Jim St. Clair, XBRL on the new Frontier: Integrated Reporting in Healthcare
Over on Hitachi Data Interactive Blog
Standardisation, regulation and recovery of the financial industry
by Alexandre Kech, https://www.swiftcommunity.net/communities/49/blogDetail/20931
Since the outburst of the crisis and its resurgence these days, politics, journalists and people in general request that there be more regulation of the financial industry. Without taking a stand on whether it should or should not be the case, I am convinced that standardisation of communication and identification protocols has a major role to play in helping the financial industry regain some of its lost credibility.
The use of communication standards such as ISO 20022 or identification standards such as ISO 9362 Business Identifier Code (BIC) or ISO 10383 Market Identifier Code (MIC) increases the transparency of data.
The adoption of these ISO standards for all financial communication would enable the transport of standardised data in compliance with standardised processes not subject to interpretation nor manipulation by the bad guys of the industry.
It would enable the creation of international or local reporting facilities usable by any regulators and allow market data to be exchanged in an efficient way among them. The current use of proprietary standards is inefficient and costly.
Martin Sexton, Director of IT at London Market Systems Ltd, once advocated in a mondovisone article regarding MiFID : “Realistically, the only way to ensure that one has achieved this [provide evidence that they have achieved 'best execution' for their clients] and met the directives requirement of market transparency is by the use of industry standards.” I cannot agree more. This is true for any need for transparency.
There is no doubt in my mind that if the whole industry was (forced?) to adopt ISO standards, the industry would save hundreds of millions of EUR or USD (same thing, nowadays, no?) in recurring maintenance costs of messaging and integration platforms and equivalence tables for static data. And you can add a few hundred millions spent on losses due to bad quality non-standard data, on staffing used for manual repair or rekeying of transactions, on implementation and testing (and maintenance) of proprietary standards to connect to “international standards disabled” market infrastructures. You just need to have worked a few years in operations or discussed with implementers to realise it.
Lillian Tham, Chief Operating Officer at Schroders was saying exactly that at a recent SWIFT event: “The only way to decrease our fixed cost infrastructure is to standardise internally and externally.” ISO 20022 is the response to this.
The issue is that those costs are spread across many years and are invisible to short term focused shareholders. They only see the cost of implementing the standards, though a fraction of the profit of most financial institutions last year (a difficult year, it was). And this cost perception issue is not an easy one to overcome these days.
Following the adoption of ISO 15022 by global custodians and ICSDs in the dawning of the 21st century, all were able to focus on what is essential; the quality and diversity of the services they offer. It has also became easier for customers to switch from one provider to another. It did remove some of the stickiness of the services some custodians were offering but if they did indeed lose clients, they also won clients. You will find nobody in the global custody business to say that their adoption of ISO standards was a mistake. If it worked for the global custodians, why wouldn’t it work for the whole financial industry, CSDs, CCPs, trading venues, etc? ISO standards will bring their full potential only if implemented by most or all of the Industry. In some cases, partial implementation can sometimes be more costly than no implementation at all.
Alistaire Milne, Senior Lecturer in Banking and Finance (Cass Business School), starts his paper on Standards and competition in post-trade securities processing by: “Standard setting in securities settlement is not just about lowering processing costs and improving cross-border interoperability, it is also a central determinant of competition in central counterparty clearing, in securities settlement, and in associated services, such as securities custody and the management of securities transactions.” I cannot agree more.
For those who would argue that ISO standards are not flexible enough to enable innovation and therefore competition based on better and new services, I would reply that it has been too long since they have looked at an ISO standards. ISO standards, nowadays, have built-in extension mechanism and other features to enable the necessary innovation and competition to take place without jeopardising the need for transparent and standardised financial communication. Most ISO identification standards such as MIC or BIC are updated on a monthly basis, some faster.
Once you have spent some time and money on optimising processes through standardisation, you have the tool box you need for a longstanding, robust recovery and for growth.
You have tools to prevent such a crisis through an effective and fair control of the industry.
You have the tools to enable investment in markets that standards finally made accessible in a cost effective way.
