Health Information Privacy and Security measures in the Meaningful Use Stage 1

Privacy and Security continue to be on top of the HealthIT priority list.  And as some of the new measures associated with Meaningful Use Stage 2 open up Electronic Health Information to patients as well as health information Exchange qualified entities, many IT executives are gearing up for more steps to ensure future changes due to stage 2 will be met with the appropriate security measures.

Since the introduction of Meaningful Use through the Medicare and Medicaid EHR incentive Program, the HIPAA privacy and security rules were intentionally included in the program.  As part of meaningful Use Stage 1 there are two main measures as part of the requirements:

• Core Objective & Measure 126: Provide patients with an electronic copy of their health information, upon request.

More than 50 percent of all patients who request an electronic copy of their health information are provided it within three business days.

• Core Objective & Measure 157: Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities.

Conduct or review a security risk analysis in accordance with the requirements under the HIPAA Security Rule (45 CFR 164.308(a)(1) (ii) (A)) implement security updates as necessary and correct identified security deficiencies as part of the risk management process.

The National Institute of Standards and Technology developed a security toolkit application that is intended to assist health organizations understand the requirements of the HIPAA security rule and implement them (Click here).

In addition, the office of National Coordinator for Health information Technology made available some additional resources.  It has released a guide to privacy and security of health information that describes the process and details of the meaningful Use core measure 12 and 15 (Click here)

RFI released by the ONC on Governance of the Nationwide Health Information Network

On May 11^th, 2012 the ONC published Request for Information (RFI) on governance of the Nationwide Health Information Network (click here)

The ONC is seeking to develop a common set of rules to guide the development of a baseline “Rules of the Road”.  This comes after having an ad-hoc governance approach for the NWHIN that was the result of the work from contractual relationships, state, federal laws and other self-regulating principles.

Some of the key components available in the proposal are:

Adoption of “conditions for trusted exchange (CTE)”:

CTEs would reflect the nationwide health information network’s portfolio of standards, services and policies.  The initial set of CTEs has been included in the RFI.

Establishment of a voluntary framework for entities that facilitate electronic exchange to be validated to CTEs adopted for the electronic exchange services or activities they are capable of supporting:

This is a certification program similar to what the HIT certification done through the ONC.  Once an entity meets the requirements it would be considered a network-validated entity NVE.

Approaches for monitoring and transparent oversight:

This would create a mechanism that will ensure the protection of consumer rights by ensuring the NEs are performing their services adequately, and having a formal process to revoke an NVE’s validation status.

Establishment of processes that could be used to adopt, revise, and retire CTEs that are no longer appropriate.

Establishment of a process to classify the readiness for nationwide adoption and use of technical standards and implementation specifications to support interoperability related CTEs.

Currently the document has been posted in the federal register as a pre-publication PDF document.  It is scheduled to be officially available on May the 15^th, 2012.  The public period is open for 30 days after the publication date.

Home health services as a way to help reduce healthcare costs

Baby boomers have started reaching their retirement age in 2011, and with over 78 million of them as patients they will require care during their senior years.  Baby boomers are commonly known as the more self-reliant, gadget early adopters, and active individuals.  But with their high population number they are bound to put demand more from our health system.

In the current care delivery model we have today for senior citizens, nursing homes, hospital visits and assisted living are costly to both payers and patients.  And for that reason payers are looking to see what cost benefits would caring for patients at home and support their independences bring.

There are many reasons for the increase in demand for home health services and following is a short list to name a few:

Lower costs:  As patients are being treated at home, this alternate care location eliminates the costs associated with transport, and beds associated with charges inside a healthcare facility.

Telemedicine:  Baby boomers are known for being early adopters of technology and gadgets.  And with many of the capabilities of today’s electronic medical devices and smart phones, patients are able to remotely transmit data and have a care giver review it as part of their care. In addition, patients can even have access to a nurse and physician through video conferencing and be able to discuss their health issues from the comfort of their home.

Active life style:  As more baby boomers continue to enter retirement at a rate of 7,000 a day, many are continuing to stay active.  This most likely influences their decision to try to seek receiving care in the home instead of in a healthcare facility.

Technology:  In this area, we see that both patients and care providers benefiting from some of the technological advancements.  For home health service providers, mobile devices, and tablets have provided many much needed improved efficiencies.  Some of the examples are accessing records remotely, and transmitting information on the patient’s visit real time.

As we to see a shift toward keeping patients healthier and out of hospitals, it will become more critical for patients to receive care, participate in wellness programs and receive preventable care that can help ensure a healthier life.  Homecare services will play a significant role in helping patients with their health needs and keep healthcare costs down by reducing long/short term stays in nursing home and other assisted facilities.

