Today is picture day at my daughter’s daycare. In my unbiased opinion, she will be the most photogenic and adorable child present, partly due to genetics, but also partly due to the outfit my wife picked out for her last weekend at Ridgedale Mall.

I was along for the ride during this mission, and when I wasn’t checking my phone for fantasy football updates, I was giving nods of approval for the various outfits my wife considered. We were in some sort of chic designer clothing store catered to parents of infants and toddlers, so pretty much every outfit looked to be picture-day ready. We aren’t normally the type of parents to shop in such stores, but again: picture day. Out-of-state grandparents demand satisfaction.

When the decision was made, I had a conversation with the cashier that made me think about direct marketing, and how the quest for personal data seems to have become a never-ending struggle between retailers and consumers.

Cashier: Is that all for you today?

Me: Yes, thank you.

Cashier: OK, what is your email address?

Me: No, thank you.

Cashier: No problem. What is your phone number?

Me: No, thank you.

Cashier: OK. Are you a member of our rewards program?

Me: No, thank you.

And so on. Eventually I was able to hand over a credit card, take my item and leave the store. But the whole experience just left me slightly irritated. It’s not that I haven’t been through that song and dance before – indeed, nearly every retailer these days requests the same personal data if you so much as pop in for a pack of gum.

Now, I work in marketing and public relations. I get it. Customer loyalty programs are great for generating repeat business and showing appreciation for reliable patrons. Phone numbers lead to addresses which lead to direct mail offers. These campaigns can be successful, else they wouldn’t be so prevalent (more so all the time, it seems). But we don’t even have a land line. Our cell numbers won’t provide an address, and we certainly don’t want to receive offers via text message. Is there a risk that eventually there will be pushback from consumers? A polite “no, thank you” isn’t a big deal, but three or four for a single transaction, times many transactions over time add up and, if you’re like me, it sours the experience. Customers want to get in, out and on with their busy lives. The personal nature of the requests can be off-putting. Customer lists are sometimes sold to third parties leading to a greater supply of junk mail.

Retailers generally have to market to survive, and I’m not advocating they stop doing so. What I would suggest is smarter, more personal marketing that avoids holding up, or even badgering, every customer at the point-of-purchase. Also, a little employee communications coaching can go a long way. Instead of “What is your email address”, opt for a softer approach. “Would you like to provide an email so we can send you exclusive offers?” It’s more courteous, it’s transparent, and it becomes a two-way opt-in process.

Point-of-purchase data mining isn’t likely to go away any time soon. A few tweaks to the way retailers go about handling the process though could result in a better response rates, higher levels of trust, and in my case, less annoyed customers.

Regardless, I still can’t wait to see how the pictures turn out.

In many ways, September 11, 2001 feels like it was yesterday. In other ways, it feels like a distant nightmare where you may struggle to not dwell on it too much as the tears might come too fast. Who can forget the shock, devastation and heartbreak for all the countless lives lost? Yet, in spite of this unparalleled feeling of loss, hope remains.

The 9/11 Memorial opens today, September 12, 2011 after a special dedication for families of the victims on September 11. If you don’t have plans to visit New York in the near future, a quick visit to its website is certainly worth a trip.

http://www.911memorial.org/

We will not forget.

As the new Congressional Debt Reduction Super Committee prepares to meet next month to cut government spending by $1.2 trillion over the next decade, supporters of the Health Information Technology for Economic and Clinical Health Act (HITECH) are marshaling various arguments for preserving the electronic health records (EHR) incentive program. EHRs save money and improve outcomes. HITECH has bi-partisan support. Doctors and hospitals are purchasing EHR systems, diverting staff time and changing workflows under the belief that HITECH incentive dollars will eventually reimburse them for their initial investments of time and money.

These are all sound arguments that should be highlighted, but perhaps the most compelling case to be made to members of the Super Committee is that HITECH is helping create jobs.

Barring a war or other cataclysmic event, the results of the 2012 election will be closely tied to unemployment. Recent polls show that the public considers jobs to be the number one issue on which the President and Congress should be focused. Neither Democrats nor Republicans receive high marks on the issue from likely voters so both sides will be especially attentive to job creation this fall.

