January 11, 2013 1:09 PM
Posted by: AllinHIT
, EHR adoption
, health insurance exchange
In this post-presidential election year, there has been a lot of talk about HIEs: both health information exchanges and health insurance exchanges, though insurance exchanges are often referred to as HIXs in order to avoid confusion. States are discussing and developing information and insurance exchanges for two separate reasons.
As we know, October 2013 is the deadline for states to provide consumers with a health information exchange plan. The Affordable Care Act (“Obamacare”) requires all 50 states to provide health information exchanges. These exchanges will serve as marketplaces for residents without health insure to acquire it.
At the same time, health industry pundits are aware that state governments, eligible physicians (EPs) and eligible hospitals (EHs), through public and/or private partnerships, are creating – or attempting to create – health information exchanges for sharing patient health data. Sharing patient information is a crucial component in the re-design of our health delivery system. Access to patient records at point of care will be crucial for lowering cost of care, especially considering the millions of patients coming into the system post Obamacare. Additionally, sharing patient records plays a vital role in meeting Medicare requirements (think Meaningful Use) and commercial payers pay-for-performance programs. Its importance is reflected in the stage 2 meaningful use requirement: sending an electronic “summary care record” (Continuity of Care Document or Record etc.) for 10% of patients when referring and/or transferring their care has now moved from a menu item to a core requirement! I suspect the stage 3 meaningful use requirement for this measure will increase drastically, increasing the need for health information exchange.
Although the aforementioned exchanges are completely separate state efforts, both share the HIE acronym. However, these exchanges should be sharing much more than the same abbreviation! They should be sharing information and resources!
Insurance exchanges should have an element of health information exchange. First, let’s approach this from a practical and real-world perspective and say consumers will access these insurance exchanges annually (open enrollment), and thus could potentially move from one insurance provider to another. In that scenario, consumers, payers and primary care physicians (PCPs) would theoretically love the ability to exchange patient personal health information for seamless continuance of care. Understandably, another way of getting this done would be with the patient’s PCP EHR system, possibly via a CCR/CCD record. However, that would require too many interfaces to individual systems and would exclude payer specific information. Though not a perfect “mirror” of data, each separate silo can almost serve as a redundant system of the other.
Another point for collaboration: both insurance and information exchanges can share resources, possibly lowering the cost of their development. For example, both entities can share the cost of creating one master patient index solution, since both serve the exact same population! Additionally, they can share knowledge pertaining to governance and technologies, and share the state’s most valuable resource, state employees involved in each project!
Both these efforts would best serve their particular state, being developed with mutual collaboration, an integrated mindset, similar timelines, and associated milestones, in a perfect, utopian alignment of the stars. If not, the fear of wasted resources, budget overruns, ineffective technologies, and operational inefficiencies will be justified.
December 17, 2012 1:21 PM
Posted by: AllinHIT
Health IT adoption
, Health IT market
, Sandy Hook
Like most Americans, I am mourning the tragic deaths of the 20 children and six adults at Sandy Hook Elementary. I heard their stories, prayed, and listened to the President’s speech during his visit there. His words stating “we must change” (meaning the USA must change to prevent these ghastly occurrences) resonated with me. I thought about putting the politics aside and recognizing the need for changing with the times. We all know times have changed with the growth of these catastrophes. The health IT industry and our delivery system also must change.
Changes in the industry are illustrated by the number of the uninsured and the out of control cost of health care. Is health IT the answer? Its importance cannot be understated, though it is not the complete solution. Health IT will be the foundation for delivering better individualized care. The old adage “information is power” is applicable to improving the provided care. Informatics, health information exchanges (HIEs), and personal health information access for patient emergency and episodic care are perfect examples of information that can be applied to improve care. I know I’m preaching to the choir and I’m happy our system is already changing. HITECH deserves credit as the driver of health IT adoption and building the foundation to access of health information. The most crucial change agents are people!
I applaud you, the people, as we close another year of EHR implementations, meaningful use attestation, HIE discussions, while simultaneously delivering care to an aging, increasingly obese society. As is often said, “change is hard”, and this can easily apply to changing workflows, documenting notes differently, dashboarding, quality measures, and delivery methods. However, I see us moving forward with change! I just hope and pray the same for addressing tragedies like Sandy Hook.
