulations.gov or at the Dockets Management Staff between 9 a.m. And 4 p.m., Monday through Friday, 240-402-7500.

• Confidential Submissions—To submit a comment with confidential information that you do not wish to be made publicly available, submit your comments only as a written/paper submission. You should submit two copies total. One copy will include the information you claim to be confidential with a heading or cover note that states “THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION.” The Agency will review this copy, including the claimed confidential information, in its consideration of comments. The second copy, which will have the claimed confidential information redacted/blacked out, will be available for public viewing and posted on https://www.regulations.gov.

Submit both copies to the Dockets Management Staff. If you do not wish your name and contact information to be made publicly available, you can provide this information on the cover sheet and not in the body of your comments and you must identify this information as “confidential.” Any information marked as “confidential” will not be disclosed except in accordance with 21 CFR 10.20 and other applicable disclosure law. For more information about FDA's posting of comments to public dockets, see 80 FR 56469, September 18, 2015, or access the information at. Https://www.govinfo.gov/​content/​pkg/​FR-2015-09-18/​pdf/​2015-23389.pdf.

Docket. For access to the docket to read background documents or the electronic and written/paper comments received, go to https://www.regulations.gov and insert the docket number, found in brackets in the heading of this document, into the “Search” box and follow the prompts and/or go to the Dockets Management Staff, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852, 240-402-7500. You may submit comments on any guidance at any time (see 21 CFR 10.115(g)(5)).

Submit written requests for single copies of this revised draft guidance to the Division of Drug Information, Center for Drug Evaluation and Research, Food and Drug Administration, 10001 New Hampshire Ave., Hillandale Building, 4th Floor, Silver Spring, MD 20993-0002. Send one self-addressed adhesive label to assist that office in processing your request or include a fax number to which the revised draft guidance may be sent. See the SUPPLEMENTARY INFORMATION section for information on electronic access to the revised draft guidance. Start Further Info With regard to the revised draft guidance.

Tracy Rupp, Center for Drug Evaluation and Research, Food and Drug Administration, 10903 New Hampshire Ave., Bldg. 51, Silver Spring, MD 20993, 301-796-3100. With regard to the proposed collection of information. Domini Bean, Office of Operations, Food and Drug Administration, Three White Flint North, 10A-12M, 11601 Landsdown St., North Bethesda, MD 20852, 301-796-5733, PRAStaff@fda.hhs.gov.

End Further Info End Preamble Start Supplemental Information I. Background FDA is announcing the availability of a revised draft guidance for industry entitled “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act.” Pharmacies located within a hospital, or standalone pharmacies that are part of a health system, frequently provide compounded drug products for administration within the hospital or health system. Some of these compounders seek to compound under section 503A of the FD&C Act (21 U.S.C. 353a) and others have registered with FDA as outsourcing facilities and are subject to section 503B of the FD&C Act (21 U.S.C.

353b). Section 503A of the FD&C Act describes the conditions that must be satisfied for human drug products compounded by a licensed pharmacist in a State-licensed pharmacy or Federal facility, or by a licensed physician, to be exempt from the following three sections of the FD&C Act. Section 501(a)(2)(B) (21 U.S.C. 351(a)(2)(B)) (concerning current good manufacturing practice (CGMP) requirements).

Section 502(f)(1) (21 U.S.C. 352(f)(1)) (concerning the labeling of drugs with adequate directions for use). And Section 505 (21 U.S.C. 355) (concerning the approval of drugs under new drug applications or abbreviated new drug applications).

This revised draft guidance proposes policies for FDA's application of certain provisions of section 503A of the FD&C Act to human drug products compounded by State-licensed pharmacies that are not outsourcing facilities and distributed for use within a hospital or health system. First, the revised draft guidance addresses the requirement that compounding be based on the receipt of a valid prescription order for an identified individual patient. Second, it addresses the provision concerning compounded drug products that are essentially copies of a commercially available drug product. This revised draft guidance does not apply to human drug products compounded by outsourcing facilities under section 503B of the FD&C Act, compounded drug products that are not distributed for use within a hospital or health system, or drug products compounded for use in animals.

In the Federal Register of April 18, 2016 (81 FR 22610), FDA announced the availability of a draft guidance for industry entitled, “Hospital and Health System Compounding Under the Federal Food, Drug, and Cosmetic Act” Start Printed Page 55849 (“draft guidance”). The draft guidance proposed new policies for the application of section 503A of the FD&C Act to drug products compounded by licensed pharmacists or physicians in State-licensed hospital or health system pharmacies. In particular, the draft guidance described certain circumstances under which FDA generally would not intend to take action if a hospital or health system pharmacy distributed compounded drug products without first receiving a patient-specific prescription or order. The comment period on the initial draft guidance ended on July 18, 2016.

FDA received approximately 76 comments on the draft guidance. FDA is issuing a revised draft guidance with certain changes made in response to received comments or on its own initiative. For example, the prescription requirement enforcement policy described in the revised draft guidance does not consider whether the drug products are distributed only to healthcare facilities that are located within a 1-mile radius of the compounding pharmacy (“1-mile radius policy”). Instead, the Agency is proposing a two-part, risk-based compliance policy.

In addition, the revised draft guidance proposes new policies for hospital and health system pharmacies regarding the provision in section 503A of the FD&C Act which states that to qualify for the exemptions under section 503A of the FD&C Act, among other conditions, a drug product must be compounded by a licensed pharmacist or physician who does not compound regularly or in inordinate amounts any drug products that are essentially copies of a commercially available drug product. FDA is issuing this revised draft guidance to address stakeholders' feedback, reflect additional Agency consideration of the proposed policies, and enable the public to further review and comment before finalization. This revised draft guidance is being issued consistent with FDA's good guidance practices regulation (21 CFR 10.115). The revised draft guidance, when finalized, will represent the current thinking of FDA on “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act.” It does not establish any rights for any person and is not binding on FDA or the public.

You can use an alternative approach if it satisfies the requirements of the applicable statutes and regulations. II. Paperwork Reduction Act of 1995 Under the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3501-3521), Federal Agencies must obtain approval from the Office of Management and Budget (OMB) for each collection of information they conduct or sponsor.

€œCollection of information” is defined in 44 U.S.C. 3502(3) and 5 CFR 1320.3(c) and includes Agency requests or requirements that members of the public submit reports, keep records, or provide information to a third party. Section 3506(c)(2)(A) of the PRA (44 U.S.C. 3506(c)(2)(A)) requires Federal Agencies to provide a 60-day notice in the Federal Register concerning each proposed collection of information before submitting the collection to OMB for approval.

To comply with this requirement, FDA is publishing notice of the proposed collection of information set forth in this document. We are consolidating the information collection in the revised draft guidance with the information collections and approvals under OMB control number 0910-0800. With respect to the following collection of information, FDA invites comments on these topics. (1) Whether the proposed collection of information is necessary for the proper performance of FDA's functions, including whether the information will have practical utility.

(2) the accuracy of FDA's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used. (3) ways to enhance the quality, utility, and clarity of the information to be collected. And (4) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques, when appropriate, and other forms of information technology. Human Drug Compounding Under Sections 503A and 503B the Federal Food, Drug, and Cosmetic Act OMB Control Number 0910-0800—Revision This notice solicits comments on certain information collections found in the revised draft guidance entitled “Hospital and Health System Compounding Under Section 503A of the Federal Food, Drug, and Cosmetic Act” (“revised draft guidance”).

This guidance, when finalized, will support implementation of the copies provisions of the 1997 Food and Drug Administration Modernization Act (FDAMA) (Pub. L. 105-115) discussed in section 503A of the FD&C Act, which were maintained by the 2013 Drug Quality and Security Act (DQSA) (Title I of Pub. L.

113-54). For efficiency of Agency operations, we are revising OMB control number 0910-0800 to include information collections relating to the copies policies for hospital and health system pharmacies that are not outsourcing facilities, as proposed in the revised draft guidance document. As proposed in section III.B of the revised draft guidance, among other conditions, we generally would not intend to take action against a hospital or health system pharmacy that is not an outsourcing facility for compounding a drug product regularly or in inordinate amounts that is essentially a copy of a commercially available drug product, if the compounded drug product is administered only to patients within the hospital or health system and the pharmacy obtains from the prescriber a statement that. (1) Specifies a change between the compounded drug product and the commercially available drug product.

(2) indicates that the compounded drug product will be administered only to patients for whom the change produces a significant difference from the commercially available drug product. And (3) describes the intended patient population for the compounded drug product. In addition, the revised draft guidance specifies that the statement would be maintained in the hospital or health system pharmacy to address routine orders for patients for whom the change produces a significant difference, and a statement would be on file for each prescriber that covers each drug product that is compounded. As provided in section III.B of the revised draft guidance, except for the policy proposed above regarding the documentation of a prescriber's determination of significant difference, we propose to apply the policies described in the guidance, “Compounded Drug Products That Are Essentially Copies of a Commercially Available Drug Product Under Section 503A of the Federal Food, Drug, and Cosmetic Act” (“503A copies guidance”) to drug products compounded by hospital and health system pharmacies that are not outsourcing facilities.

As described in section III.B.2 of the 503A copies guidance, and proposed in the revised draft guidance to apply to hospital and health system pharmacies, if a compounder intends to rely on a prescriber determination of significant difference to establish that a compounded drug is not essentially a copy of a commercially available drug product, the compounder should ensure that the determination is documented on the prescription. If a prescription Start Printed Page 55850 does not make clear that the prescriber made the determination required by section 503A(b)(2) of the FD&C Act, or a compounded drug is substituted for the commercially available drug product, the compounder can contact the prescriber and if the prescriber confirms it, make a notation on the prescription that the compounded drug product contains a change that makes a significant difference for the patient. The notations should be as specific as those described in the 503A copies guidance, and the date of the conversation with the prescriber should be included on the prescription. With respect to the determination of significant difference described above, we estimate that, annually, a total of approximately 3,075 hospital or health system pharmacies (table 1) will obtain a prescriber determination of significant difference.

This estimate represents approximately half of the hospitals in the United States, including those that are in health systems. Of these, we estimate that approximately half (1,538) will have hospital or health system pharmacies that will follow the policy in the revised draft guidance, obtaining a statement of significant difference for the intended patient population, and approximately half (1,537) will have hospital or health system pharmacies that will follow the policy with respect to prescriber determination of significant difference in the 503A copies guidance, documenting the notation on the individual patient prescription. This estimate assumes that most pharmacies in smaller hospitals and health systems will follow the policy in the 503A copies guidance because a prescriber determination of significant difference will not be routinely needed and can be most efficiently managed on a patient-by-patient basis. On the other hand, this estimate assumes that most pharmacies in larger hospitals and health systems will follow the policy in the revised draft guidance because the need for a prescriber determination of significant difference is more routinely necessary and, therefore, most efficiently managed with a statement of significant difference that is maintained in the hospital or health system pharmacy to address routine orders for patients for whom the change produces a significant difference.

We estimate that, annually, approximately 1,538 hospital or health system pharmacies following the policy in the revised draft guidance will obtain approximately 30 statements of significant difference for compounded drug products, for a total of approximately 46,140 statements (table 1, row 1). We estimate that the consultation between the hospital or health system pharmacy and the prescriber to obtain the statement of significant difference will require approximately 5 minutes per statement (table 1, row 1). We estimate that, annually, approximately 1,537 hospital or health pharmacies following the policy in the 503A copies guidance will consult a prescriber to determine whether the prescriber has made a determination that the compounded drug product has a change that produces a significant difference for a patient as compared to the comparable commercially available drug and that the compounders will document this determination on approximately 76,850 prescription orders for compounded drug products (table 1, row 2). We estimate that the consultation between the compounder and the prescriber and adding a notation to each prescription that does not already document this determination will take approximately 3 minutes per prescription order (table 1, row 2).

The average burden per consultation and notation for pharmacies following the significant difference policy in the 503A copies guidance, compared to pharmacies following the significant difference policy in the revised draft guidance, is estimated to be less (3 minutes) because the significant difference determination described in the 503A copies policy is specific to one patient, whereas the statement of significant difference in the revised draft guidance describes the intended patient population. In addition, as described in section III.B.3 of the 503A copies guidance, and proposed in the revised draft guidance to apply to hospital and health system pharmacies, if the drug product was compounded because the approved drug product was not commercially available because it was on the FDA drug shortage list, the prescription or a notation on the prescription should note that it was on the drug shortage list and note the date the list was checked. We estimate that a total of approximately 4,613 hospital or health system pharmacies will document this information on approximately 922,600 prescription orders for compounded drug products (table 1, row 3). We estimate that checking FDA's drug shortage list and documenting this information will require approximately 2 minutes per prescription order (table 1, row 3).

With respect to maintaining records of the statement of significant difference proposed in section III.B of the revised draft guidance, we estimate that a total of approximately 1,538 hospital or health system pharmacies will maintain approximately 46,140 statements of significant difference (table 2, row 1). We estimate that maintaining the records will require approximately 2 minutes per record (table 2, row 1). With respect to maintaining records of the significant difference determination, as provided in section III.B.5 of the 503A copies guidance, we estimate that a total of approximately 1,537 hospital or health system pharmacies will maintain approximately 76,850 records (table 2, row 2). We estimate that maintaining records will require approximately 2 minutes per record (table 2, row 2).

Also with respect to maintenance of records, as described in section III.B.5 of the 503A copies guidance, and proposed in the revised draft guidance to apply to hospital and health system pharmacies, compounders under section 503A should maintain records of (1) the frequency in which they have compounded drug products that are essentially copies of commercially available drug products and (2) the number of prescriptions that they have filled for compounded drug products that are essentially copies of commercially available drug products. We estimate that a total of approximately 3,075 hospital or health system pharmacies will maintain approximately 61,500 records of prescriptions that they have filled for compounded drug products that are essentially copies of commercially available drug products (table 2, row 3). We estimate that maintaining the records will require approximately 2 minutes per record (table 2, row 3). We estimate the burden of this collection of information as follows.