Washington’s renewed focus on jobs provides yet another opportunity for the HITECH program to show its worth. Talk to anyone in the health information technology (HIT) industry and they will share an anecdote about their company’s aggressive hiring or the dearth of qualified candidates to fill openings. Significant HIT job growth is surely happening, but unfortunately, there does not appear to be any hard data to support these anecdotes.

The most often cited figure is contained in a section of the 2010-2011 Occupational Outlook Handbook issued by the Bureau of Labor Statistics (BLS). In their Outlook, BLS sees job prospects for Medical Record and Health Information Technicians growing faster than average (20%) and estimates that 35,000 new jobs will be added by 2018. Last week, Computer Economics, an IT research and advisory firm, revealed that 61 percent of health care organizations plan to increase IT staff in 2011. In testimony before a House Small Business Subcommittee in early June, the National Coordinator for Health Information Technology, Farzad Mostashari, pointed to the fact that 60% of the HIT products certified as of early June had been developed at firms with 50 employees or fewer, suggesting that HITECH dollars were spurring job creation among small businesses.

Dr. Mostashari’s testimony illustrates this lack of hard data on job creation. Besides citing the BLS outlook, he said the following in his written testimony:

“Other sources suggest that many jobs are being created among private sector firms that install and maintain EHR systems for providers. The software and tech industries are also adding jobs as more EHR products are developed and hardware is manufactured. Our experience suggests that many jobs are being created among private sector firms that install and maintain EHR systems for providers.”

The Office of the National Coordinator should seek out these ‘other sources’ to provide more detail and data on job creation. Similarly, the American Medical Association and American Hospital Association may have figures to share on HIT job growth in large practice groups and hospitals. HIMSS should consider surveying its membership to gauge the pace of job growth in the industry between 2009 and the present. At a minimum, the upcoming HIMSS Policy Summit in mid-September provides an excellent opportunity to collect additional anecdotes and testimonials about job growth in the HIT sector.

With the public seeking answers on both the debt and jobs, members of the Super Committee will be hard pressed to cut any program that can demonstrate cost savings in the long run and job creation in the near term. There are already numerous studies to demonstrate the enormous cost savings EHR adoption will generate over the long term. If the HIT industry can also present solid data illustrating HITECH’s job-creating power, supporters of the EHR incentive program should be able to sleep soundly this fall.

I remember being in elementary school and visiting the fire department. During the tour, the fire chief discussed several things but what I remember most were his words about how every home should have multiple fire extinguishers; that each family should have an evacuation plan; the importance of the “stop, drop and roll”; and that every bedroom on a second floor should have a portable ladder in its closet.  Learning to “stop, drop and roll” was certainly easy and appeared to be a no-brainer, but I remember being mortified when I got home armed with all of this new knowledge and expertise to discover that my parents not only didn’t have portable ladders (I had a second-floor bedroom), but there was nary a fire extinguisher in the house or any kind of evacuation plan – discussed or written. It all seemed so irresponsible despite being what appeared to be such an obvious and fundamental need.

This same sentiment can be applied to businesses – big or small – when they find themselves in an unlikely situation where internal and external communication must be managed delicately. While the majority of large corporations and businesses have plans in place to address potential conflicts or adverse issues, there are still plenty of companies that don’t.

Termed crisis communication plans, these well thought-out processes and steps can be just as critical to a business as an evacuation plan would be to a family dealing with a fire in the middle of the night. A crisis communications plan is often the Holy Grail for business owners that need a strict and formal guide to light the way for how they are to deal with their situation – step by step – during what would most likely be a very tense time when emotions run high.

Plans should be as comprehensive as possible and include employee designations, contingency plans and prepared statements (which can be modified if necessary). Author Otto Lerbinger wrote in his book “The Crisis Manager” that there are at least seven different crisis categories that can either be considered acts of nature or human error. Preparing for both is necessary and in today’s communications realm, social media will also require a significant focus. While this endeavor will require a concerted effort and a lot of time, the payoff is invaluable. While some crises are much more dramatic than others, developing a plan that considers the situations with the most potential, can save a company valuable resources, not the least of which is its reputation.

