**American Health Information Community**

Consumer Empowerment Subcommittee, Department of Health & Human Services

Mary Switzer Building, Washington, DC

May 2, 2007

Testimony of

John Casillas, Founder and Executive Director

The Medical Banking Project

320 Main Street, Suite 230

Franklin, TN 37064

615.794.2009 - www.mbproject.org

Before my testimony, I want to thank this committee for inviting the
Medical Banking Project to speak about our movement, now global in
scope. I also want to publicly thank the members of MBProject,
representing a diverse constituency of banks and financial service
groups, healthcare providers and plans, IT and consulting firms,
automotive, entertainment and pharmaceutical firms, government agencies,
associations, academic health centers and non-profits who have dedicated
over 200 C-level executives to our work.

Today, I want to invite you on a journey -- a digital pathway to better
health. You know, one of my favorite movies growing up was *The Wizard
of Oz*. I loved the journey following "the yellow brick road" into a
land of imagination and fascination. We watched the Tin Man, who needed
a heart, the Lion who wanted Courage, and the Scare Crow who wanted a
brain. If ever there was need for these three things -- a heart, courage
and a brain full of wisdom -- now is the time as we face a broad and
deepening healthcare crisis in America. Now I'm no wizard, but I've been
on a journey for the past decade that I believe, in fact I'm positive,
will help to solve one of the most vexing problems our country has ever
faced -- **[universal access to quality healthcare at a reasonable
cost.]{.underline}**

Starting this journey in earnest in 1996, I coined the term "medical
banking" that is now in general industry use. That was 9 years before we
announced our membership program; 9 years of pushing the ball uphill
financially, intellectually and emotionally. I must admit, with
naysayers at almost every corner the journey was very lonely -- but not
anymore. When a major publication like *HealthLeaders* heralds *The
Banks Are Coming*, you know you're making great progress. So I'm sure
many are asking, why banks? In the short 15 minutes we have today I hope
to answer this for you.

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Our new journey comes packed with new terms like medical banking™, which
simply stated means using banking systems to improve healthcare. *Have
you ever noticed that sometimes when we try to solve a complex problem
the answer is right under our nose?* I believe medical banking is much
like that. Other industries have learned how to link EDI to streamline
end-to-end programs. The bank, central to the healthcare value chain,
can help us to do just that. New "inter-organizational systems" have
dramatically changed how we find and purchase airline tickets for
example. Today we go online and our options are numerous and increasing.
As the academic researchers have critically shown, what made this
convenience possible is the integration of banking and ticketing
systems. There's nothing more important to a sale than knowing for sure
that you've been paid. Its foundational for providing an ever increasing
array of consumer options.

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Likewise, we believe that **what will empower medical consumers** is the
integration of their pocket books with healthcare choices, through their
bank account. We call it the "health -- wealth" equation. Using
sophisticated tools, implemented in secure, consumer authenticated and
authorized online banking systems, where 55 million Americans pay their
bills everyday, you and I will be able to see, with the aid of our
family doctors, how our health conditions will affect us over time and
how much they will cost. These modeling programs will empower us to
strike a balance between how much we will likely pay for our healthcare
and how much we want to keep for retirement, and we'll even be able to
measure these costs throughout our lives. Equipped with sophisticated
identity proofing, the online banking platform will house our medical
and financial tool kits. Think of it as single sign on for the consumer.

Today banks own secure systems that link all the healthcare actors --
including consumers. In 2001, we jump-started the medical banking
industry by showing banks how to use this linkage to reduce transaction
processing costs in healthcare by \$35 billion annually. A recent survey
commissioned by PNC Bank showed that most hospitals would use these
savings, estimated at up to \$10 million dollars per year per facility,
to provide charity or indigent care. This is consistent with our guiding
mission to *convert digital savings into charitable resources*. Yet this
is just the first leg of the medical banking build out, as we move
forward to develop a secure, self-sustaining system for *On Demand
Personal Healthcare Records*. We view this effort as highly synergistic
with RHIOs and the new Health Record Banks.

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Now, sometimes we place the cart before the horse. In our race to
improve healthcare we think its important to keep at least two things
crystal clear: first is **[Public Trust]{.underline}**, the true
bellwether of our drive to empower consumers; and second is **[meeting
the challenge of the underserved]{.underline}** and in medical banking
this includes the **[unbanked]{.underline}**. Medical banking programs
address this critical area and also meet the needs of consumers to
access money and health records during times of man-made or natural
disaster through the banking system -- clearly a consumer empowerment
issue.

Now back to that cart analogy. The cart in our case is HIPAA. As you can
see with our HIPAA Wizard, we dressed him up a bit to debut Phase 1 of
our build out because most industries had a hard time embracing this
guy! Clearly, banks must embrace HIPAA before paving new eHealth
highways. That means that banks must comply with the highest medical
privacy rules in the land, as envisioned in the HIPAA regulations. For
four years, through multiple outreach venues in cooperation with CMS,
the Office of Civil Rights, privacy groups and others, we paved the
cornerstone of medical banking policy, which in two words -- **[Public
Trust]{.underline}** -- *represents what we must have to do anything in
this space*. Banks have it, and without it they simply fail. We should
realize that "just under our nose" is a banking system that routinely
spends billions of dollars **[in an identity theft arms
race]{.underline}** that keeps the bad guys away from your money, day in
and day out. It can keep the bad guys away from your health data too.