December 13, 2012 2:49 PM
Posted by: AllinHIT
My wife once told me my brain gets bored easily, and to some degree, I must confess she is right (notice I said “to some degree”!) I believe her observation is directly related to why I love all things health IT. I keep my mind occupied with the rapid pace of health IT adoption, workflow re-engineering, informatics, meaningful use stages and comment periods. I also follow payer-related initiatives like ICD-10, accountable care organizations (ACOs) and health information exchanges (HIEs), mHealth, and of course, keeping pace with EpicCare EMR. The aforementioned topics, what I call the “full breadth of health IT”, satisfy my inquisitive nature. Recently, I’ve been focused on getting my Epic Ambulatory Certification. I’ve been ignoring my emails, other publications and material on other aspects of health IT. I’ve truly missed the full breadth of health IT in doing so, but it has given me a consulting blueprint for 2013.
My decision to focus mainly on Epic was huge, after years of being a vendor agnostic consultant. In a way, it was a shift in implementation strategies; from implementations with independent physicians to implementing with hospitals. I knew how important it was to include strategic planning into your EHR decision because I was a consultant. A consultant needs knowledge in HIEs, ACOs, and other care delivery models.
My breadth of health IT knowledge will serve my Epic clients well, especially after receiving my Epic Ambulatory Certification. What makes a really good consultant is the value-add that the client receives and didn’t expect, as I’ve often told other consultants. I will be able to use my industry knowledge and experience, combined with my Epic certification and building experience to deliver a better client solution. I don’t plan on missing the full breadth of health IT anymore, but applying it in an “epic” way.
November 14, 2012 1:56 AM
Posted by: AllinHIT
, meaningful use stage 3
I had the pleasure of educating physician practices in Florida on HITECH during its early stages, and the “how to” for selecting and implementing EHR’s. These dinner seminars, sponsored by Quest Diagnostics, were prior to any final rules established for any stages of meaningful use, though just mentioning meaningful use emanated loud chatter instantaneously. The chatter has since subsided due to checks being cut and received. I expect to hear hear even less chatter from physicians when the stage 3 rules are finalized, after reading The Office of the National Coordinator for Health Information Technology (ONC) HIT Policy Committee’s meaningful use stage 3 draft, which was released for comments on Nov. 7.
Why even less chatter? The quick answer is there are less core measures to comply with, and more of the same measures physicians have already adopted in their workflow. For example, recording demographics and smoking attestations are “retired” due to reaching the 80% threshold. There are some new measures, as most industry pundits expected, and they involve care coordination, using health IT to support new delivery models, supporting and exchanging information for population health, and engaging patients.
The new draft can be downloaded from The Centers for Medicare and Medicaid Services’ (CMS) website, so I won’t address each issue. However, I would like to address a few interesting items in the draft. Some in our industry have been discussing a possible stage 4, based on earlier proposed/final rules and comment periods. In the beginning of the draft CMS explains there is a new column called “future stages” and it contains measures that are under consideration for stage 3 and they would like opinions on those measures. Does that mean there could be a possible stage 4?
There is also consideration of giving partial credit to those that do not meet all of MU criteria and possibly giving out partial payments. My favorite new measure is one that requires eligible providers and eligible hospitals to communicate with 20% of patients on how they want the provider to communicate about their care. Finally, we are asking the the patient as the most valued stakeholder, how they want to communicate versus proposing measures that require a provider to electronically communicate with patients.
These, for now, are just draft items. They can easily go from draft to proposed to final, based upon your comments and others in our industry. CMS has been great in responding with feedback, so what are you waiting for?
October 31, 2012 11:18 PM
Posted by: AllinHIT
I love to write, but sometimes words just aren’t enough. Sometimes words don’t capture the emotion, and its emotion that can sometimes change the world. I don’t mean to expose this philosophical thought emanating from my emotional being. However, when there are people in New York, New Jersey, and Connecticut without water and food who have lost all of their possessions, and some who have lost their lives, writing this blog seems so trivial. This calamity, also known as “Sandy”, is a natural disaster with no equal, and I believe in the end, will be the most costly. Sandy has sent our society an old message, which we should act upon.