Start Printed Page 55851 Table 1—Estimated Annual Third-Party Disclosure Burden 1ActivityNumber of respondentsNumber of disclosures per respondentTotal annual disclosuresAverage burden per disclosureTotal hoursConsultation between the hospital or health system pharmacy and the prescriber to document the statement of significant difference (revised draft guidance)1,5383046,140.08 (5 minutes)3,691Consultation between the hospital or health system pharmacy and prescriber and the notation on the prescription documenting the prescriber's determination of significant difference (503A copies guidance)1,5375076,850.05 (3 minutes)3,843Hospital or health system pharmacy checking FDA's drug shortage list and documenting on the prescription that the drug is in shortage (503A copies guidance)4,613200922,600.03 (2 minutes)27,678Total35,2121  There are no capital costs or operating and maintenance costs associated with this collection of information. Table 2—Estimated Annual Recordkeeping Burden 1ActivityNumber of recordkeepersNumber of records per recordkeeperTotal annual recordsAverage burden per recordkeepingTotal hoursRecords of the statement of significant difference (revised draft guidance)1,5383046,140.03 (2 minutes)1,384Records of documentation of significant difference (503A copies guidance)1,5375076,850.03 (2 minutes)2,306Records of frequency and number of prescriptions filled for compounded drug products that are essentially a copy (503A copies guidance)3,0752061,500.03 (2 minutes)1,845Total5,5351  There are no capital costs or operating and maintenance costs associated with this collection of information. IV. Electronic Access Persons with access to the internet may obtain an electronic version of the revised draft guidance at either https://www.fda.gov/​Drugs/​GuidanceComplianceRegulatoryInformation/​Guidances/​default.htm or https://www.regulations.gov.

Start Signature Dated. October 4, 2021. Lauren K. Roth, Associate Commissioner for Policy.

End Signature End Supplemental Information [FR Doc. 2021-21970 Filed 10-6-21. 8:45 am]BILLING CODE 4164-01-PStart Preamble Centers for Medicare &. Medicaid Services, Health and Human Services (HHS).

Notice. The Centers for Medicare &. Medicaid Services (CMS) is announcing an opportunity for the public to comment on CMS' intention to collect information from the public. Under the Paperwork Reduction Act of 1995 (the PRA), federal agencies are required to publish notice in the Federal Register concerning each proposed collection of information (including each proposed extension or reinstatement of an existing collection of information) and to allow 60 days for public comment on the proposed action.

Interested persons are invited to send comments regarding our burden estimates or any other aspect of this collection of information, including the necessity and utility of the proposed information collection for the proper performance of the agency's functions, the accuracy of the estimated burden, ways to enhance the quality, utility, and clarity of the information to be collected, and the use of automated collection techniques or other forms of information technology to minimize the information collection burden. Comments must be received by October 19, 2021. When commenting, please reference the document identifier or OMB control number. To be assured consideration, comments and recommendations must be submitted in any one of the following ways.

1. Electronically. You may send your comments electronically to http://www.regulations.gov. Follow the instructions for “Comment or Submission” or “More Search Options” to find the information collection document(s) that are accepting comments.

2. By regular mail. You may mail written comments to the following address. CMS, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention.

Document Identifier/OMB Control Number. __, Room C4-26-05, 7500 Security Boulevard, Baltimore, Maryland 21244-1850. To obtain copies of a supporting statement and any related forms for the proposed collection(s) summarized in this notice, you may make your request using one of following. 1.

Access CMS' website address at website address at https://www.cms.gov/​Regulations-and-Guidance/​Legislation/​PaperworkReductionActof1995/​PRA-Listing.html. Start Further Info William N. Parham at (410) 786-4669. End Further Info End Preamble Start Supplemental Information Contents This notice sets out a summary of the use and burden associated with the following information collections.

More detailed information can be found in each collection's supporting statement and associated materials (see ADDRESSES). CMS-10280 Home Health Change of Care Notice CMS-1557 Survey Report Form for Clinical Laboratory Improvement Amendments (CLIA) and Supporting Regulations CMS-3070G-I ICF/IID Survey Report Form and Supporting Regulations Under the PRA (44 U.S.C. 3501-3520), federal agencies must obtain approval from the Office of Management and Budget (OMB) for each collection of information they conduct or sponsor. The term “collection of information” is defined in 44 U.S.C.

3502(3) and 5 CFR 1320.3(c) and includes agency requests or requirements that members of the public submit reports, keep records, or provide information to a third party. Section 3506(c)(2)(A) of the PRA requires federal agencies to publish a 60-day notice in the Federal Register concerning each proposed collection of information, including each proposed extension or reinstatement of an existing collection of information, before submitting the collection to OMB for approval. To comply with this requirement, CMS is publishing this notice. Information Collection 1.

Type of Information Collection Request. Extension of a currently approved collection. Title of the Information Collection. Home Health Change of Care Notice.

Use. The purpose of the Home Health Change of Care Notice (HHCCN) is to notify original Medicare beneficiaries receiving home health care benefits of plan of care changes. Home health agencies (HHAs) are required to provide written notice to Original Medicare beneficiaries under various circumstances involving the reduction or termination of items and/or services consistent with Home Health Agencies Conditions of Participation (COPs). The home health COP requirements are set forth in § 1891[42 U.S.C.

1395bbb] of the Social Security Act (the Act). The implementing regulations under 42 CFR 484.10(c) specify that Medicare patients receiving HHA services have rights. The patient has the right to be informed, in advance about the care to be furnished, and of any changes in the care to be furnished. The HHA must advise the patient in advance of the disciplines that will furnish care, and the frequency of visits proposed to be furnished.

The HHA must advise the patient in advance of any change in the plan of care before the change is made.” Notification is required for covered and non-covered services listed in the plan of care (POC). The beneficiary will use the information provided to decide whether or not to pursue alternative options to continue receiving the care noted on the HHCCN. Form Number. CMS-10280 (OMB control number.

0938-1196). Frequency. Yearly. Affected Public.

Private Sector (Business or other for-profits, Not-for-Profit Institutions). Number of Respondents. 11,157. Total Annual Responses.

12,385,108. Total Annual Hours. 824,848. (For policy questions regarding this collection contact Jennifer McCormick at 410-786-2852.) 2.

Type of Information Collection Request. Extension of a currently approved collection. Title of Information Collection. Survey Report Form for Clinical Laboratory Improvement Amendments (CLIA) and Supporting Regulations.

Use. The form is used to report surveyor findings during a CLIA survey. For each type of survey conducted (i.e., initial certification, recertification, validation, complaint, addition/deletion of specialty/subspecialty, transfusion fatality investigation, or revisit inspections) the Survey Report Form incorporates the requirements specified in the CLIA regulations. Form Number.

CMS-1557 (OMB control number. 0938-0544). Frequency. Biennially.

Affected Public. Private sector (Business or other for-profit and Not-for-profit institutions, State, Local or Tribal Governments and Federal Government). Number of Respondents. 15,975.

Total Start Printed Page 46855Annual Responses. 7,988. Total Annual Hours. 3,994.

(For policy questions regarding this collection contact Kathleen Todd at 410-786-3385). 3. Type of Information Collection Request. Revision of a currently approved collection.

Title of Information Collection. ICF/IID Survey Report Form and Supporting Regulations. Use. The information collected with forms 3070G, CMS-3070H and CMS-3070I is used by the surveyors from the State Survey Agencies (SAs) to determine the level of compliance with the ICF/IID Conditions of Participation (CoPs) necessary to participate in the Medicare/Medicaid program and to report any non-compliance with the ICF/IID CoPs to the Federal government.

These forms summarize the survey team characteristics, facility characteristics, client population, and the special needs of clients. These forms are used in conjunction with the CMS regulation text and additional surveyor aids such as the CMS interpretive guidelines and probes. The CMS-3070G-I forms serves as coding worksheets, designed to facilitate data entry and retrieval into the Automated Survey Processing Environment Suite (ASPEN) in the State and at the CMS regional offices. Form Number.

CMS-3070G-I (OMB control number. 0938-0062). Frequency. Reporting—Yearly.

Affected Public. Business or other for-profits and Not-for-profit institutions. Number of Respondents. 5,758.

Total Annual Responses. 5,758. Total Annual Hours. 17,274.

(For policy questions regarding this collection contact Caroline Gallaher at 410-786-8705.) Start Signature Dated. August 17, 2021. William N. Parham, III Director, Paperwork Reduction Staff, Office of Strategic Operations and Regulatory Affairs.

End Signature End Supplemental Information [FR Doc. 2021-17908 Filed 8-19-21. 8:45 am]BILLING CODE 4120-01-P.

Propecia vs finasteride generic

In this http://luxurypropertiesofmarcoisland.com/2011/07/marco-island-lifestyle/ issue of propecia vs finasteride generic BMJ Quality and Safety, Jorro-Barón and colleagues1 report the findings of a stepped-wedge cluster randomised trial (SW-CRT) to evaluate the implementation of the I-PASS handover system among six paediatric intensive care units (PICUs) at five Argentinian hospitals between July 2018 and May 2019. According to the authors, prior to the intervention there were complaints that handovers were ‘…lengthy, disorganized, …participants experienced problems with interruptions, distractions, and … propecia vs finasteride generic senior professionals had problems accepting dissent’.Adverse events were assessed by two independent reviewers using the Global Assessment of Pediatric Patient Safety instrument. Study results demonstrated significantly improved handover compliance in the intervention group, validating Kirkpatrick Level 3 (behavioural change)2 effectiveness of the training initiative.

Notably, however, on the primary outcome there propecia vs finasteride generic were no differences between control and intervention groups regarding preventable adverse events per 1000 days of hospitalisation (control 60.4 (37.5–97.4) vs intervention 60.4 (33.2–109.9), p=0.998, risk ratio. 1.0 (0.74–1.34)). Regarding balancing measures, there was no observed difference in the ‘full-shift’ propecia vs finasteride generic handover duration (control 35.7 min (29.6–41.8).

Intervention 34.7 min (26.5–42.1), p=0.490), although more time was spent on individual patient handovers in the intervention period (7.29 min (5.77–8.81). Control 5.96 propecia vs finasteride generic min (4.69–7.23). P=0.001).

From the provider perspective, preintervention and postintervention Agency for Healthcare Research and Quality (AHRQ) safety culture surveys did not show significant differences in their responses to communication-focused questions before and after the intervention.Thus, consistent with all previous studies, I-PASS was implemented successfully and handover quality improved. However, is the lack of association of I-PASS implementation with clinical outcomes and adverse events in this study a concern?. To answer this question, it is necessary to review the origins of I-PASS more than a decade ago and its continually expanding evidence base.Healthcare has a handover problemHandovers are among the most vulnerable reoccurring processes in healthcare.

In the AHRQ safety culture survey,3 the handovers and transitions of care domain is consistently among the lowest scoring, and handover and communication issues are among the most common cause of Joint Commission Sentinel Events and the subject of Joint Commission Sentinel Event Alert Issue 58.4 A study by CRICO Strategies found that communication issues were a factor in 30% of 23 658 malpractice claims filed from 2009 to 2013, accounting for $1.7 billion in incurred losses.5 The importance of handovers and care transitions for trainees is specifically discussed in a Clinical Learning Environment Review Issue Brief published by the Accreditation Council for Graduate Medical Education (ACGME),6 and Section VI.E.3 (Transitions of Care) of the ACGME Common Program Requirements (Residency) addresses the requirement for residents to be taught and to use structured handovers.7Both the numbers of handovers and handover-related problems have increased in contemporary practice because of greater patient complexity and the expanding number and types of providers involved in a typical patient’s care. Further, in teaching institutions, resident work-hour restrictions have resulted in the need for complex coverage schemes. Off-hours care is often provided by ‘cross-covering’, ‘float’ or ‘moonlighting’ practitioners who are responsible for numerous unfamiliar patients during their shifts, thus imposing an even greater need for effective handovers.

The net effect of all these changes may be inconsistent, fragmented care resulting from suboptimal handovers from one provider, service or hospital to another, with resulting medical errors (often of omission) and adverse events.Structured, standardised handoversThese serious vulnerabilities have led to pleas for more consistent, structured and standardised handovers.8–11 In addition to their use in routine shift-to-shift provider sign-off, these may be of particular value in the high-risk transfers of critically ill patients, such as from operating rooms to postoperative care units and ICUs12–16. Admissions to a surgery unit17. Management of trauma patients18–20.

ICU to general ward transfers21 22. Night and weekend coverage of large services, many of whose patients are unfamiliar to the physician receiving the handover23–28. And end-of-rotation resident transitions.29–31Given these considerations, standardised handovers, often involving mnemonic devices, have been widely advocated and studied in the past several decades, though many lack rigorous evaluation and few if any showed demonstrable associations with outcomes.32 33 Further, although some individual hospitals, units and services have implemented their own idiosyncratic handover systems, this does not solve the issue of handover inconsistency between different care delivery sites.

A basic, common framework that could be customised to individual use cases would clearly be preferable.The I-PASS systemResponding to these concerns, the I-PASS Study Group was initiated in 2009 and the I-PASS Institute in 2016. Although numerous other systems are available, since its pilot studies a decade ago,34 35 I-PASS has emerged as the dominant system in healthcare for structured, standardised handovers. This system is specifically designed for healthcare applications.

It is based on adult educational principles and simple to use. It has been extensively validated in the peer-reviewed literature encompassing studies at multiple institutions in the USA and internationally34–40. And extensive training materials are available to assist programmes in implementation.39 41–45 Ideally, this system is implemented hospital-wide, which addresses the issue of cross-unit and cross-service transfers.I-PASS includes five major elements regarded as important for every handover—illness severity, patient summary, action list, situation awareness/contingency planning and synthesis by receiver.