As the fire chief once said, having an evacuation plan will make all the difference should your house catch on fire.

As advertisers continue to flock to Facebook, many are wondering if Google+ has the makings of a solid competitor to the world’s top social networking site. Whether Google+ will become a successful social media service with a dedicated user base remains to be seen. However, in the one month since its launch one thing has become apparent: this is no Facebook killer. Here’s why.

Engagement Overload

You’re on Facebook. Probably a majority of the people you know are on Facebook. The site has over 750 million users, many of whom check the site constantly. LinkedIn continues to gain influence. Not to mention Twitter, Tumblr, FourSquare and countless other social platforms that integrate these big hitters into their sharing options (Xbox LIVE, for example). How many people do you think are eager to manage yet another online profile? Especially when everyone that’s on Google+ is already on Facebook. Eventually, social media saturation is reached and choices must be made.

In addition, participation within these networks generally involves posting detailed personal information: birth date, email, phone number, political views, location, etc. At what point will users shy away from giving this information to yet another corporation?

You’re Already Hooked

Business blogger and fellow skeptic Mark Schafer points out on his blog {grow} that, “…Facebook may be entrenched as the king of social networking sites for a long time because the emotional and psychological cost of switching to something else is too high.”

Exactly. Those that check in and update their Facebook profile regularly have built up tremendous loyalty to the service, whether they realize it or not. It’s not uncommon for today’s college students and recent grads to have over 1,000 friends on Facebook. Many have dozens of photo albums. Starting over would be no simple task. On the flip side, the older generation is still cautiously dipping its toes in the Facebook waters. To many of them, Google+ remains foreign altogether. Consider this invitation to Google+ I posted recently:

My Facebook friend is not exactly an early adopter. Now we expect Grandpa to begin using Circles and Sparks?

Social Segmentation

Speaking of Circles, this feature is a key differentiator. Essentially it takes one’s “friends list” a step further, allowing the user to segregate contacts into specific groups, then interact with each group as they please. It’s a feature that many have requested of Facebook as friend lists have evolved to include more coworkers and family members. And certainly having more control over one’s message is a positive thing. But it also has potential drawbacks, like requiring more effort to manage, the potential for user mistakes and the knowledge that you could be in someone’s circle titled “Jerks I Ignore”. (One does not have the ability to see what others have named their circles, or who is in them.)

No Third-Party Support

At least, not yet. Facebook embraced third-party development, which brought a new level of interactivity and innovation to the site. Farmville and Mafia Wars are just two hugely popular examples of what third-party support can bring.

From Math to Social Science

Can a company that knows algorithms and search technology also strike gold with social networking? It’s the same question many asked at the launch of Google Wave (and what a debacle that turned out to be!)

Paul Adams is a former Google employee that joined Facebook shortly before the launch of Google+. He recently felt the need to clarify a few things about his departure from Google, and described his frustrations this way: “Google is an engineering company, and as a researcher or designer, it’s very difficult to have your voice heard at a strategic level. Ultimately I felt that although my research formed a cornerstone of the Google social strategy, and I had correctly predicted how other products in the market would play out, I wasn’t being listened to when it came to executing that strategy. My peers listened intently, but persuading the leadership was a losing battle. Google values technology, not social science.” [emphasis added]

On the Plus Side

Still, despite a plethora of obstacles, it’s foolish to count Google out entirely over the long term. The company is flush with cash, employs many brilliant minds, and is already one of the world’s best-known brands. Millions of people use the company’s variety of products such as Gmail, YouTube, Picasa, Maps and of course the search engine itself.

Google+ does have some very good things going for it, too. “Hangouts” are video web chats that allow up to ten participants at once. Unlike Facebook and Twitter, one can edit their posts after publishing. And simply by not being Facebook, a certain segment will be eager to give it a try.

Google execs are referring to Google+ as a “project,” not a product. Eventually it will be open to everyone, not just those who have received an invitation. Currently the network does not support advertising, although we can expect that to change at some point. But judging from what I’ve seen so far, Facebook doesn’t have much reason to be worried.