You have all your need for a financial industry at the service of the economy (its historical role). You can quote me on that one.
In another life, I was in the door-to-door selling business. You know what? I kind of liked it (for a short while…) because I believed in the product I was selling. It is the same for ISO standards. The last 10 years, I have been market-to-market selling ISO 15022, ISO 20022 and others. I like it because I am convinced that the standardisation of the financial industry is the key to many of the issues to which it is confronted.
It is not for nothing that so many international or local players such as Target 2, Target 2 for Securities, Jasdec, DTCC, Euroclear, Clearstream, Strate... decided to speak ISO. Global custodians, I have already mentioned, do not need any more convincing.
It is not for nothing that most banks use ISO 9162 BIC as a way to identify themselves globally, that internet uses ISO 3166 for identifying countries, that treasurers use ISO 4217 for identifying currency codes, etc. It is because it brings value, efficiency and cost reduction.
So whenever someone proposes to you a communication or identification protocol, if it is not ISO, say you are not interested and have them call us.
Input on Tennessee's Strategic and Operational plans for Health Information Exchange
From: Dean Flener
Subject: For Public Comment
The Office of e-Health Initiatives would like your input on Tennessee's Strategic and Operational plans for Health Information Exchange. These documents describe Tennessee’s plan to increase the adoption and use of health information technology and health information services among health care providers. The Office of e-Health’s Strategic and Operational plans aim to create a patient-centered health care system with the primary goal of enabling secure access to electronic health care information Click the links below to download and view the documents:
Tennessee's Operational Plan for HIE https://bit.ly/ckUeJw
Tennessee's Strategic Plan for HIE https://bit.ly/9hhapO
Instructions for sharing your comments:
1) E-mail your comments to [email protected].
2) You may share your comments as narrative in e-mail or as an attachment to an e-mail message.
3) Please include your first name, last name and organization name. We’re sorry but if this information is not included, we will not be able to consider your comment for response.
4) Please indicate the page number(s) and paragraph(s) where proposed edits or comments should be considered.
5) All comments are due by noon CDT on Friday, May 21, 2010.
6) If you have questions, please e-mail [email protected] After we review and respond to the received public comments, we will post a compiled list of the comments on the Office of e-Health website, https://www.tn.gov/ehealth and to the Listserv. If you know others in our state who would be interested in providing public comment on Tennessee’s Strategic and Operational plans for Health Information Exchange, please forward this message to them. We want to hear from as many Tennesseans as possible.
Georgia Automated Clearing House Association 2010 Solutions Request for Speaking Proposals
Jessica Jane Rios twitter.com/jtrundley would love to hear something on medical banking
Miller-McCune’s recent SWIFT articles
SWIFT and American Espionage By Michael Scott Moore –> Europe’s newly empowered Parliament’s first muscle flex involves privacy and tracking terrorist finances.
The New Trans-Atlantic SWIFT Agreement By Michael Scott Moore –> Will it give European intelligence agencies access to U.S. banking records?
Anyone Noticing A Trend?
A quarter of office workers would steal sensitive company data if they thought it would help a friend or family member secure a job, says Cyber-Ark Software.
More Than Half of Fired Employees Steal Data
Most fired workers steal data on way out the door, survey shows
Report: 88 Percent of IT Workers Would Steal Data If Fired
Comment Period Closing on Proposed Rule for Medicare and Medicaid EHR Incentive Program/Meaningful Us
As part of the HITECH Act in 2009, The Centers for Medicare & Medicaid Services (CMS) administers the Electronic Health Record (EHR) incentive programs under Medicare and Medicaid. CMS prepared a proposed rule on the EHR incentive programs for public comment. This proposed rule includes the definition of meaningful use and other requirements for qualifying for incentive payments.
The comment period for this proposed rule closes on March 15, 2010. CMS welcomes your comments which may be submitted through https://www.regulations.gov. For additional information on the proposed rule, visit https://www.cms.hhs.gov/Recovery/11_HealthIT.asp on the Web. Here you will find fact sheets, presentation materials summarizing the proposed rule, and links to the proposed rule itself.