The first three of these elements are often included in non-structured handovers, although not necessarily in a specific sequence or format. The last two I-PASS elements—situational awareness/contingency planning and synthesis—have not historically been included in typical handover practice. The former assures that any anticipated problems are conveyed from the handover giver to the incoming provider and that appropriate responses to these issues are discussed.

Synthesis is closed-loop communication, with brief read-back of the handover information by the receiver to assure their accurate comprehension, followed by an opportunity for questions and discussion. This read-back of mission-critical communications is standard operating practice in other high-reliability settings such as aviation, the military and nuclear power. It is essential to establishing a shared mental model of the current state and any potential concerns.

However, other than in I-PASS, it is quite uncommon in healthcare, with the potential exception of confirming verbal or telephonic orders.I-PASS validationIn an initial study of I-PASS handover implementation by residents on two general inpatient paediatric units at Boston Children’s Hospital,34 written handovers were more comprehensive and had fewer omissions of key data, and mean time spent on verbal handover sessions did not change significantly (32.3 min vs 33.2 min). Medical errors and adverse events were ascertained prospectively by research nurse reviewers and independent physician investigators. Following I-PASS implementation, preventable adverse events decreased from 3.3 (95% CI 1.7 to 4.8) to 1.5 (95% CI 0.51 to 2.4) per 100 admissions (p=0.04), and medical error rates decreased significantly from 33.8 per 100 admissions (95% CI 27.3 to 40.3) to 18.3 per 100 admissions (95% CI 14.7 to 21.9.

P<0.001). A commentary by Horwitz46 noted that this was ‘…by far the most comprehensive study of the direct effects of handoff interventions on outcomes within the context of existing work-hour regulations and is the first to demonstrate an associated significant decrease in medical errors on a large scale’, while also noting limitations including its uncontrolled, ‘before and after’ design, confounding by secular changes, Hawthorne effects and inability to blind the nurses collecting adverse event data.The more expansive, landmark I-PASS study was conducted by Starmer and colleagues37 among nine paediatric hospitals and 10 740 patient admissions between January 2011 and May 2013. Handover quality was evaluated, and medical errors and adverse events were ascertained by active surveillance, including on-site nurse review of medical records, orders, formal incident reports, nursing reports and daily medical error reports from residents.

Independent physician investigators classified occurrences as adverse events, near misses or exclusions, and they subclassified adverse events as preventable or non-preventable. Results revealed a 23% reduction in medical errors from the preintervention to the postintervention period (24.5 vs 18.8 per 100 admissions, p<0.001) and a 30% reduction in preventable adverse events (4.7 vs 3.3 events per 100 admissions, p<0.001). Inclusion of prespecified elements in written and verbal handovers increased significantly, and there was no significant change in handover time per patient (2.4 vs 2.5 min.

P=0.55).Subsequent investigations in other institutions have replicated many of the findings of the original I-PASS studies, with higher postintervention inclusion rates of critical handover elements. Fewer mistakes or omissions. Greater provider satisfaction with handover organisation and information conveyed.

Unchanged or shorter handoff times. And decreased handover interruptions (probably reflecting greater attention to the importance of the handover process).36 40 47–50 In a mentored implementation study conducted in 2015–2016 among 16 hospitals (five community hospitals, 11 academic centres and multiple specialties), handover quality improved, and there was a provider-reported 27% reduction in adverse events.38 Among nurses at Boston Children’s Hospital, I-PASS implementation was associated with significant decreases in handover-related care failures.40In recognition of its achievements in improving healthcare quality, the I-PASS Study Group was awarded the 2016 John M Eisenberg Award for Patient Safety and Quality by the National Quality Forum and the Joint Commission.The challenge of linking handovers to clinical outcomes and eventsAlthough investigations from many centres, including the report of Jorro-Barrón and colleagues,1 have now confirmed that I-PASS can be readily assimilated and used by clinicians, most of these have either not rigorously assessed adverse events, medical errors and other clinical outcomes (Kirkpatrick Level 4 evaluation) or have failed to demonstrate significant postintervention improvements in these clinical outcomes. Why is this, and should current or potential I-PASS users be concerned?.

With regard to the first question, there are practical considerations that complicate the rigorous study of clinical outcome improvements associated with I-PASS (or any other handover system). Notwithstanding the importance of effective communications, these are only one of many provider processes and hospital systems, not to mention the overall hospital quality and safety culture, that impact a patient’s clinical outcome. In most hospitals, a diverse portfolio of quality and safety improvement initiatives are always being conducted.

Disentangling and isolating the effects of any one specific intervention, such as I-PASS handovers, is challenging if not impossible. At a minimum, it requires real-time, prospective monitoring by trained nurse or physician reviewers as in the original I-PASS studies, a research design which realistically is unlikely to be reproduced. Ideally, the study design would also include blinding of the study period (control or intervention) and blinding of observers, the former of which is virtually impossible for this type of intervention.Further, if other provider processes and hospital systems are functioning at a high level, they may partially offset the impact of suboptimal communications and make it even more challenging to demonstrate significant improvements.

The current study of Jorro-Barón and colleagues,1 which uses PICUs as the unit of analysis, illustrates this concept. PICUs are typically among the most compulsive, detail-oriented units in any hospital, even if they may have nominally ‘non-standardized’ handovers.Study design. The SW-CRTIn an attempt to address the limitations of some previous studies, Parent and colleagues51 studied eight medical and surgical ICUs across two academic tertiary teaching hospitals using an SW-CRT design.

Clinician self-assessment of having been inadequately prepared for their shift because of a poor-quality handoff decreased from 35 of 343 handoffs (10.2%) in the control arm to 53 of 740 handoffs (7.2%) postintervention (OR 0.19. 95% CI 0.03 to 0.74. P=0.03).

€˜Last-minute’, early morning order writing decreased, and handover duration increased but not significantly (+5.5 min. 95% CI 0.34 to 9.39. P=0.30).

As in the current study of Jorro-Barón and colleagues,1 who also employed visit an SW-CRT, there were no associated changes in clinical outcomes such as ICU length of stay, duration of mechanical ventilation or necessity for reintubation. The authors comment that given high baseline quality of care in these ICUs, it was not surprising that there were no changes in outcomes.An SW-CRT is generally considered a rigorous study design as it includes cluster randomisation. However, though novel and increasingly popular, this approach is complex and may sometimes add confusion rather than clarity.52–57 Its major appeal is that all clusters will at some point, in a random and sequential fashion, transition from control to intervention condition.

For an intervention that is perceived by participants as having more potential for good than harm, this may enhance cluster recruitment. It may also make it possible to conduct a randomised study in scenarios where pragmatic considerations, such as the inability to conduct interventions simultaneously across numerous clusters, may make a parallel randomised study (or any study) infeasible.However, as acknowledged even by its proponents, the added practical and statistical complexity of SW-CRTs often makes them more challenging to properly implement, and compared with traditional parallel cluster randomised trials they may be more prone to biases.53–57 A Consolidated Standards of Reporting Trials extension has been specifically developed in response to these concerns.55 Unique design and analytical considerations include the number of clusters, sequences and periods. Clusters per sequence.

And cluster-period sizes.55 56 Concerns include recruitment and selection biases. Proper accounting for secular trends in outcomes (ie, because of the sequential rather than simultaneous nature of the SW-CRT design, observations from the intervention condition occur on average at a later calendar time, so that the intervention effect may be confounded by an underlying time trend). Accounting for repeated measures on participants and clusters in sample size calculations and analyses (ie, data are not independent).

Possible time-varying treatment effects. And the potential for within-cluster contamination of observations obtained under the control or intervention condition.52–56Regarding contamination, a secular trend may be responsible if, for example, institutional activities focused on improving patient outcomes include a general emphasis on communications. There might also be more direct contamination of the intervention among clusters waiting to be crossed over, as described in the context of the Matching Michigan programme.58 Participating in a trial and awareness of being observed may change the behaviour of participants.

For example, in the handover intervention of Jorro-Barón and colleagues,1 some providers in a control condition cluster may, because they are aware of the interest in handovers, begin to implement more standardised practices before the formal shift to the intervention condition. This potentially dilutes any subsequent impact of the intervention by virtue of what could be considered either a Hawthorne effect or a local secular trend, in either case leading to generally better handovers in the preintervention period. Some SW-CRTs include a transition period without any observations to allow for sufficient time to implement the intervention,53 59 thereby creating more contrast.

Finally, because of sometimes prolonged PICU length of stay and regularly scheduled resident rotations on and off a unit or service, some patients and providers might overlap the transition from control to intervention state and contribute observations to both, while others will be limited to one or the other. This possibility is not clearly defined by the authors of the current study, but seems unlikely to have had a major statistical effect.Do we need more evidence?. From an implementation science perspective, handovers are a deeply flawed healthcare process with the demonstrated potential to harm patients.

A new tool—I-PASS—has been developed which can be easily and economically taught and subsequently applied by virtually any provider, and many resources are available to assist in implementation.45 It has few, if any, unintended negative consequences to patients or providers and has been associated in at least two extensive and well-conducted (although non-randomised) trials with dramatic reductions in medical errors and adverse events. Notably, these were conducted at a time when there was much less emphasis on and awareness of handover systems, including I-PASS. Thus, there was much greater separation between control and intervention states than would be possible today.Returning to the question posed at the beginning of this commentary, is the inability to demonstrate a favourable impact on clinical outcomes in studies other than those of the developers34 35 a reason to question the value of I-PASS?.

For the reasons discussed above, I think not. In his classic 2008 article,60 ‘The Science of Improvement’, Dr Don Berwick recounts the transformational development of sophisticated statistical analyses in healthcare, of which the randomised clinical trial is the paradigm. While in many instances randomised controlled trials have been invaluable in scientifically affirming or rejecting the utility of specific treatments or interventions, their limitations are more obvious in interventions involving complex social and behavioural change.

Berwick illustrates this challenge with the example of hospital rapid response teams, whose benefit was challenged by the results of a large cluster randomised trial. His comments regarding that conflict are equally applicable to the current challenge of demonstrating the impact of standardised handovers on clinical outcomes:These critics refused to accept as evidence the large, positive, accumulating experience of many hospitals that were adapting rapid response for their own use, such as children’s hospitals. How can accumulating local reports of effectiveness of improvement interventions, such as rapid response systems, be reconciled with contrary findings from formal trials with their own varying imperfections?.

The reasons for this apparent gap between science and experience lie deep in epistemology. The introduction of rapid response systems in hospitals is a complex, multicomponent intervention—essentially a process of social change. The effectiveness of these systems is sensitive to an array of influences.

Leadership, changing environments, details of implementation, organizational history, and much more. In such complex terrain, the RCT is an impoverished way to learn. Critics who use it as a truth standard in this context are incorrect.Having personally observed the value of I-PASS, as well as the devastating consequences of inadequate handovers, I vote with Dr Berwick.

The evidence for effectiveness is overwhelming and the need for action is urgent—all that is lacking is the will to implement.Ethics statementsPatient consent for publicationNot required.Palliative care is associated with improved patient-centred and caregiver-centred outcomes, higher-quality end-of-life care, and decreased healthcare use among patients with serious illness.1–3 The Centre to Advance Palliative Care has established a set of recommended clinical criteria (or ‘triggers’), including a projected survival of less than 1 year,4 to help clinicians identify patients likely to benefit from palliative care. Nevertheless, referrals often occur within the last 3 months of life5 due in part to clinician overestimation of prognosis.6 A growing number of automated predictive models leverage vast data in the electronic medical record (EMR) to accurately predict short-term mortality risk in real time and can be paired with systems to prompt clinicians to refer to palliative care.7–12 These models hold great promise to overcome the many clinician-level and system-level barriers to improving access to timely palliative care. First, mortality risk prediction algorithms have been shown to outperform clinician prognostic assessment, and clinician–machine collaboration may even outperform both.13 Second, algorithm-based ‘nudges’ that systematically provide prognostic information could address many cognitive biases, including status quo bias and optimism bias,14 15 that make clinicians less apt to identify patients who may benefit from palliative care.

Indeed, such models have been shown to improve the frequency of palliative care delivery and patient outcomes in the hospital and clinic settings.9 16 17 With that said, successful implementation of automated prognostic models into routine clinical care at scale requires clinician and patient engagement and support.In this issue of BMJ Quality &. Safety, Saunders and colleagues report on the acceptability of using the EMR-based Modified Hospitalised-Patient One-Year Mortality Risk (mHOMR) score to alert clinicians to individual patients with a >21% risk of dying within 12 months. The goal of the clinician notification of an elevated risk score was to prompt clinicians to consider palliative care referral.18 In a previously reported feasibility study among 400 hospitalised patients, use of the mHOMR alert was associated with increased rates of goals of care discussions and palliative care consultation in comparison to the preimplementation baseline (34% vs 18%, respectively).19 In the present study, the authors conducted qualitative interviews pre-mHOMR and post-mHOMR implementation among 64 stakeholders, including patients identified at high risk by the mHOMR algorithm, their caregivers, staff and physicians.

Thirty-five (55%) participants agreed that the mHOMR tool was acceptable. 14 (22%) were unsure or did not agree. And 15 (23%) did not respond.

Participants identified many potential benefits of the programme, citing the advantages of an automated approach to facilitate and justify clinical decision making. Participants also acknowledged possible barriers, particularly ‘situational challenges’ such as the content, timing and mechanism of provider notification. Additional logistical concerns included alert fatigue, potential redundancy, uncertainty regarding next steps and a worry that certain therapeutic options could be withheld from flagged patients.