Banks have operationalized privacy and security in a comprehensive and
global way, everyday of the week. When you consider healthcare is just
getting started, we think *[not]{.underline}* using banking systems
could squander an historic opportunity in America. The sheer cost alone
is reason enough to look at what's lying right beneath our nose using
banks, not to mention the necessary operating experience. This isn't
just a technology issue.

So how will medical banking build a better mousetrap? Turning towards
Phase 2 of our movement, we needed to move the dialogue from HIPAA
compliance to interoperability, so we created the *"Great American
Interoperability Tour"*. This 14 month lecture series, picked up by
CNBC, provided sneak previews to 10 stakeholders of what banks can do.
It ended in our 2003 Institute, where three of the largest banks in
America publicly embraced HIPAA and announced they were moving ahead to
provide better tools for care providers, health plans and consumers. At
that moment, a new race was on. Today banks, in order to compete in the
medical banking world, have invested hundreds of millions of dollars
into healthcare IT. A new, non-traditional buyer is in town -- banks --
and they are providing funds that can **ramp providers onto a digital
ecosystem in healthcare**.

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We next announced our C.O.M.B.A.T. Initiative at the Vanderbilt Center
for Better Health to steer this new momentum. The acronym stands for
Cooperative Open-source Medical Banking Architecture & Technology, and
the mission is to combat the rising costs of healthcare using medical
banking. We are managing two pilots under the initiative. One helps the
doctor to know how much to bill an out-of-network patient at point of
service who presents with a High Deductible Health Plan. This is an
industry-wide critical path issue in consumer-driven healthcare, for it
allows care providers to calculate what the consumer owes at point of
service and bill accordingly, as opposed to shouldering this increasing
burden. The pilot was funded by Exante Financial Services and managed
pro-bono by Foresight Corp., PricewaterhouseCoopers, Sun Microsystems
and ACS. We organized two open meetings to kick off our work.

A second Pilot Program links the consumer to his/her healthcare records
through HIPAA-compliant online banking systems. Only bank members of
MBProject, who have been thoroughly indoctrinated with the HIPAA, are
working on this. We agree passionately with the privacy groups that a
Chinese firewall between the bank and your health data is a pivotal
element in building Public Trust.

Sometimes its important to move quickly, and that's why we announced
Phase 4 of our build out -- a *Common Medical Banking Platform* called
BoardTrust™. BoardTrust will literally hand-hold banks into this
fascinating new world we call medical banking by ramping them onto
standards, processes and operating agreements quickly and easily. It
will be directed by a Board of Governors, as we take our lead from the
Federal Reserve System. This body will be supported by at least two
Advisory Boards -- a Public Trust Advisory Board and a Technical
Advisory Board. These groups will keep our work focused on what's
happening on the ground in terms of privacy, security and consumer
protection. Under the leadership of our diverse membership, our venue
will help to ensure that the information families use to make decisions
will improve healthcare and is based on evidence-based medicine --
especially as more of that information is distributed through the online
banking platform.

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Many have joined our cause, including a new *Joint Taskgroup for Value
In Health*, that we formed with the 1600 employer strong Automotive
Industry Action Group. Together we're introducing value-driven
healthcare strategies into the medical banking model, and designing
employer programs that can motivate employees financially to live long
and healthy lives, managed by the local bank. Disney has been a constant
supporter of our work and has promoted MBProject to the Top 100
corporations in America. We also have a world class Advisory Board that
keeps us well informed.

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Our journey is just beginning and requires constant focus on
environmental factors. As you can see from this graph, *community
integration* of systems that were previously behind corporate walls
demands tight multi-domain integration. All of these systems are
accountable to the golden standard of Public Trust.

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To summarize, the medical banking journey has lead us to a new vision
for healthcare using a "Bank Infomediary". This intermediate market
structure is well positioned, extremely well financed and willing to
make large investments to improve healthcare. Its areas of focus
include: (1) improving administrative efficiency; (2) creating a highly
secure, patient authorized health data network; (3) delivering
healthcare tools to bank account holders to manage their health-wealth
equation; and (4) driving better coordination of community healthcare
through a program we call Charitable Communities Network™.

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To assist the medical banking journey we are asking AHIC to consider
three things. First, we invite you to engage a cross-industry dialogue
to ferret out policy issues. We often find ourselves on the defensive as
we try to coordinate policy in these established systems, (sort of like
a mouse dancing in between elephants), so that medical banking can
flourish as an industry strategy that empowers consumers. Second,
consider appointing a liaison for our electronic and personal healthcare
records pilot program. I'm sure you get thousands of request like this
but there's nothing wrong with wishful thinking in the Land of Oz!
Seriously, your involvement will help us to refine the model. And
finally, participate in our annual institutes where ONC, the National
Governors Association, Centers for Disease Control, former Pentagon
officials and many others participated, who have a sense that our
program can empower medical consumers in the emerging digital world.

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I hope this helps you to understand our work to support universal access
to quality healthcare at a reasonable cost using medical banking. Thank
you.