There is no neutral position on fraud!

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This is a review of the 2011 article, “There is no neutral position on fraud.” by Donald W. Simborg.


With visions of widespread adoption of Electronic Health Records (EHRs) amongst the Office of the National Coordinator for Health Information Technology (ONC), an advisory panel recommended proactive fraud management functions be embedded in the infrastructure in 2005. Fast forward to 2011, and the ONC leadership has still not taken action to prevent or minimize fraud and the responsibility of fraud remains with the Centers for Medicare and Medicaid Services (CMS), the Office of the Inspector General (OIG), and the Department of Justice (DOJ). Although Congress, CMS, OIG, and DOJ are expressing concerns and investing in reducing fraud, the department that sets the standards for EHRs, ONC, is remaining neutral and not doing anything to prevent or minimize fraud at this time. [1]

What could ONC do to prevent and minimize fraud

There are many things that ONC could implement to reduce the threat of fraud, like establishing guidelines for use of EHR tools. Certification requirements could be implemented to certify not only that services are performed properly, but also to ensure illegal services are not performed. Better standards could be defined for the collection of metadata. Lastly but not least penalties such as decertification should be threatened to those vendors who fail to eliminate illegitimate use of their EHR systems and more money should be appointed to the research of EHR and Health IT fraud.


This was a short and sweet article. While the article basis is centered around EHR fraud, the point of the article was the lack of involvement by the direct organization that regulates and sets the standards for EHRs, the ONC. I believe if you fast forward to today, you would see that the ONC, CMS, OIG, and DOJ have made significant improvement from when this article was written, as this article is a little outdated. What I enjoyed about the article was how it capture fraud, what’s being done to prevent and minimize, what’s not being done, and what could be done.


  1. Donald W. Simborg. 2011. There is no neutral position on fraud.