The authors concluded that clinicians and patients found the automated prognostic trigger to be an acceptable addition to usual clinical care.Saunders et al’s work adds to our understanding of critical perceptions regarding end users’ acceptability of automated prognostic triggers in routine clinical care. The findings from this study align with prior evidence suggesting that clinicians recognise the value of automated, algorithm-based approaches to improve serious illness care. For example, in a qualitative study of clinicians by Hallen et al, prognostic models confirmed clinicians’ gestalt and served as a tool to help communicate prognosis to patients.20 Clinicians described prognostic models as a tool to facilitate interclinician disagreements, mitigate medicolegal risk, and overcome the tendency to ignore or overestimate prognosis.20 Clinicians also reported that EMR-generated lists of high-risk patients improved their ability to identify potential palliative care beneficiaries in a mixed-methods study by Mason et al.21 In a single-centre pilot study, we similarly found that most clinicians believed that using an EMR-based prognostic model to encourage inpatient palliative care consultation was acceptable.9 However, in the Saunders et al study, as in prior similar work, clinicians highlighted the importance of delivering notifications without causing excess provider workload, redundancy or alert fatigue.16 18 21 Clinicians also raised concerns regarding the accuracy of the prognostic information and the potential for negative effects on patients due to common misperceptions about palliative care being equivalent to hospice.18 20 21 Ultimately, Saunders et al’s work complements and builds on existing literature, demonstrating a general perception that integration of automated prognostic models into routine clinical care could be beneficial and acceptable.Important gaps remain in this literature which were not addressed by the Saunders et al study.

For example, there is a need to capture more diverse clinician and patient perspectives, and there was no information provided about the sociodemographic or clinical characteristics of the study participants. Additionally, important themes found in prior studies were not identified in this study. For example, two prior studies of clinicians’ perspectives on automated prognostic triggers for palliative care revealed concerns that prognosis alone may not be a sufficient surrogate indicator of actual palliative care need, or may inadvertently engender clinician overconfidence in an individual patient’s prognosis.9 21 The brevity of the interviews in Saunders et al’s study (mean.

12 min) could suggest all relevant themes may not have emerged in the data analysis. Additionally, while the inclusion of patient and caregiver perceptions is an important addition, limited information is provided about their perspectives and whether certain themes differed among the stakeholders. In the study from Mason et al, themes unique to patients and caregivers were identified, such as hesitancy due to a lack of understanding of palliative care, a preference to ‘focus on the present’, and a worry that a clinician would not have the time to adequately address advanced care planning or palliative care during their visit.21 Healthcare systems should therefore be prepared to consider their unique workflows, patients and staff prior to implementing one of these programmes.Achieving stakeholder acceptability prior to widespread implementation is essential.

An intervention should ideally undergo multiple cycles of optimisation with ongoing appraisal of patient and clinician perspectives prior to wide-scale implementation.22 23 Additionally, it is unclear whether clinicians’ acceptability of the intervention in one setting will generalise to other inpatient health settings. For instance, Saunders et al found that some providers were leery about the use of mHOMR due the need to balance the patient’s acute needs that brought them to the hospital with their long-term priorities that may be better served in the outpatient setting.18 Clinical workflows, patient acuity and patient–provider relationships are markedly different between the inpatient and outpatient settings, suggesting Saunders et al’s findings cannot be extrapolated to outpatient care. This is particularly relevant as many ‘off-the-shelf’ prognostic algorithms are now commercially available that, while accurate, may not be as familiar or acceptable to clinicians as a homegrown model.

Therefore, while Saunders et al’s work is a great addition to the field, additional assessments are needed across different healthcare environments and varying clinical and demographic cohorts to demonstrate that this approach is acceptable in other health settings. It is likely that multiple implementation strategies will be needed to successfully adapt automated prognostic models across a range of clinical settings.Thoughtful consideration of the many forces that alter clinical decision making will also be critical for downstream success of these interventions. Suboptimal clinical decision making is often a result of systemic biases, such as status quo and optimism bias, which result in clinician resistance to change current practice and a belief that their patients are less prone to negative outcomes.14 15 Intentional application of targeted behavioural economics principles will help ensure that the use of prognostic triggers to improve palliative care effectively changes clinical behaviour.24 For example, using an ‘opt-out’ approach for palliative care referral may make the optimal choice the path of least resistance, increasing uptake among clinicians.16 These approaches will need to be balanced against rising clinician alert fatigue25 and resource constraints.Given the implementation challenges that accompany an intervention using prognostic triggers, hybrid effectiveness trials that test both clinical effectiveness and implementation outcomes offer one strategy to advance the integration of automated prognostic models.26 Implementation outcomes are typically based on a framework which provides a systematic way to develop, manage and evaluate interventions.

For example, Reach Effectiveness Adoption Implementation Maintenance (RE-AIM) is a framework that measures the impact of a programme based on five factors. Reach, effectiveness, adoption, implementation and maintenance.27 Due to their pragmatic approach, hybrid trials frequently include heterogenous samples and clinical settings that optimise external validity and generalisability.26 28 They can be designed to primarily test the effects of a clinical interventions while observing and gathering information on implementation outcomes (type I), for equal evaluation of both the clinical intervention and implementation strategies (type II), or to primarily assess implementation outcomes while collecting effectiveness data (type III).26 29 For example, Beidas et al used a type I hybrid effectiveness–implementation trial design to test the effectiveness of an exercise intervention for breast cancer. This study not only evaluated the effectiveness of the intervention but also identified multiple significant implementation barriers such as cost, referral logistics and patient selection challenges which informed their subsequent dissemination efforts.30 Prospective, randomised, hybrid effectiveness–implementation designs focusing on other key implementation outcomes are a logical and necessary next step in advancing the field.

In total, the work by Saunders et al demonstrates the potential acceptability of an automated prognostic model to improve the timeliness of palliative care, setting the stage for further work to optimise and implement these programmes into real-world clinical care.Ethics statementsPatient consent for publicationNot required..

In this issue of BMJ Quality and Safety, can i get propecia without a prescription Jorro-Barón and colleagues1 report the findings of a stepped-wedge cluster randomised trial (SW-CRT) to evaluate the implementation of the I-PASS handover system among six paediatric how to buy propecia in usa intensive care units (PICUs) at five Argentinian hospitals between July 2018 and May 2019. According to the authors, prior to the intervention there were complaints that handovers were ‘…lengthy, disorganized, …participants can i get propecia without a prescription experienced problems with interruptions, distractions, and … senior professionals had problems accepting dissent’.Adverse events were assessed by two independent reviewers using the Global Assessment of Pediatric Patient Safety instrument. Study results demonstrated significantly improved handover compliance in the intervention group, validating Kirkpatrick Level 3 (behavioural change)2 effectiveness of the training initiative. Notably, however, on the primary outcome there were no differences between control and intervention groups regarding preventable adverse events per 1000 days of hospitalisation (control 60.4 (37.5–97.4) vs intervention 60.4 (33.2–109.9), p=0.998, can i get propecia without a prescription risk ratio.

1.0 (0.74–1.34)). Regarding balancing measures, there was no observed can i get propecia without a prescription difference in the ‘full-shift’ handover duration (control 35.7 min (29.6–41.8). Intervention 34.7 min (26.5–42.1), p=0.490), although more time was spent on individual patient handovers in the intervention period (7.29 min (5.77–8.81). Control 5.96 can i get propecia without a prescription min (4.69–7.23).

P=0.001). From the provider perspective, preintervention and postintervention Agency for Healthcare Research and Quality (AHRQ) safety culture surveys did not show significant differences in their responses to communication-focused questions before and after the intervention.Thus, consistent with all previous studies, I-PASS was implemented successfully and handover quality improved. However, is the lack of association of I-PASS implementation with clinical outcomes and adverse events in this study a concern?. To answer this question, it is necessary to review the origins of I-PASS more than a decade ago and its continually expanding evidence base.Healthcare has a handover problemHandovers are among the most vulnerable reoccurring processes in healthcare.

In the AHRQ safety culture survey,3 the handovers and transitions of care domain is consistently among the lowest scoring, and handover and communication issues are among the most common cause of Joint Commission Sentinel Events and the subject of Joint Commission Sentinel Event Alert Issue 58.4 A study by CRICO Strategies found that communication issues were a factor in 30% of 23 658 malpractice claims filed from 2009 to 2013, accounting for $1.7 billion in incurred losses.5 The importance of handovers and care transitions for trainees is specifically discussed in a Clinical Learning Environment Review Issue Brief published by the Accreditation Council for Graduate Medical Education (ACGME),6 and Section VI.E.3 (Transitions of Care) of the ACGME Common Program Requirements (Residency) addresses the requirement for residents to be taught and to use structured handovers.7Both the numbers of handovers and handover-related problems have increased in contemporary practice because of greater patient complexity and the expanding number and types of providers involved in a typical patient’s care. Further, in teaching institutions, resident work-hour restrictions have resulted in the need for complex coverage schemes. Off-hours care is often provided by ‘cross-covering’, ‘float’ or ‘moonlighting’ practitioners who are responsible for numerous unfamiliar patients during their shifts, thus imposing an even greater need for effective handovers. The net effect of all these changes may be inconsistent, fragmented care resulting from suboptimal handovers from one provider, service or hospital to another, with resulting medical errors (often of omission) and adverse events.Structured, standardised handoversThese serious vulnerabilities have led to pleas for more consistent, structured and standardised handovers.8–11 In addition to their use in routine shift-to-shift provider sign-off, these may be of particular value in the high-risk transfers of critically ill patients, such as from operating rooms to postoperative care units and ICUs12–16.

Admissions to a surgery unit17. Management of trauma patients18–20. ICU to general ward transfers21 22. Night and weekend coverage of large services, many of whose patients are unfamiliar to the physician receiving the handover23–28.

And end-of-rotation resident transitions.29–31Given these considerations, standardised handovers, often involving mnemonic devices, have been widely advocated and studied in the past several decades, though many lack rigorous evaluation and few if any showed demonstrable associations with outcomes.32 33 Further, although some individual hospitals, units and services have implemented their own idiosyncratic handover systems, this does not solve the issue of handover inconsistency between different care delivery sites. A basic, common framework that could be customised to individual use cases would clearly be preferable.The I-PASS systemResponding to these concerns, the I-PASS Study Group was initiated in 2009 and the I-PASS Institute in 2016. Although numerous other systems are available, since its pilot studies a decade ago,34 35 I-PASS has emerged as the dominant system in healthcare for structured, standardised handovers. This system is specifically designed for healthcare applications.

It is based on adult educational principles and simple to use. It has been extensively validated in the peer-reviewed literature encompassing studies at multiple institutions in the USA and internationally34–40. And extensive training materials are available to assist programmes in implementation.39 41–45 Ideally, this system is implemented hospital-wide, which addresses the issue of cross-unit and cross-service transfers.I-PASS includes five major elements regarded as important for every handover—illness severity, patient summary, action list, situation awareness/contingency planning and synthesis by receiver. The first three of these elements are often included in non-structured handovers, although not necessarily in a specific sequence or format.

The last two I-PASS elements—situational awareness/contingency planning and synthesis—have not historically been included in typical handover practice. The former assures that any anticipated problems are conveyed from the handover giver to the incoming provider and that appropriate responses to these issues are discussed. Synthesis is closed-loop communication, with brief read-back of the handover information by the receiver to assure their accurate comprehension, followed by an opportunity for questions and discussion. This read-back of mission-critical communications is standard operating practice in other high-reliability settings such as aviation, the military and nuclear power.

It is essential to establishing a shared mental model of the current state and any potential concerns. However, other than in I-PASS, it is quite uncommon in healthcare, with the potential exception of confirming verbal or telephonic orders.I-PASS validationIn an initial study of I-PASS handover implementation by residents on two general inpatient paediatric units at Boston Children’s Hospital,34 written handovers were more comprehensive and had fewer omissions of key data, and mean time spent on verbal handover sessions did not change significantly (32.3 min vs 33.2 min). Medical errors and adverse events were ascertained prospectively by research nurse reviewers and independent physician investigators. Following I-PASS implementation, preventable adverse events decreased from 3.3 (95% CI 1.7 to 4.8) to 1.5 (95% CI 0.51 to 2.4) per 100 admissions (p=0.04), and medical error rates decreased significantly from 33.8 per 100 admissions (95% CI 27.3 to 40.3) to 18.3 per 100 admissions (95% CI 14.7 to 21.9.

P<0.001). A commentary by Horwitz46 noted that this was ‘…by far the most comprehensive study of the direct effects of handoff interventions on outcomes within the context of existing work-hour regulations and is the first to demonstrate an associated significant decrease in medical errors on a large scale’, while also noting limitations including its uncontrolled, ‘before and after’ design, confounding by secular changes, Hawthorne effects and inability to blind the nurses collecting adverse event data.The more expansive, landmark I-PASS study was conducted by Starmer and colleagues37 among nine paediatric hospitals and 10 740 patient admissions between January 2011 and May 2013. Handover quality was evaluated, and medical errors and adverse events were ascertained by active surveillance, including on-site nurse review of medical records, orders, formal incident reports, nursing reports and daily medical error reports from residents. Independent physician investigators classified occurrences as adverse events, near misses or exclusions, and they subclassified adverse events as preventable or non-preventable.

Results revealed a 23% reduction in medical errors from the preintervention to the postintervention period (24.5 vs 18.8 per 100 admissions, p<0.001) and a 30% reduction in preventable adverse events (4.7 vs 3.3 events per 100 admissions, p<0.001). Inclusion of prespecified elements in written and verbal handovers increased significantly, and there was no significant change in handover time per patient (2.4 vs 2.5 min. P=0.55).Subsequent investigations in other institutions have replicated many of the findings of the original I-PASS studies, with higher postintervention inclusion rates of critical handover elements. Fewer mistakes or omissions.