This same message has been delivered to us from other storms, like Irene, Charley, Hugo, and many others. However, it seems the message is being delivered to an empty mailbox. What is this message? The message is disasters will come, and disaster recovery is a must and should be acted upon now if a business is to continue operations. I touched on disaster recovery a little a few weeks ago. I talked a little about disaster recovery, although, it wasn’t really the point of the blog.
Coincidentally, it isn’t with this blog either. What I want to do here is remind physicians that these disasters are a real reason to implement EHRs, in the spirit of those of those who’ve lost everything. Victims of these disasters have lost everything including their medical records, child immunizations, and other pertinent information. Some of these victims will sadly and reluctantly relocate to other areas, cities, and possibly states as a result of this misfortune. The ability to get all of their medical records would be a small comfort at a time when a small comfort is big.
Let us all pray for these victims!
October 26, 2012 4:38 PM
Posted by: AllinHIT
, Venture Capital
In 1995, I co-founded the Orange County Business Incubator, the first public/private incubator program in the Florida. The purpose of the program was to help small businesses develop, grow and succeed. Incubators, much like accelerators, provide early-staged firms services they typically can’t afford like class A office space, legal and tax services, business development, and most importantly, funding. The difference in the two terms is that incubators typically assist early staged firms, whereas accelerators focus their resources with firms on the verge of growth that need to accelerate their growth. I believe accelerators must also cater to firms with intellectual properties, in a growth market. Hence, the firm’s “acceleration” is timed with the market, taking full advantage of the opportunity. Market timing is so very important (just think about the early adopters of e-commerce, especially online shopping sites).
So, I was very happy to read about a new accelerator program, the New York Digital Health Accelerator. NYDHA is a partnership between the Partnership for New York City Fund and the New York eHealth Collaborative, and will be one of the largest in terms of creating jobs and in providing venture capital funding. This is great news to the those firms that are accepted in the program and better news for the New York community. The purpose of both incubators and accelerators is to increase the employment and tax base for their communities. The program will create approximately 300 jobs per year for the next five years, according to NYDHA, which is a lofty goal but not unrealistic when considering all the factors. The main factor is health IT has been the hottest industry since 2010, and its expected to get even hotter. , There are many areas that will guarantee that it remains the hottest industry in the USA for years to come such as meaningful Use, ICD-10, accountable care organizations(ACOs)/patient centered medical homes (PCMHs), population health, quality vs. fee for service, and the snowball effect of keeping baby boomers healthy. The time for accelerators in health IT is now, and I’m not talking about incubation!
October 9, 2012 7:13 AM
Posted by: AllinHIT
I developed a disaster recovery plan for a local municipal in Texas while working as an executive consultant with Navigant. I learned about the varying degrees of redundancy and preparations (i.e. infrastructure like switches & point-of-presence (POP), mobile communications, mirroring servers, hot site locations, call lists, and backup devices). The manual that explained all of the downtime procedures was one of the most important items. It offered many lessons for any organization, department, or individual to continue operations and was filled with procedures and valuable communication protocols.
Human communication and a paper process is key to having downtime procedures work, I was recently reminded. I was providing Epic support to a group of dedicated and bright physicians. There wasn’t a clear workflow for a particular, life-threatening and rare, patient care event where efficiency was the difference between life and death. Orders needed to be written despite limited demographic information, which can pose challenges to the system if there is no clear workflow. I asked the magic question, “What did or would you do under your old system in this scenario?” when presented with the issue by my team of consultants. Making calls to pharmacy for needed drugs, manual orders and inked signatures, and physician and nurses working together side by side communicating needs was their answer. Hence, we implemented those procedures using the newly-written Epic downtime procedure manual.
In the end, I witnessed the power of just “plain ole communicating”, reminding me of the term “plain ole telephone” or POTS to the telecom industry. It showed a team working together to efficiently save a life. Nothing was done electronically, although we did go back and update the system. I got to see downtime procedures being implemented, exposing the imperfections of my electronic world. In a strange way, it made my day and I never thought downtime procedures would lift me up!