Up until the passage of the HITECH Act in 2009, electronic health records (EHR) were largely unregulated, with adoption rates among providers not significant enough to warrant government oversight. CMS’ final rule defining the Stage 1 ‘Meaningful Use’ criteria was the first widespread federal effort to control the implementation and use of EHRs. Given the financial commitment the federal government is making to wire the U.S. health care system, and the critical role EHRs will play in streamlining care and assisting in clinical decision-making, future regulatory oversight of health information technology (HIT) promises to be both rigorous and widespread.

While exact roles still need to be defined, there will be at least three federal agencies exercising some level of regulatory jurisdiction over EHRs.

Through the EHR Incentive program and the Meaningful Use criteria, the Center for Medicare and Medicaid Services (CMS) will play a hands-on role in the use of EHR systems through this decade. Though the final stage of the EHR Incentive program will occur in 2015, Medicaid providers have a much longer glide path to adoption and could conceivably receive incentive payments up until 2021. Even after incentive dollars cease to flow, CMS can still control behavior by levying penalties on providers and hospitals (in the form of lower reimbursements) who have not become meaningful users.

CMS is also beginning to build a foundation for oversight by including EHR-related requirements and mandates in other programs. For example, the recently released Notice of Proposed Rulemaking (NPRM) on the Medicare Shared Savings Program requires that at least 50% of an Accountable Care Organization’s (ACO) providers be meaningful users of HIT. The NPRM also requires an ACO’s infrastructure to include shared clinical decision support capabilities, and to report the percentage of their providers who use CDS.

The prospect of regulatory oversight by the Food and Drug Administration (FDA) has caused many a sleepless night for HIT vendors, who fear their product development efforts will suffer from the same filings, trials and delays the pharmaceutical and medical device industries have experienced. The FDA has already stated publicly that health information technology falls within its jurisdiction. The only question remaining is whether select HIT products will be labeled as Class III devices, subject to pre-market approval before being rolled out to doctors and hospitals. The HIT Industry received positive news (relatively speaking) in February when the FDA released a rule on Medical Device Data Systems, determining that these would be treated as Class I devices only, requiring registration, quality manufacturing practices and reporting of adverse events, but stopping short of pre-market approval. The FDA has recently indicated that it will regulate mobile medical applications that will run on smart phones, tablets and other hand-held devices, with specific guidance to be released later this year. Further definition of the FDA’s role may also be forthcoming this fall when the Institute of Medicine releases a report on HIT and patient safety.

A relative newcomer to the federal regulation scene, the Office of the National Coordinator for Health Information Technology (ONC) is already overseeing the EHR certification and standards setting processes that support the EHR Incentive program. As health information technology becomes more ingrained in other programs (i.e. ACOs, Medical Homes) as well as the default method for CMS quality reporting, look for ONC to continue providing certification for HIT functionality so doctors and hospitals can rest assured the new systems and modules they purchase meet government guidelines. Similarly the emphasis on health information exchange to foster care coordination will require ONC to continually update and articulate new data exchange standards. ONC’s future regulatory role will be further defined (and likely expanded) in the upcoming NPRM on Governance of the National Health Information Network.

Other federal agencies and offices will also play roles in overseeing or influencing HIT policy, including the National Institute for Standards and Technology (NIST) and HHS’ Office of Civil Rights (OCR). NIST will continue to work with ONC on testing procedures and scripts used in the certification process. OCR will focus on safeguarding personal health information that is more widely accessible through the use of HIT. OCR’s recent NPRM updating the Health Insurance Portability and Accountability Act (HIPAA) with new accounting of disclosures rules is just one example of their work in HIT.

And this is just the feds. In a future post, I’ll explore the possible role states will play in regulating health information technology.

The digitization of the American health care system began earlier this year with the launch of the Health Information Technology and Economic Health (HITECH) incentive program. Eligible providers and hospitals who install certified electronic health record (EHR) systems and use them in a meaningful way will receive incentive payments from the federal government to help defray the cost of the installation. The program could cost as much as $30 billion over the next decade, fulfilling President Obama’s goal of having an electronic health record for every American by 2014.