Greater provider satisfaction with handover organisation and information conveyed. Unchanged or shorter handoff times. And decreased handover interruptions (probably reflecting greater attention to the importance of the handover process).36 40 47–50 In a mentored implementation study conducted in 2015–2016 among 16 hospitals (five community hospitals, 11 academic centres and multiple specialties), handover quality improved, and there was a provider-reported 27% reduction in adverse events.38 Among nurses at Boston Children’s Hospital, I-PASS implementation was associated with significant decreases in handover-related care failures.40In recognition of its achievements in improving healthcare quality, the I-PASS Study Group was awarded the 2016 John M Eisenberg Award for Patient Safety and Quality by the National Quality Forum and the Joint Commission.The challenge of linking handovers to clinical outcomes and eventsAlthough investigations from many centres, including the report of Jorro-Barrón and colleagues,1 have now confirmed that I-PASS can be readily assimilated and used by clinicians, most of these have either not rigorously assessed adverse events, medical errors and other clinical outcomes (Kirkpatrick Level 4 evaluation) or have failed to demonstrate significant postintervention improvements in these clinical outcomes. Why is this, and should current or potential I-PASS users be concerned?.

With regard to the first question, there are practical considerations that complicate the rigorous study of clinical outcome improvements associated with I-PASS (or any other handover system). Notwithstanding the importance of effective communications, these are only one of many provider processes and hospital systems, not to mention the overall hospital quality and safety culture, that impact a patient’s clinical outcome. In most hospitals, a diverse portfolio of quality and safety improvement initiatives are always being conducted. Disentangling and isolating the effects of any one specific intervention, such as I-PASS handovers, is challenging if not impossible.

At a minimum, it requires real-time, prospective monitoring by trained nurse or physician reviewers as in the original I-PASS studies, a research design which realistically is unlikely to be reproduced. Ideally, the study design would also include blinding of the study period (control or intervention) and blinding of observers, the former of which is virtually impossible for this type of intervention.Further, if other provider processes and hospital systems are functioning at a high level, they may partially offset the impact of suboptimal communications and make it even more challenging to demonstrate significant improvements. The current study of Jorro-Barón and colleagues,1 which uses PICUs as the unit of analysis, illustrates this concept. PICUs are typically among the most compulsive, detail-oriented units in any hospital, even if they may have nominally ‘non-standardized’ handovers.Study design.

The SW-CRTIn an attempt to address the limitations of some previous studies, Parent and colleagues51 studied eight medical and surgical ICUs across two academic tertiary teaching hospitals using an SW-CRT design. Clinician self-assessment of having been inadequately prepared for their shift because of a poor-quality handoff decreased from 35 of 343 handoffs (10.2%) in the control arm to 53 of 740 handoffs (7.2%) postintervention (OR 0.19. 95% CI 0.03 to 0.74. P=0.03).

€˜Last-minute’, early morning order writing decreased, and handover duration increased but not significantly (+5.5 min. 95% CI 0.34 to 9.39. P=0.30). As in the current study of Jorro-Barón and colleagues,1 who also employed an SW-CRT, there were no associated changes in clinical outcomes such as ICU length of stay, duration of mechanical ventilation or necessity for reintubation.

The authors comment that given high baseline quality of care in these ICUs, it was not surprising that there were no changes in outcomes.An SW-CRT is generally considered a rigorous study design as it includes cluster randomisation. However, though novel and increasingly popular, this approach is complex and may sometimes add confusion rather than clarity.52–57 Its major appeal is that all clusters will at some point, in a random and sequential fashion, transition from control to intervention condition. For an intervention that is perceived by participants as having more potential for good than harm, this may enhance cluster recruitment. It may also make it possible to conduct a randomised study in scenarios where pragmatic considerations, such as the inability to conduct interventions simultaneously across numerous clusters, may make a parallel randomised study (or any study) infeasible.However, as acknowledged even by its proponents, the added practical and statistical complexity of SW-CRTs often makes them more challenging to properly implement, and compared with traditional parallel cluster randomised trials they may be more prone to biases.53–57 A Consolidated Standards of Reporting Trials extension has been specifically developed in response to these concerns.55 Unique design and analytical considerations include the number of clusters, sequences and periods.

Clusters per sequence. And cluster-period sizes.55 56 Concerns include recruitment and selection biases. Proper accounting for secular trends in outcomes (ie, because of the sequential rather than simultaneous nature of the SW-CRT design, observations from the intervention condition occur on average at a later calendar time, so that the intervention effect may be confounded by an underlying time trend). Accounting for repeated measures on participants and clusters in sample size calculations and analyses (ie, data are not independent).

Possible time-varying treatment effects. And the potential for within-cluster contamination of observations obtained under the control or intervention condition.52–56Regarding contamination, a secular trend may be responsible if, for example, institutional activities focused on improving patient outcomes include a general emphasis on communications. There might also be more direct contamination of the intervention among clusters waiting to be crossed over, as described in the context of the Matching Michigan programme.58 Participating in a trial and awareness of being observed may change the behaviour of participants. For example, in the handover intervention of Jorro-Barón and colleagues,1 some providers in a control condition cluster may, because they are aware of the interest in handovers, begin to implement more standardised practices before the formal shift to the intervention condition.

This potentially dilutes any subsequent impact of the intervention by virtue of what could be considered either a Hawthorne effect or a local secular trend, in either case leading to generally better handovers in the preintervention period. Some SW-CRTs include a transition period without any observations to allow for sufficient time to implement the intervention,53 59 thereby creating more contrast. Finally, because of sometimes prolonged PICU length of stay and regularly scheduled resident rotations on and off a unit or service, some patients and providers might overlap the transition from control to intervention state and contribute observations to both, while others will be limited to one or the other. This possibility is not clearly defined by the authors of the current study, but seems unlikely to have had a major statistical effect.Do we need more evidence?.

From an implementation science perspective, handovers are a deeply flawed healthcare process with the demonstrated potential to harm patients. A new tool—I-PASS—has been developed which can be easily and economically taught and subsequently applied by virtually any provider, and many resources are available to assist in implementation.45 It has few, if any, unintended negative consequences to patients or providers and has been associated in at least two extensive and well-conducted (although non-randomised) trials with dramatic reductions in medical errors and adverse events. Notably, these were conducted at a time when there was much less emphasis on and awareness of handover systems, including I-PASS. Thus, there was much greater separation between control and intervention states than would be possible today.Returning to the question posed at the beginning of this commentary, is the inability to demonstrate a favourable impact on clinical outcomes in studies other than those of the developers34 35 a reason to question the value of I-PASS?.

For the reasons discussed above, I think not. In his classic 2008 article,60 ‘The Science of Improvement’, Dr Don Berwick recounts the transformational development of sophisticated statistical analyses in healthcare, of which the randomised clinical trial is the paradigm. While in many instances randomised controlled trials have been invaluable in scientifically affirming or rejecting the utility of specific treatments or interventions, their limitations are more obvious in interventions involving complex social and behavioural change. Berwick illustrates this challenge with the example of hospital rapid response teams, whose benefit was challenged by the results of a large cluster randomised trial.

His comments regarding that conflict are equally applicable to the current challenge of demonstrating the impact of standardised handovers on clinical outcomes:These critics refused to accept as evidence the large, positive, accumulating experience of many hospitals that were adapting rapid response for their own use, such as children’s hospitals. How can accumulating local reports of effectiveness of improvement interventions, such as rapid response systems, be reconciled with contrary findings from formal trials with their own varying imperfections?. The reasons for this apparent gap between science and experience lie deep in epistemology. The introduction of rapid response systems in hospitals is a complex, multicomponent intervention—essentially a process of social change.

The effectiveness of these systems is sensitive to an array of influences. Leadership, changing environments, details of implementation, organizational history, and much more. In such complex terrain, the RCT is an impoverished way to learn. Critics who use it as a truth standard in this context are incorrect.Having personally observed the value of I-PASS, as well as the devastating consequences of inadequate handovers, I vote with Dr Berwick.

The evidence for effectiveness is overwhelming and the need for action is urgent—all that is lacking is the will to implement.Ethics statementsPatient consent for publicationNot required.Palliative care is associated with improved patient-centred and caregiver-centred outcomes, higher-quality end-of-life care, and decreased healthcare use among patients with serious illness.1–3 The Centre to Advance Palliative Care has established a set of recommended clinical criteria (or ‘triggers’), including a projected survival of less than 1 year,4 to help clinicians identify patients likely to benefit from palliative care. Nevertheless, referrals often occur within the last 3 months of life5 due in part to clinician overestimation of prognosis.6 A growing number of automated predictive models leverage vast data in the electronic medical record (EMR) to accurately predict short-term mortality risk in real time and can be paired with systems to prompt clinicians to refer to palliative care.7–12 These models hold great promise to overcome the many clinician-level and system-level barriers to improving access to timely palliative care. First, mortality risk prediction algorithms have been shown to outperform clinician prognostic assessment, and clinician–machine collaboration may even outperform both.13 Second, algorithm-based ‘nudges’ that systematically provide prognostic information could address many cognitive biases, including status quo bias and optimism bias,14 15 that make clinicians less apt to identify patients who may benefit from palliative care. Indeed, such models have been shown to improve the frequency of palliative care delivery and patient outcomes in the hospital and clinic settings.9 16 17 With that said, successful implementation of automated prognostic models into routine clinical care at scale requires clinician and patient engagement and support.In this issue of BMJ Quality &.

Safety, Saunders and colleagues report on the acceptability of using the EMR-based Modified Hospitalised-Patient One-Year Mortality Risk (mHOMR) score to alert clinicians to individual patients with a >21% risk of dying within 12 months. The goal of the clinician notification of an elevated risk score was to prompt clinicians to consider palliative care referral.18 In a previously reported feasibility study among 400 hospitalised patients, use of the mHOMR alert was associated with increased rates of goals of care discussions and palliative care consultation in comparison to the preimplementation baseline (34% vs 18%, respectively).19 In the present study, the authors conducted qualitative interviews pre-mHOMR and post-mHOMR implementation among 64 stakeholders, including patients identified at high risk by the mHOMR algorithm, their caregivers, staff and physicians. Thirty-five (55%) participants agreed that the mHOMR tool was acceptable. 14 (22%) were unsure or did not agree.

And 15 (23%) did not respond. Participants identified many potential benefits of the programme, citing the advantages of an automated approach to facilitate and justify clinical decision making. Participants also acknowledged possible barriers, particularly ‘situational challenges’ such as the content, timing and mechanism of provider notification. Additional logistical concerns included alert fatigue, potential redundancy, uncertainty regarding next steps and a worry that certain therapeutic options could be withheld from flagged patients.

The authors concluded that clinicians and patients found the automated prognostic trigger to be an acceptable addition to usual clinical care.Saunders et al’s work adds to our understanding of critical perceptions regarding end users’ acceptability of automated prognostic triggers in routine clinical care. The findings from this study align with prior evidence suggesting that clinicians recognise the value of automated, algorithm-based approaches to improve serious illness care. For example, in a qualitative study of clinicians by Hallen et al, prognostic models confirmed clinicians’ gestalt and served as a tool to help communicate prognosis to patients.20 Clinicians described prognostic models as a tool to facilitate interclinician disagreements, mitigate medicolegal risk, and overcome the tendency to ignore or overestimate prognosis.20 Clinicians also reported that EMR-generated lists of high-risk patients improved their ability to identify potential palliative care beneficiaries in a mixed-methods study by Mason et al.21 In a single-centre pilot study, we similarly found that most clinicians believed that using an EMR-based prognostic model to encourage inpatient palliative care consultation was acceptable.9 However, in the Saunders et al study, as in prior similar work, clinicians highlighted the importance of delivering notifications without causing excess provider workload, redundancy or alert fatigue.16 18 21 Clinicians also raised concerns regarding the accuracy of the prognostic information and the potential for negative effects on patients due to common misperceptions about palliative care being equivalent to hospice.18 20 21 Ultimately, Saunders et al’s work complements and builds on existing literature, demonstrating a general perception that integration of automated prognostic models into routine clinical care could be beneficial and acceptable.Important gaps remain in this literature which were not addressed by the Saunders et al study. For example, there is a need to capture more diverse clinician and patient perspectives, and there was no information provided about the sociodemographic or clinical characteristics of the study participants.

Additionally, important themes found in prior studies were not identified in this study. For example, two prior studies of clinicians’ perspectives on automated prognostic triggers for palliative care revealed concerns that prognosis alone may not be a sufficient surrogate indicator of actual palliative care need, or may inadvertently engender clinician overconfidence in an individual patient’s prognosis.9 21 The brevity of the interviews in Saunders et al’s study (mean. 12 min) could suggest all relevant themes may not have emerged in the data analysis. Additionally, while the inclusion of patient and caregiver perceptions is an important addition, limited information is provided about their perspectives and whether certain themes differed among the stakeholders.

In the study from Mason et al, themes unique to patients and caregivers were identified, such as hesitancy due to a lack of understanding of palliative care, a preference to ‘focus on the present’, and a worry that a clinician would not have the time to adequately address advanced care planning or palliative care during their visit.21 Healthcare systems should therefore be prepared to consider their unique workflows, patients and staff prior to implementing one of these programmes.Achieving stakeholder acceptability prior to widespread implementation is essential. An intervention should ideally undergo multiple cycles of optimisation with ongoing appraisal of patient and clinician perspectives prior to wide-scale implementation.22 23 Additionally, it is unclear whether clinicians’ acceptability of the intervention in one setting will generalise to other inpatient health settings. For instance, Saunders et al found that some providers were leery about the use of mHOMR due the need to balance the patient’s acute needs that brought them to the hospital with their long-term priorities that may be better served in the outpatient setting.18 Clinical workflows, patient acuity and patient–provider relationships are markedly different between the inpatient and outpatient settings, suggesting Saunders et al’s findings cannot be extrapolated to outpatient care. This is particularly relevant as many ‘off-the-shelf’ prognostic algorithms are now commercially available that, while accurate, may not be as familiar or acceptable to clinicians as a homegrown model.