Very Helpful Folks at HIMSS10 Meet the Bloggers Session #3
Twitpic by Brian Ahier
Cesar Torres, Manager, All Things Webbie, Healthcare Information and Management Systems Society, has a thread on linkedin.com asking for follow on thoughts about HIMSS10 in general. Here are some responses:
Gwen Darling, HealthcareITCentral.com [Healthcare Informatics magazine]:
Why is the XBRL community so disinterested in the Medical Banking space?
Posted by ED
From "Designing the Healthcare Financial Network of the Future" By John Casillas
The U.S. healthcare system represents some $2.5 trillion annually and growing. Hidden within the cost of the infrastructure are the diversity of methods used to manage money and associated remittance data. Incremental advances in this area could result in systemic savings across the healthcare stakeholders. While existing regulations under the Health Insurance Portability and Accountability Act (HIPAA or “the Act”) recognize the value of this critical area (as specified in the Administrative Simplification provisions of the Act), the advancement of industry-wide and systemic programs, best practices and standards to capture this value have proven remarkably tedious and slow to implement.
A good example of unrealized value in this area is the comparative cost to transfer funds and remittance data in other industry segments (an area called ‘financial electronic data interchange’ or ‘FEDI’), at $5 more or less, versus a cost of $11 per payment or more in healthcare (Banker’s EDI Council, 1994). Extrapolation of this data suggests that the healthcare industry could save $35 billion annually by implementing electronic payments, inclusive of the ability to trigger workflow automation across the complex healthcare revenue cycle, like automating contractual allowances, denial management, contract management and more (Casillas, 2001). More recently, a new “Healthcare Efficiency Index” estimates a $30 billion savings could be attained by making improvements that include this vital area (see https://www.save30billion.com )
[ED: XBRL as a technology could hasten John's predictions but nobody seems interested in the slightest. If I'm wrong please see https://www.mbproject.org/8MBI2010.php ]
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Paul Wilkinson, CEO at paulwilkinson.com responds:
Perhaps the same challenge we had implementing XBRL in the financial reporting sector is part of the answer: those $30 billion or $35 billion or whatever "savings" aren't really savings if you're the one billing companies for those monies today -- whether you're an outsourced firm or someone in the internal department responsible for your large and important existing business process. One person's "savings" are another person's "losings." Therefore, there's not just plain old fear, uncertainty and doubt to address -- there are strong incentives for many current market participants to paint change as "high risk," tell their customers and their employers there are more important priorities, and that they should "let other people go first" with all of this scary technology stuff.
With such a large health information ecosystem, and so many long-term information technology contracts and projects already in place, and many of the unnecessary costs being paid and managed by non-profits or by people who believe their main purpose in life is helping patients, not promoting efficiency, it probably shouldn't be a surprise that innovative energies devoted to the ultimate mission of improving medicine are directed more at improving treatments and less at improving how the back office works.
Also, HHS apparently has yet to fully realize that it could do exactly what the FDIC and SEC did and simply mandate the use of an open technology standard like XBRL. In fact, XBRL would be a good standard for lots of health related data. Automated data validation and low- or no-cost software upgrades via taxonomy updates and access to the existing XBRL technology infrastructure would all be wonderful in the health sector. Heck, the FDIC and the SEC have already laid the foundation for the necessary cost/benefit analysis, and despite all the FUD, found the benefits to exceed the costs. But those $30 billion or $35 billion losers are sure to explain to HHS and everyone else who will listen to them in painful detail every reason they can conceive why an open technology standard would be a bad idea and why they should move s l o w l y.
The good news is that on my last trip to DC, I met some new HHS people who understand this and who are quietly leading to do the right thing -- and this is from someone who spent 16 years in DC working for leaders of what today is the minority party. And more good news is that market pressures always prevail, even if they don't do so as quickly as we like. Someone will find a value proposition for an open technology standard. I've been working with https://www.cloudinc.org -- looking at ways to avoid reinventing perfectly good technologies that XBRL has already developed and offering a new value proposition: A domain that's based not on a particular industry, but on the end user -- people.