As is typically the case with government programs of this scope and magnitude, HITECH is being implemented in stages.  Stage 1 was launched this past January. Stage 2 is set to follow in 2013 and Stage 3 two years later.  The HIT Policy Committee, a public private advisory council created by HITECH and tasked with the defining “meaningful use”, already has draft criteria for Stage 2 which were subjected to public comment in February. Though stakeholders generally supported the proposed criteria, many eligible providers, hospitals and HIT vendors complained that the January 2013 launch date for Stage 2 was much too aggressive.

Several options for delaying Stage 2 are currently being considered by the HIT Policy Committee’s Meaningful Use work group. The first would involve carrying over the 90-day reporting period from Stage 1 into Stage 2. Since doctors and hospitals would only have to be compliant on Stage 2 criteria for 90 days during 2013, they could effectively delay implementation 9 months until October 1^st. The second option would simply push the start date for Stage 2 to January 2014.  A third alternative is to split Stage 2 criteria into two groups: those that draw upon Stage 1 HIT functionality would launch on schedule; those that require new HIT functionality would be delayed until 2014.

Don’t expect the Centers for Medicare and Medicaid Services (CMS) to immediately embrace delay. An overly aggressive deadline is a common complaint heard by regulatory agencies. The critique on Stage 2 timing was loud but not universal, with consumer advocates strongly in favor of maintaining the current timelines. Even some doctors and hospitals support the 2013 launch. This past Friday in a hearing held by the Meaningful Use work group, representatives of a small physicians group in Wisconsin and a federally qualified health center in Washington DC both voiced support for the current HITECH timeline.

While maximizing HITECH payments represents a strong incentive for doctors and hospitals to implement Stage 2 on time, there is no penalty for failing to do so. Penalties in the form of reduced payments from Medicare do not begin until 2015. In lieu of delay, CMS may decide to scale back new Stage 2 criteria, particularly those that require new HIT functionality. And from a purely political standpoint, delaying a program is usually a signal that that program is not working. Neither President Obama nor HHS Secretary Sebelius want to send that message about HITECH, particularly during an election year.

Look for CMS to adhere to the current January 2013 launch for Stage 2 in the Notice of Proposed Rulemaking tentatively scheduled for release later this year. CMS loses nothing in proposing the current timeline in the NPRM and gauging stakeholder support or opposition for delay. By that time, more data will also be available on Stage 1 participation. Short of universal hue and cry in support of delay, and data showing unusually low participation in HITECH, the January 2013 launch of Stage 2 will most likely remain in place.

In the February issue of Upsize Magazine, Katy Tanghe writes about the importance of establishing key messages before conducting media outreach. Read the full article here.

The Sony public relations team finds itself in the midst of a very difficult situation these days.  Hackers have broken into the PlayStation Network, its digital media and online gaming delivery service, possibly stealing sensitive customer data. With 77 million users, this could be one of the largest data breaches in history. The entire network has been offline for 13 days (and counting) while Sony assesses the damage and improves its own security by rebuilding the entire network from the ground up. In the meantime, Sony is dealing with furious customers, a sliding stock, at least one class action lawsuit, and no shortage of bad press.

It doesn’t help that Sony waited until six days after the breach to warn that customer banking information may have been compromised. That’s an eternity, both in terms of credit theft and crisis communications.

The key to effective crisis communications is to have a plan in place that allows for swift communication in the event of an incident, even while the damage is still being surveyed. Otherwise the public impression is that the company is dragging its feet (regardless of whether scores of employees are working 80 hours per week to fix the problem). Communicating before the extent of the damage is fully understood is difficult and uncomfortable. But it’s still better than remaining silent while hoping the IT team doesn’t turn up anything else.

A pre-developed crisis communications plan identifies spokespeople, key publics and preferred mediums. It allows for swift, centralized responses that minimize rumors and address key concerns. Perhaps most importantly, it anticipates various crises and the best response methods for each. Naturally, some details have to be filled in later because every crisis is unique, but in the age of social media every hour saved is crucial.

The Sony communications team deserves some credit for its handling of the situation so far – the PlayStation blog has posted numerous updates and alerts over the past week. The company posted a formal statement detailing actions being taken. But by delaying its admission of the most damaging details (that user credit card data may have been compromised) for nearly a week, Sony made a bad situation even worse.