Therefore, while Saunders et al’s work is a great addition to the field, additional assessments are needed across different healthcare environments and varying clinical and demographic cohorts to demonstrate that this approach is acceptable in other health settings. It is likely that multiple implementation strategies will be needed to successfully adapt automated prognostic models across a range of clinical settings.Thoughtful consideration of the many forces that alter clinical decision making will also be critical for downstream success of these interventions. Suboptimal clinical decision making is often a result of systemic biases, such as status quo and optimism bias, which result in clinician resistance to change current practice and a belief that their patients are less prone to negative outcomes.14 15 Intentional application of targeted behavioural economics principles will help ensure that the use of prognostic triggers to improve palliative care effectively changes clinical behaviour.24 For example, using an ‘opt-out’ approach for palliative care referral may make the optimal choice the path of least resistance, increasing uptake among clinicians.16 These approaches will need to be balanced against rising clinician alert fatigue25 and resource constraints.Given the implementation challenges that accompany an intervention using prognostic triggers, hybrid effectiveness trials that test both clinical effectiveness and implementation outcomes offer one strategy to advance the integration of automated prognostic models.26 Implementation outcomes are typically based on a framework which provides a systematic way to develop, manage and evaluate interventions. For example, Reach Effectiveness Adoption Implementation Maintenance (RE-AIM) is a framework that measures the impact of a programme based on five factors.

Reach, effectiveness, adoption, implementation and maintenance.27 Due to their pragmatic approach, hybrid trials frequently include heterogenous samples and clinical settings that optimise external validity and generalisability.26 28 They can be designed to primarily test the effects of a clinical interventions while observing and gathering information on implementation outcomes (type I), for equal evaluation of both the clinical intervention and implementation strategies (type II), or to primarily assess implementation outcomes while collecting effectiveness data (type III).26 29 For example, Beidas et al used a type I hybrid effectiveness–implementation trial design to test the effectiveness of an exercise intervention for breast cancer. This study not only evaluated the effectiveness of the intervention but also identified multiple significant implementation barriers such as cost, referral logistics and patient selection challenges which informed their subsequent dissemination efforts.30 Prospective, randomised, hybrid effectiveness–implementation designs focusing on other key implementation outcomes are a logical and necessary next step in advancing the field. In total, the work by Saunders et al demonstrates the potential acceptability of an automated prognostic model to improve the timeliness of palliative care, setting the stage for further work to optimise and implement these programmes into real-world clinical care.Ethics statementsPatient consent for publicationNot required..

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Representatives from the Veterans Administration faced concerns from legislators this past week propecia prescription only around patient-safety issues associated with the agency's Cerner electronic health record modernization initiative. "At the end of the day, this whole undertaking is about improving patient care," said Rep. Debbie Wasserman Schultz, D-Fla., in a House Appropriations Military propecia prescription only Construction, Veterans Affairs, and Related Agencies Subcommittee hearing on Thursday. WHY IT MATTERS Wasserman Schultz noted that the VA's first rollout of its new EHR took place one year ago this month, at Mann-Grandstaff VA Medical Center in Spokane, Washington.

The VA had initially planned to go live at 11 sites by propecia prescription only the end of 2021. "At this point, VA is more than one year behind their initial schedule," said Wasserman Schultz. She cited complaints from staff and local propecia prescription only legislators, particularly those about patient-safety issues. "While there have been no reports of patient harm – thank God – at Mann-Grandstaff, this is not a concern to be taken lightly," she said.

Wasserman Schultz also flagged issues around funding, including findings from the propecia prescription only Office of Inspector General that the estimates of project costs had fallen short by billions. She called a revised estimate time line "problematic." VA Deputy Secretary Donald Remy took a determined stance, assuring legislators that he was taking responsibility for the program's progress. "The success propecia prescription only or failure of any program boils down to a partnership," he said. "Our handling of EHRM to date has failed to live up to this program's promise for our veterans and our providers," he continued.

"Regardless of what happened before, and regardless of how long I've been here, I'm here now," propecia prescription only he said. "I promise I'll be accountable to you and collaborate with you as we move forward." He said the VA is learning from its implementation mistakes. That the Cerner system works propecia prescription only. And that the agency is bringing together all relevant internal and external stakeholders.

"I appreciate your propecia prescription only enthusiasm," said Wasserman Schultz. "But we really need to go beyond enthusiasm." Remy explained that the agency has organized patient safety concerns into several domains, such as order management, administration of medicine, pharmacy, suicide risk, tracking and documentation, identity, referrals and consults, roles, positions, privileges, and ambulatory care When concerns arise, Remy said, the agency categorizes them, examines them and "makes sure they don't reoccur." "OK, but really. How did propecia prescription only this happen?. " Wasserman Schultz said.

"What, specifically, propecia prescription only are you doing to prevent this in the future?. " Remy said it's a matter of evaluation, training and putting protective processes in place, using a multidisciplinary team. "Specifically, these teams are monitoring our clinical workflows to make sure that the integration process of EHR and what our clinicians propecia prescription only are doing is not interfering with their ability to care for their patients properly," he said. He reiterated that the agency still intends to meet its ten-year rollout time frame, but said the agency could not yet provide a specific time line for it.Still, Wasserman Schultz said she required more information.

"I can appreciate that you inherited a mess, and that you are in the middle propecia prescription only of sorting through the morass, but unfortunately your … responses to our questions about patient safety really aren't detailed enough," she said, especially regarding how issues happened, and how the agency planned to fix them. When it came to prioritizing cybersecurity, Remy said the agency recognized the need for interoperability between the new and legacy programs, while ensuring information remains protected. "Cybersecurity is a clear part of our priorities," he said.Still, propecia prescription only legislators sounded the alarm that an enterprise-wide strategy had not been put forward yet."It's so critical that we get going. This isn't a 'nice to have.' We're already seeing these cyber intrusions in every aspect of our lives," said Rep.

Vicente Gonzalez, propecia prescription only D-Texas. "It's only a matter of time before the VA becomes the next target." Wasserman Schultz proposed more frequent hearings – including one specifically on patient safety, and perhaps on a monthly basis – to ensure comprehensive information sharing. She also hinted that the appropriations committee might find it difficult to propecia prescription only justify continuing to set funding aside for the project without specifics about how it will be spent. "There's nothing better than direct communication … with a good, old-fashioned hearing with members," she said.

"I'll be praying for you," said Rep. John "Judge" Carter, propecia prescription only R-Texas. "Because we need to get this done right." "It is a cumulative mess of multiple administrations," added Wasserman Schultz. "Help us propecia prescription only help you, Mr.

Secretary." THE LARGER TRENDThe VA has continued to face legislative scrutiny about the EHR modernization program, particularly following the release of numerous OIG reports about the initiative. But despite the setbacks, the agency has continued to push forward, most recently allocating $134 million to Cerner to continue deploying the EHR and turning to a third party to analyze the true cost of the project.ON THE RECORD propecia prescription only "The secretary has tasked me with building exactly that type of partnership on electronic health record implementation – to create a platform that seamlessly delivers the best access and outcomes for our vets and the best experience for our clinicians and providers, and that's exactly what I'm going to do," said the VA's Remy during the hearing. Kat Jercich is senior editor of Healthcare IT News.Twitter. @kjercichEmail.

Kjercich@himss.orgHealthcare IT News is a HIMSS Media publication.Concentra is a Texas-based healthcare organization that serves the occupational health needs of one in four injured employees through 517 medical centers across the country, another 150 clinics at employer locations, and telemedicine.THE PROBLEMConcentra has seen telemedicine as a much-needed additional option for the delivery of care. It implemented the first model via kiosks, piloted with a single employer. It learned a lot of valuable information from the pilot – namely that the kiosk system was not scalable. The healthcare organization knew there could be a more cost-effective and efficient way to deliver virtual care."I joined Concentra in June 2017.

Just before, I was a long-term Concentra client as vice president of risk management/claims for Macy's," said Ann Schnure, vice president of telemedicine at Concentra. "I wanted our retail organization to be a beta tester of Concentra's telemedicine program and was very interested in telemedicine as a way to increase access to care."I was thrilled to have the opportunity to join Concentra and lead our efforts to develop and implement a telemedicine solution that would provide high value to employers and their employees."Before she joined the organization, Concentra had explored many software solutions. The first live telemedicine visit was in June 2017."Flexible workflows right out of the box and support of our multi-patient group waiting room – these are key to our efficient workflow, and allow us to focus our clinicians on the delivery of patient care."Ann Schnure, Concentra"Across about two years we saw steady growth in our program and maintained a continuous learning process to enhance this patient care delivery modality for our client organizations," she recalled. "But we also hit some significant barriers with too many clicks-to-visit and additional challenges."Then we learned of vendor eVisit's virtual care platform, which met our crucial criteria to fix these challenges and more.

We made our purchase decision in 2019 and launched eVisit in 2020."PROPOSALWhen Concentra started with eVisit, it was to address a video visit plug-in situation. But as the organization has continued to work with the vendor, the platform and team have become a longer-term solution."We knew it had rich end-to-end functionality, but what was so great for us in our occupational telemedicine workflows was its flexibility, its integration layer, ease of use, and tools like the scheduling tool and the platform's sophisticated reporting features, including real-time reports," Schnure said."Specifically, for our largest customers, connecting to the video visit is seamless – no plug-in required," she continued. "And for the patient clicks-to-visit, we have brought that from 27 down to about eight clicks, and that's a direct reflection of the ease of use of eVisit."The Concentra Telemed offering offers a group waiting room with care coordinators who can see the multiple patients and their status. It also features multiple hand-offs to providers and back-to-care coordinators.

It's a complicated virtual workflow and somewhat unique to occupational care. The platform enables this workflow seamlessly, she added."Our clinicians' time is maximized – our aim is to have clinicians focus 100% of their time on delivering patient care, and in our virtualized workflow they spend very little time on administrative tasks," she explained. "We have objectives for service and know in real time if we are meeting our service standards because the eVisit system allows us to track everything we need to have visibility against our goals and metrics."MARKETPLACEThere is a wide variety of companies providing telemedicine technologies and services on the marketplace today. Healthcare IT News published a special report detailing these companies and their offerings.

Click here to access the special report.MEETING THE CHALLENGEThe initial challenge was to find a system with seamless video connection, no plug-ins, and just a few clicks-to-visits for patients. What Concentra found in the platform were many features that allowed it to optimize and expand its telemedicine solution. Under a continuous improvement model, Concentra routinely is finding value and efficiencies.A dedicated Concentra Telemed staff of 40-plus individuals serving virtual care patient needs with all clinicians who have a user profile and the ability to conduct a visit use the system."Flexible workflows right out of the box and support of our multi-patient group waiting room – these are key to our efficient workflow and allow us to focus our clinicians on the delivery of patient care," Schnure noted. "The scheduling tool allows our care coordinators to send patients a link and all they need to do is click it to get into the visit.

The charting tool is used to very effectively prep for second visits where we are reviewing labs or imagery."The eAnalyze tool is a sophisticated reporting system that tracks data we need to manage our telemedicine program – from patient wait times in the waiting room, virtual visits completed/canceled, provider usage and tasks performed, and more," she continued. "This feature delivers up-to-the-minute real-time data. It's very useful for many reasons, but mostly to help us gain insights into where we can improve and make efficiencies."RESULTSFollowing are successes Schnure reports through using the new telemedicine system:Clicks to visit. Through efficiencies and ease of use of the technology, the organization got patient clicks from 27 down to 8 clicks to the visit.Real-time accurate reporting helps Concentra do better and address issues.

Before, it did manual reporting, knitting together disparate spreadsheets of data. It was not fast, effective nor comprehensive. Now the organization has comprehensive reporting in real time across the entire platform, which allows staff to:Improve staffing modelsImmediately address cancellations – they can see the reason for the cancellation immediately. Staff can address that same-day within minutes and get back on track with that patient and the scheduleTraining – if staff are seeing a care coordinator who is very efficient, they have modeled that and trained others to be more efficient and effectiveHelps with quality auditsReduced no-shows by 10%ADVICE FOR OTHERS"Carefully evaluate the video portion of the platform," Schnure advised her peers.

"In many cases, the SaaS provider outsources that element of the platform, and they aren't experts on that piece of the technology. The video visit is important and connects the patient to the clinician. Also, ask about average click-to-visit stats and patient satisfaction metrics."Be careful with telemedicine platforms that come with D2C provider networks," she added. "Ask questions like, Do you provide patient care directly through the platform?.

And if so, what percentage of your company's revenue comes from providing these healthcare services?. "In Schnure's experience, they often are their own biggest customer and those technology providers tend to make technology development decisions based on their D2C models, and a client's technical requests may not be heard."There are hundreds of solutions out there, and telemedicine is moving at a rapid rate," she noted. "If a technology provider hasn't made any changes or enhancements to their platform over the past 18 months, that may be a concern."Find a partner with a vision of telemedicine that aligns with yours," she continued. "Look for partners who can power your telemedicine strategies and have flexible workflows, integration capabilities and sophisticated reporting functionality."Many healthcare organizations have unique telemedicine needs when it comes to how to implement the technology, and it's important that a healthcare organization pick a technology vendor that is flexible and listens to distinct needs, goals, strategies and requirements, she concluded.Twitter.

@SiwickiHealthITEmail the writer. Bsiwicki@himss.orgHealthcare IT News is a HIMSS Media publication.The plans include introducing digital systems for healthcare organisations which have not previously used them, restocking and updating old technology, improving cybersecurity and expanding the use of shared digital care records.This much-needed cash is part of the government’s so-called levelling-up agenda, which will be beneficial for all regions in the UK.WHY IT MATTERSThe extra investment in IT and data services to create digital patient records is part of the government’s plans to speed up working practices in the NHS and free up valuable time for health workers.There will be support for around 100 'one-stop-shop' community diagnostic centres across England, to assist those waiting for clinical tests such as MRIs, uasounds and CT scans.One in 10 trusts still operate on “paper-based systems” according to Health and social care secretary, Sajid Javid. NHS trusts have been seeking an additional £1.8 billion per year by 2024, which would take the overall NHS capital budget to £10.3 billion.Figures released earlier this month showed GPs were also facing record demand with 24 million appointments taking place – above pre-propecia levels.Greater use of technology has meant that some 1.25 million texts and 300,000 emails were sent to parents of two and three-year-olds informing them of booking appointments for hair loss treatment jab for their children.THE LARGER CONTEXTIn total, the chancellor is expected to announce an increase of £5 billion in the health service’s capital budget. This will go towards the government’s pledge of building 48 new hospitals by 2030 and a comprehensive programme of hospital upgrades.The funds will also aid the NHS in tackling backlogs caused by the hair loss treatment propecia.