September 29, 2012 5:52 PM
Posted by: AllinHIT
, Coding and documentation
, EHR fraud and abuse
, Fraud and abuse
, Medicare fraud and abuse
HHS chief Kathleen Sebelius, and Attorney General Eric Holder, recently sent a letter to five hospital organizations –the American Hospital Association (AHA), Federation of American Hospitals (FHA), Association of Academic Health Centers (AAHC), Association of American Medical Colleges (AAMC) and the National Association of Public Hospitals and Health Systems (NAPH) — warning that their EHR should not be used to game the system when billing CMS.
My first thought was that hospitals should heed the warning. The Obama administration has been very diligent in exposing Medicare fraud, probably more than any other administration in U.S. history. It was announced last week that Recovery Audit Contractor (RAC), Connolly, will be conducting extensive audits on CPT 99215 (a level five office visit), much to the chagrin of the AMA. My second thought was these audits, and the warning of audits associated with EHR use could penalize physicians for honest mistakes during implementation. The warning is a mistake chasing a mistake!
I’ve seen many instances where the physician has keyed in the wrong code, as an Epic trainer and go-live consultant. Capturing the N2 billing code when it should have been the E2 billing code for an established patient is one example. Of course, the N2 code (new patient, service level 2), is at a higher reimbursement. These are honest, unintentional mistakes that are very common during implementation and beyond. This warning will only increase the wait times physicians are already dealing with during implementation. Don’t get me wrong, I do understand that fraudulent intent is possible with some practices, and the government must address these issues. However, I’m at odds with the timing and the approach. Hence, I have a couple of suggestions for HHS/CMS/ONC.
My first suggestion has to do with the approach. Extending a hand to assist hospitals with billing more accurately with their EHR is a better approach than warning these five organizations. This approach reflects a supportive role in solving the issue of inaccurate billing, versus a punitive role in a criminal and fraudulent billing. There is a huge difference between the two, the latter represents a threatening tone, whereas the former reflects collaborative one. Mock audits for hospitals should be done on a volunteer basis once the right approach has been established. This would accomplish two things; 1) It would be a real assessment of the hospital’s exposure, allowing them to implement corrective action and develop best practices. 2) It would give CMS an idea of the most common mistakes made with EHR billing. This is just a few suggestions, out of many. I’m certain that the AHA, FHA, AAHC, AAMC and the NAPH also have a few!
September 23, 2012 9:11 PM
Posted by: AllinHIT
I believe CMS/ONC deserves credit for being flexible and listening to stakeholder’s concerns, regardless of criticisms associated with programs birthed from HITECH, including MU rules and future proposed rules. Time and again fluidity has been shown, whether it’s MU requirements, or ICD-10 deadlines. The ONC announced the “rules of the road” regulations for the nationwide health information network (NwHIN), will be dropped (I believe “suspended” is more likely!). The community felt these rules were a barrier to adoption when they were announced in May, so it just took 5 months for them to reconsider. Vendors, state HIEs, and others will be more inclined to connect due to the demise of these regulations, increasing PHI’s portability.
I read the “support VA’s Blue Button speech” given by Farzad Mostashari, MD, the national health IT coordinator, during HealthIT week. He makes a great case! The Blue Button Initiative, created by the Veterans Administration, has more than 1 million veterans participating, creating a noticeable trove of PHI. The number of Blue Buttons participants will steadily increase, especially after the iEHR integration project between the VA’s and Department of Defense.
Finally, technology vendors are also jumping on the bandwagon towards connectivity. Epic and Surescripts’ recent announcement of connecting Epic Everywhere to Surescripts Network for Clinical Interoperability, is a perfect example of connectivity. Epic has over 150 million patient records, representing 44% of the population! This announcement will have a huge effect on access and portability due to Epic’s standing as one of the fastest growing EHR vendors post-HITECH. I have also read that some health plans are considering their own “Blue Button”.
CMS and vendor efforts are vibrant due to stage 2 meaningful use rules. Health IT benefits will snowball the sooner we move towards collaborative health and data informatics/analytics. After all, we know separate silos are unacceptable. Soon, I hope and pray, these public/private efforts will provide true connectivity instead of being just a thought in motion.