Specifically, to address millions of patients waiting for diagnostic tests and non-emergency operations.As part of the £3 billion “skills revolution”, Sunak is expected to announce a number of “boot camps” for skills including cybersecurity and artificial intelligence.ON THE RECORD“Any significant budget allocated towards the digitisation of healthcare services is positive. However, we must always remember this is a long term journey so a single budget is not enough but needs to be sustained instead,” Dr Saif F Abed, director of Cybersecurity Advisory Services told Healthcare IT News.“In terms of where the money should go I think we need to be pragmatic. Investments need to be made in people and process improvements - as well as technology itself. €œElectronic medical records, enhanced interoperability, capacity management platforms and clinical decision support tools are prime candidates here.

We must also remember that accelerated digitisation presents tremendous risks from a cyber-crime perspective too so it is critical that a sizeable budget is allocated for investments in cybersecurity skills and solutions from national to local levels.”The U.S. Cybersecurity and Infrastructure Security Agency announced this week that it had issued a first-of-its kind $2 million award to two organizations developing cyber workforce training programs. NPower and CyberWarrior will use the money to address the cybersecurity workforce shortage around the country, said the agency. "CISA is dedicated to recruiting and training individuals from all areas and all backgrounds with the aptitude and attitude to succeed in this exciting field," said CISA Director Jen Easterly in a statement.

"It’s not just the right thing to do. It’s the smart thing to do – for the mission and the country," Easterly said. WHY IT MATTERS CyberWarrior and NPower will collaborate with the agency to develop a three-year pilot program aimed at benefiting populations that may not have access to cybersecurity training – such as unemployed and underemployed people, and underserved communities in urban and rural areas.The program aims to. Develop and implement a comprehensive cybersecurity pathways retention strategyDeliver entry-level cybersecurity training through innovative training hubsProvide hands-on and professional development experience through apprenticeshipsPlace talented individuals into entry-level cybersecurity jobs "CyberWarrior is honored to take part in the Cybersecurity Workforce Development and Training Pilot for Underserved Communities,” said CyberWarrior Foundation founder Reinier Moquete.

"Working with CISA and other stakeholders, our 28-week bootcamp program will train persons from underserved populations for a career in cybersecurity," Moquete continued. "NPower’s cybersecurity program offers young adults and veterans the opportunity to advance their careers and deepen their specialties. This is particularly important for individuals coming from underrepresented communities that systemically lack access to those specialized skills," said Bertina Ceccarelli, CEO of NPower. "We are honored for the support from CISA, which will enable NPower to expand our reach to trainees across the country," added Ceccarelli.

THE LARGER TREND In the face of escalating ransomware attacks on critical infrastructure – including hospitals and health networks – the federal government has ramped up its defense efforts. This summer, President Joe Biden issued a memo formally establishing the Industrial Control System Cybersecurity Initiative and directing agencies to develop cybersecurity performance goals for infrastructure. Legislators have also introduced several bills aimed at beefing up organizations' cyber muscles. And the private sector has stepped in too.

Earlier this month, Google announced the launch of its Cybersecurity Action Team, aimed at guiding customers through the cycle of security transformation. ON THE RECORD "We’re best positioned to solve the cyber challenges facing our nation when we have a diverse range of thought bringing every perspective to the problem," said CISA's Easterly in a statement. Kat Jercich is senior editor of Healthcare IT News.Twitter. @kjercichEmail.

Kjercich@himss.orgHealthcare IT News is a HIMSS Media publication.As communities across the nation seek new ways to bring hair loss treatment vaccination rates up to levels that can more effectively mitigate the spread of variants, they are looking for new and better ways to reach those who are just hesitant, undecided or unaware of how to get vaccinated.A study of one regional health system's digital campaign found that sending interactive text messages increased vaccinations rates by more than 4%, in this case by using "psychological ownership" techniques designed to make the message receiver think of the treatment shot as "theirs."In an interview with Healthcare IT News, Sonia Singh, senior vice president of consumerism at AVIA Health, a digital health company, sheds light into this concept and explains the value of digital campaigns. She draws on the company's work helping promote the study's interactive text messaging program and other similar digital campaigns.Q. Please discuss the study featured on Nature.com, examining one regional health system's digital campaign for vaccinations.A. I'm excited to see texting capabilities receiving attention for their powerful ability to drive health engagements.

We've seen similar results as the findings in the study with AVIA members who have implemented text and chat solutions in order to increase their patients' participation in their health journey.One of the primary areas where we see the power of texting is through providing ongoing and personalized nudging capabilities, tailoring the messaging to the patient. We can shift the message, language and frequency of text communications to best motivate patients to take action.Texting also brings a level of urgency we haven't seen through sending emails and making phone calls. Ninety percent of text messages are read within 90 seconds, drastically increasing the likelihood that the consumer will see, respond and interact with the communication.Q. What is the value of digital campaigns when it comes to efforts like vaccination?.

A. Digital campaigns are foundational to increasing the reach and accessibility of public health initiatives, including vaccination. Ninety-seven percent of adults in the U.S. Can send and receive texts through their phone, making it one of the best ways to reach a wide audience.

They also can be received and read, even if a consumer doesn't have access to a smartphone or reliable internet.The additional advantage with digital campaigns is they can be easily personalized to the audience's context, including language preferences and incorporating cultural sensitivities in the content.Q. Why have interactive text messaging and other similar digital campaigns proven effective?. A. Text messaging and chatbots have transformed the way that health systems interact with their patients, and vice versa.

Seventy-eight percent of consumers say they want the ability to text with businesses, and consumers are 82% more likely to convert to a patient through texting, rather than calling or filling out a form. The patient demand and the business case for texting are clear.Health systems are leaning into texting and similar digital campaigns because it allows patients to interact with the health system on their terms. Texts also can provide comprehensive education capabilities, as health systems are using SMS to send relevant snippets of educational content to patients.Additionally, text and chat digital solutions give health systems the ability to see who has read and responded to their messages, making it easy to provide targeted follow-ups and reminders when necessary.Text messaging also has proven effective in a variety of other areas, including scheduling and rescheduling appointments, sending appointment reminders and registration information, and filling in gaps in care with preventative care and wellness reminders.Q. What should healthcare provider organization CIOs and other health IT leaders be doing now to help with the country's effort to get more people vaccinated?.

A. Health system leaders must consider how digital can help them engage with unreached populations. Digital, especially texting, can be a powerful tool to reach and motivate patients to get vaccinated.Health systems can start by creating digital campaigns focused on educating patients and clarifying any misconceptions a community has about vaccination. Texts and other digital tools can also be personalized based on the target population to ensure the messaging fits in their cultural context and health literacy levels.Twitter.

@SiwickiHealthITEmail the writer. Bsiwicki@himss.orgHealthcare IT News is a HIMSS Media publication..

Representatives from can i get propecia without a prescription the Veterans Administration faced concerns from legislators this past week around patient-safety issues associated with the agency's Cerner electronic health record modernization initiative. "At the end of the day, this whole undertaking is about improving patient care," said Rep. Debbie Wasserman Schultz, D-Fla., in a House Appropriations Military can i get propecia without a prescription Construction, Veterans Affairs, and Related Agencies Subcommittee hearing on Thursday. WHY IT MATTERS Wasserman Schultz noted that the VA's first rollout of its new EHR took place one year ago this month, at Mann-Grandstaff VA Medical Center in Spokane, Washington. The VA can i get propecia without a prescription had initially planned to go live at 11 sites by the end of 2021.

"At this point, VA is more than one year behind their initial schedule," said Wasserman Schultz. She cited complaints can i get propecia without a prescription from staff and local legislators, particularly those about patient-safety issues. "While there have been no reports of patient harm – thank God – at Mann-Grandstaff, this is not a concern to be taken lightly," she said. Wasserman Schultz also flagged issues around funding, including findings from the Office of Inspector can i get propecia without a prescription General that the estimates of project costs had fallen short by billions. She called a revised estimate time line "problematic." VA Deputy Secretary Donald Remy took a determined stance, assuring legislators that he was taking responsibility for the program's progress.

"The success or failure can i get propecia without a prescription of any program boils down to a partnership," he said. "Our handling of EHRM to date has failed to live up to this program's promise for our veterans and our providers," he continued. "Regardless of what happened before, and regardless of how long I've been here, can i get propecia without a prescription I'm here now," he said. "I promise I'll be accountable to you and collaborate with you as we move forward." He said the VA is learning from its implementation mistakes. That the Cerner system can i get propecia without a prescription works.

And that the agency is bringing together all relevant internal and external stakeholders. "I can i get propecia without a prescription appreciate your enthusiasm," said Wasserman Schultz. "But we really need to go beyond enthusiasm." Remy explained that the agency has organized patient safety concerns into several domains, such as order management, administration of medicine, pharmacy, suicide risk, tracking and documentation, identity, referrals and consults, roles, positions, privileges, and ambulatory care When concerns arise, Remy said, the agency categorizes them, examines them and "makes sure they don't reoccur." "OK, but really. How did this happen? can i get propecia without a prescription. " Wasserman Schultz said.

"What, specifically, are you doing to prevent this in can i get propecia without a prescription the future?. " Remy said it's a matter of evaluation, training and putting protective processes in place, using a multidisciplinary team. "Specifically, these teams are monitoring our clinical workflows to make sure that the integration process of EHR and what our clinicians are doing is not can i get propecia without a prescription interfering with their ability to care for their patients properly," he said. He reiterated that the agency still intends to meet its ten-year rollout time frame, but said the agency could not yet provide a specific time line for it.Still, Wasserman Schultz said she required more information. "I can appreciate that you inherited can i get propecia without a prescription a mess, and that you are in the middle of sorting through the morass, but unfortunately your … responses to our questions about patient safety really aren't detailed enough," she said, especially regarding how issues happened, and how the agency planned to fix them.

When it came to prioritizing cybersecurity, Remy said the agency recognized the need for interoperability between the new and legacy programs, while ensuring information remains protected. "Cybersecurity is a clear part can i get propecia without a prescription of our priorities," he said.Still, legislators sounded the alarm that an enterprise-wide strategy had not been put forward yet."It's so critical that we get going. This isn't a 'nice to have.' We're already seeing these cyber intrusions in every aspect of our lives," said Rep. Vicente Gonzalez, can i get propecia without a prescription D-Texas. "It's only a matter of time before the VA becomes the next target." Wasserman Schultz proposed more frequent hearings – including one specifically on patient safety, and perhaps on a monthly basis – to ensure comprehensive information sharing.

She also hinted that the appropriations committee might find it difficult to justify continuing to set funding aside for the project without specifics about how can i get propecia without a prescription it will be spent. "There's nothing better than direct communication … with a good, old-fashioned hearing with members," she said. "I'll be praying for you," said Rep. John "Judge" Carter, can i get propecia without a prescription R-Texas. "Because we need to get this done right." "It is a cumulative mess of multiple administrations," added Wasserman Schultz.

"Help us can i get propecia without a prescription help you, Mr. Secretary." THE LARGER TRENDThe VA has continued to face legislative scrutiny about the EHR modernization program, particularly following the release of numerous OIG reports about the initiative. But despite the setbacks, the agency has continued to push forward, most recently allocating $134 million to Cerner to continue deploying the EHR and turning to a third party to analyze the true cost of the project.ON THE RECORD "The secretary has tasked me with building exactly that type of partnership on electronic health record implementation – to create a platform that seamlessly delivers the best access and outcomes for our vets and the best experience for our clinicians and providers, can i get propecia without a prescription and that's exactly what I'm going to do," said the VA's Remy during the hearing. Kat Jercich is senior editor of Healthcare IT News.Twitter. @kjercichEmail.

Kjercich@himss.orgHealthcare IT News is a HIMSS Media publication.Concentra is a Texas-based healthcare organization that serves the occupational health needs of one in four injured employees through 517 medical centers across the country, another 150 clinics at employer locations, and telemedicine.THE PROBLEMConcentra has seen telemedicine as a much-needed additional option for the delivery of care. It implemented the first model via kiosks, piloted with a single employer. It learned a lot of valuable information from the pilot – namely that the kiosk system was not scalable. The healthcare organization knew there could be a more cost-effective and efficient way to deliver virtual care."I joined Concentra in June 2017. Just before, I was a long-term Concentra client as vice president of risk management/claims for Macy's," said Ann Schnure, vice president of telemedicine at Concentra.

"I wanted our retail organization to be a beta tester of Concentra's telemedicine program and was very interested in telemedicine as a way to increase access to care."I was thrilled to have the opportunity to join Concentra and lead our efforts to develop and implement a telemedicine solution that would provide high value to employers and their employees."Before she joined the organization, Concentra had explored many software solutions. The first live telemedicine visit was in June 2017."Flexible workflows right out of the box and support of our multi-patient group waiting room – these are key to our efficient workflow, and allow us to focus our clinicians on the delivery of patient care."Ann Schnure, Concentra"Across about two years we saw steady growth in our program and maintained a continuous learning process to enhance this patient care delivery modality for our client organizations," she recalled. "But we also hit some significant barriers with too many clicks-to-visit and additional challenges."Then we learned of vendor eVisit's virtual care platform, which met our crucial criteria to fix these challenges and more. We made our purchase decision in 2019 and launched eVisit in 2020."PROPOSALWhen Concentra started with eVisit, it was to address a video visit plug-in situation. But as the organization has continued to work with the vendor, the platform and team have become a longer-term solution."We knew it had rich end-to-end functionality, but what was so great for us in our occupational telemedicine workflows was its flexibility, its integration layer, ease of use, and tools like the scheduling tool and the platform's sophisticated reporting features, including real-time reports," Schnure said."Specifically, for our largest customers, connecting to the video visit is seamless – no plug-in required," she continued.

"And for the patient clicks-to-visit, we have brought that from 27 down to about eight clicks, and that's a direct reflection of the ease of use of eVisit."The Concentra Telemed offering offers a group waiting room with care coordinators who can see the multiple patients and their status. It also features multiple hand-offs to providers and back-to-care coordinators. It's a complicated virtual workflow and somewhat unique to occupational care. The platform enables this workflow seamlessly, she added."Our clinicians' time is maximized – our aim is to have clinicians focus 100% of their time on delivering patient care, and in our virtualized workflow they spend very little time on administrative tasks," she explained. "We have objectives for service and know in real time if we are meeting our service standards because the eVisit system allows us to track everything we need to have visibility against our goals and metrics."MARKETPLACEThere is a wide variety of companies providing telemedicine technologies and services on the marketplace today.

Healthcare IT News published a special report detailing these companies and their offerings. Click here to access the special report.MEETING THE CHALLENGEThe initial challenge was to find a system with seamless video connection, no plug-ins, and just a few clicks-to-visits for patients. What Concentra found in the platform were many features that allowed it to optimize and expand its telemedicine solution. Under a continuous improvement model, Concentra routinely is finding value and efficiencies.A dedicated Concentra Telemed staff of 40-plus individuals serving virtual care patient needs with all clinicians who have a user profile and the ability to conduct a visit use the system."Flexible workflows right out of the box and support of our multi-patient group waiting room – these are key to our efficient workflow and allow us to focus our clinicians on the delivery of patient care," Schnure noted. "The scheduling tool allows our care coordinators to send patients a link and all they need to do is click it to get into the visit.

The charting tool is used to very effectively prep for second visits where we are reviewing labs or imagery."The eAnalyze tool is a sophisticated reporting system that tracks data we need to manage our telemedicine program – from patient wait times in the waiting room, virtual visits completed/canceled, provider usage and tasks performed, and more," she continued. "This feature delivers up-to-the-minute real-time data. It's very useful for many reasons, but mostly to help us gain insights into where we can improve and make efficiencies."RESULTSFollowing are successes Schnure reports through using the new telemedicine system:Clicks to visit. Through efficiencies and ease of use of the technology, the organization got patient clicks from 27 down to 8 clicks to the visit.Real-time accurate reporting helps Concentra do better and address issues. Before, it did manual reporting, knitting together disparate spreadsheets of data.

It was not fast, effective nor comprehensive. Now the organization has comprehensive reporting in real time across the entire platform, which allows staff to:Improve staffing modelsImmediately address cancellations – they can see the reason for the cancellation immediately. Staff can address that same-day within minutes and get back on track with that patient and the scheduleTraining – if staff are seeing a care coordinator who is very efficient, they have modeled that and trained others to be more efficient and effectiveHelps with quality auditsReduced no-shows by 10%ADVICE FOR OTHERS"Carefully evaluate the video portion of the platform," Schnure advised her peers. "In many cases, the SaaS provider outsources that element of the platform, and they aren't experts on that piece of the technology. The video visit is important and connects the patient to the clinician.

Also, ask about average click-to-visit stats and patient satisfaction metrics."Be careful with telemedicine platforms that come with D2C provider networks," she added. "Ask questions like, Do you provide patient care directly through the platform?. And if so, what percentage of your company's revenue comes from providing these healthcare services?. "In Schnure's experience, they often are their own biggest customer and those technology providers tend to make technology development decisions based on their D2C models, and a client's technical requests may not be heard."There are hundreds of solutions out there, and telemedicine is moving at a rapid rate," she noted. "If a technology provider hasn't made any changes or enhancements to their platform over the past 18 months, that may be a concern."Find a partner with a vision of telemedicine that aligns with yours," she continued.

"Look for partners who can power your telemedicine strategies and have flexible workflows, integration capabilities and sophisticated reporting functionality."Many healthcare organizations have unique telemedicine needs when it comes to how to implement the technology, and it's important that a healthcare organization pick a technology vendor that is flexible and listens to distinct needs, goals, strategies and requirements, she concluded.Twitter. @SiwickiHealthITEmail the writer. Bsiwicki@himss.orgHealthcare IT News is a HIMSS Media publication.The plans include introducing digital systems for healthcare organisations which have not previously used them, restocking and updating old technology, improving cybersecurity and expanding the use of shared digital care records.This much-needed cash is part of the government’s so-called levelling-up agenda, which will be beneficial for all regions in the UK.WHY IT MATTERSThe extra investment in IT and data services to create digital patient records is part of the government’s plans to speed up working practices in the NHS and free up valuable time for health workers.There will be support for around 100 'one-stop-shop' community diagnostic centres across England, to assist those waiting for clinical tests such as MRIs, uasounds and CT scans.One in 10 trusts still operate on “paper-based systems” according to Health and social care secretary, Sajid Javid. NHS trusts have been seeking an additional £1.8 billion per year by 2024, which would take the overall NHS capital budget to £10.3 billion.Figures released earlier this month showed GPs were also facing record demand with 24 million appointments taking place – above pre-propecia levels.Greater use of technology has meant that some 1.25 million texts and 300,000 emails were sent to parents of two and three-year-olds informing them of booking appointments for hair loss treatment jab for their children.THE LARGER CONTEXTIn total, the chancellor is expected to announce an increase of £5 billion in the health service’s capital budget. This will go towards the government’s pledge of building 48 new hospitals by 2030 and a comprehensive programme of hospital upgrades.The funds will also aid the NHS in tackling backlogs caused by the hair loss treatment propecia.

Specifically, to address millions of patients waiting for diagnostic tests and non-emergency operations.As part of the £3 billion “skills revolution”, Sunak is expected to announce a number of “boot camps” for skills including cybersecurity and artificial intelligence.ON THE RECORD“Any significant budget allocated towards the digitisation of healthcare services is positive. However, we must always remember this is a long term journey so a single budget is not enough but needs to be sustained instead,” Dr Saif F Abed, director of Cybersecurity Advisory Services told Healthcare IT News.“In terms of where the money should go I think we need to be pragmatic. Investments need to be made in people and process improvements - as well as technology itself. €œElectronic medical records, enhanced interoperability, capacity management platforms and clinical decision support tools are prime candidates here. We must also remember that accelerated digitisation presents tremendous risks from a cyber-crime perspective too so it is critical that a sizeable budget is allocated for investments in cybersecurity skills and solutions from national to local levels.”The U.S.

Cybersecurity and Infrastructure Security Agency announced this week that it had issued a first-of-its kind $2 million award to two organizations developing cyber workforce training programs. NPower and CyberWarrior will use the money to address the cybersecurity workforce shortage around the country, said the agency. "CISA is dedicated to recruiting and training individuals from all areas and all backgrounds with the aptitude and attitude to succeed in this exciting field," said CISA Director Jen Easterly in a statement. "It’s not just the right thing to do. It’s the smart thing to do – for the mission and the country," Easterly said.

WHY IT MATTERS CyberWarrior and NPower will collaborate with the agency to develop a three-year pilot program aimed at benefiting populations that may not have access to cybersecurity training – such as unemployed and underemployed people, and underserved communities in urban and rural areas.The program aims to. Develop and implement a comprehensive cybersecurity pathways retention strategyDeliver entry-level cybersecurity training through innovative training hubsProvide hands-on and professional development experience through apprenticeshipsPlace talented individuals into entry-level cybersecurity jobs "CyberWarrior is honored to take part in the Cybersecurity Workforce Development and Training Pilot for Underserved Communities,” said CyberWarrior Foundation founder Reinier Moquete. "Working with CISA and other stakeholders, our 28-week bootcamp program will train persons from underserved populations for a career in cybersecurity," Moquete continued. "NPower’s cybersecurity program offers young adults and veterans the opportunity to advance their careers and deepen their specialties. This is particularly important for individuals coming from underrepresented communities that systemically lack access to those specialized skills," said Bertina Ceccarelli, CEO of NPower.

"We are honored for the support from CISA, which will enable NPower to expand our reach to trainees across the country," added Ceccarelli. THE LARGER TREND In the face of escalating ransomware attacks on critical infrastructure – including hospitals and health networks – the federal government has ramped up its defense efforts. This summer, President Joe Biden issued a memo formally establishing the Industrial Control System Cybersecurity Initiative and directing agencies to develop cybersecurity performance goals for infrastructure. Legislators have also introduced several bills aimed at beefing up organizations' cyber muscles. And the private sector has stepped in too.

Earlier this month, Google announced the launch of its Cybersecurity Action Team, aimed at guiding customers through the cycle of security transformation. ON THE RECORD "We’re best positioned to solve the cyber challenges facing our nation when we have a diverse range of thought bringing every perspective to the problem," said CISA's Easterly in a statement. Kat Jercich is senior editor of Healthcare IT News.Twitter. @kjercichEmail. Kjercich@himss.orgHealthcare IT News is a HIMSS Media publication.As communities across the nation seek new ways to bring hair loss treatment vaccination rates up to levels that can more effectively mitigate the spread of variants, they are looking for new and better ways to reach those who are just hesitant, undecided or unaware of how to get vaccinated.A study of one regional health system's digital campaign found that sending interactive text messages increased vaccinations rates by more than 4%, in this case by using "psychological ownership" techniques designed to make the message receiver think of the treatment shot as "theirs."In an interview with Healthcare IT News, Sonia Singh, senior vice president of consumerism at AVIA Health, a digital health company, sheds light into this concept and explains the value of digital campaigns.

She draws on the company's work helping promote the study's interactive text messaging program and other similar digital campaigns.Q. Please discuss the study featured on Nature.com, examining one regional health system's digital campaign for vaccinations.A. I'm excited to see texting capabilities receiving attention for their powerful ability to drive health engagements. We've seen similar results as the findings in the study with AVIA members who have implemented text and chat solutions in order to increase their patients' participation in their health journey.One of the primary areas where we see the power of texting is through providing ongoing and personalized nudging capabilities, tailoring the messaging to the patient. We can shift the message, language and frequency of text communications to best motivate patients to take action.Texting also brings a level of urgency we haven't seen through sending emails and making phone calls.

Ninety percent of text messages are read within 90 seconds, drastically increasing the likelihood that the consumer will see, respond and interact with the communication.Q. What is the value of digital campaigns when it comes to efforts like vaccination?. A. Digital campaigns are foundational to increasing the reach and accessibility of public health initiatives, including vaccination. Ninety-seven percent of adults in the U.S.

Can send and receive texts through their phone, making it one of the best ways to reach a wide audience. They also can be received and read, even if a consumer doesn't have access to a smartphone or reliable internet.The additional advantage with digital campaigns is they can be easily personalized to the audience's context, including language preferences and incorporating cultural sensitivities in the content.Q. Why have interactive text messaging and other similar digital campaigns proven effective?. A. Text messaging and chatbots have transformed the way that health systems interact with their patients, and vice versa.

Seventy-eight percent of consumers say they want the ability to text with businesses, and consumers are 82% more likely to convert to a patient through texting, rather than calling or filling out a form. The patient demand and the business case for texting are clear.Health systems are leaning into texting and similar digital campaigns because it allows patients to interact with the health system on their terms. Texts also can provide comprehensive education capabilities, as health systems are using SMS to send relevant snippets of educational content to patients.Additionally, text and chat digital solutions give health systems the ability to see who has read and responded to their messages, making it easy to provide targeted follow-ups and reminders when necessary.Text messaging also has proven effective in a variety of other areas, including scheduling and rescheduling appointments, sending appointment reminders and registration information, and filling in gaps in care with preventative care and wellness reminders.Q. What should healthcare provider organization CIOs and other health IT leaders be doing now to help with the country's effort to get more people vaccinated?. A.

Health system leaders must consider how digital can help them engage with unreached populations. Digital, especially texting, can be a powerful tool to reach and motivate patients to get vaccinated.Health systems can start by creating digital campaigns focused on educating patients and clarifying any misconceptions a community has about vaccination. Texts and other digital tools can also be personalized based on the target population to ensure the messaging fits in their cultural context and health literacy levels.Twitter. @SiwickiHealthITEmail the writer. Bsiwicki@himss.orgHealthcare IT News is a HIMSS Media publication..

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They attribute patients’ rejection of psychological and behavioural interventions, such as cognitive–behavioural therapy (CBT) and graded exercise therapy (GET), to a ‘paradox’ resulting from a supposed failure to acknowledge that ‘there is no good objective evidence of bodily disease’. In response, we explain that understandings about the causes of long term effects of propecia and treatments for medical complaints have shifted across centuries, and that conditions once thought to be ‘psychosomatic’ have later been determined to have physiological causes. We also note that Sharpe and Greco do not disclose that leading scientists and physicians believe that ME/CFS is a biomedical disease, and that numerous experts, not just patients, have rejected the research underlying the CBT/GET treatment approach. In conclusion, we remind investigators that medical classifications are always subject to revision based on subsequent research, and we therefore call for more humility before declaring categorically that patients are experiencing ‘illness without disease’.health policypublic healthmedical humanities.

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In response, we explain that understandings can i get propecia without a prescription about the causes of and treatments for medical complaints have shifted across centuries, and that conditions once thought to be ‘psychosomatic’ have later been determined to have physiological causes. We also note that Sharpe and Greco do not disclose that leading scientists and physicians believe that ME/CFS is a biomedical disease, and that numerous experts, not just patients, have rejected the research underlying the CBT/GET treatment approach. In conclusion, we remind investigators that medical classifications are always subject to revision based on subsequent research, and we therefore call for more humility before declaring categorically that patients are experiencing ‘illness without disease’.health policypublic healthmedical humanities.