Top considerations when planning on joining an HIE

More independent physicians are being solicited to connect to a community, local, or state HIE.  Since many of these entities have gone live in higher numbers this past year, and continue to see an increase especially due to the meaningful use stage 2 proposed ruling, physicians will continue to find themselves with several vendors and options from which to choose. Below are a few important areas of considerations for all providers taking the next steps forward in data exchange:

Connectivity with other existing community based (private HIEs) and state or national (NHIN):

One of the core components and purposes of an HIE is to provide continuous availability to medical records, enabling physicians to make better treatment decisions and deliver a higher quality of care in a more efficient manner.  When joining an HIE, providers must also consider what other entities the HIE can use to locate charts electronically.

Contracts:

When joining an HIE, a physician would be subscribing to the services that will be offered.  They will also be agreeing to local state laws around HIEs as well as specific liability and data security requirements set forth by the HIE. These contracts must be reviewed in great details, as they are very complex. The binding legal document will address privacy, security concerns, technical issues, as well as any obligations that maybe associated with early termination.

Usability of system and patient information:

There are several different methods of accessing a patient’s chart through an HIE.  One of the most commonly used and simplest method is via the HIE’s web portal which allows the physician to connect securely and perform record searches for patients.  This set up does not require any special software or interfacing to gain access to the record information.  Another access method that provides a seamless and common interface is through the use of physician’s EHR to request and process incoming patient’s summary chart.  This allows for some of the outside patient information to be combined with current physician’s patient records.  It is important to consider the connectivity model that can help create efficiencies for the organization, so both must be evaluated to ensure the right option is selected.

Value added services:

A great example of how some of the HIE are providing subscribers value added services is what a NC based HIE is doing.  CareConnect Carolinas a local HIE through Carolinas Health System is providing the following services:
·         Comprehensive medication list from SureScipts as well as many other local and national pharmacy networks.
·         Access to patient’s imaging records available through the hospital Information System
·         Access to Lab reports, Transcriptions, letter, Encounter details, Patient facesheet
·         Advanced alerting capabilities such as flags for drug seekers
·         Downloadable CCD (Continuity Care Document)
·         An EHR Lite to assist physicians with Meaningful Use
·         Referral management to digitize the information exchanged during the referral process
·         Web orders for certain labs at some of the health system facilities

There are other health systems that are also providing a PHR access feature for the patients.  This feature provides another method for the patient to be engaged and actively maintain their health record.  It also encourages up to date information even it is manually entered.

Pricing model:

Similar to many of the online subscription based services, HIEs fees are monthly.  Whether it is the physician or health system, they pay a reoccurring monthly fee for the length of the agreement. There is some setup fee associated with most and possibly additional third party charges when interfacing or integrating with an EHR.

Integration capabilities with existing system:

Not all HIEs provide integration with all EHR systems.  Ideally an HIE can provide a strong and tight integration with an EHR product and allow end users to simply use their electronic medical records application which they are already familiar with.  This will enable physicians to simply use the same application to manage patient charts as well as request medical records from an HIE.  But unfortunately, not all HIEs or EHRs allow for this integration.  So for some access to an HIE web portal that provides the ability to print/save the summary record is as far as the system will go.

With the proposed meaningful use stage 2, and 3 there is a stronger emphasis on the electronic exchange of medical records through a qualified Health Information Exchange.  And more physicians and organizations will begin to review some of the available HIEs in their community and state.

Medicare Proposed Payment Rule FY 2013

On April 24, 2012 CMS issued a proposed rule for the updated payment policy and rates for inpatients stays to general acute care hospitals paid under the hospital inpatient prospective payment system and long-term care hospital PPS (IPPS and LTCH) proposed rule for fiscal year 2013.

“The proposed rule would implement key elements of the Affordable Care Act’s value-based purchasing program as well as the hospital readmissions reduction program. It also establishes the groundwork for extending Medicare’s quality reporting programs beyond general acute care hospitals to other types of facilities,” said CMS Acting Administrator Marilyn Tavenner.  “It is part of a comprehensive strategy to use Medicare’s payment systems to foster better care and better value in all settings, thereby reducing overall Medicare spending.”

The current increase in payment rates is projected to be 2.3 percent in FY 2013.  It has also been projected by CMS that the increase in payment rate and some of the projected utilization will increase Medicare’s operating payments by 0.9 percent in FY 2013.

The proposed ruling includes new outcome measures that will reward hospitals that avoid healthcare-associated infections (HAI) from central line-associated bloodstream infection.  CMS is also proposed to include measures for perinatal care and readmission, including overall readmissions and readmissions relating to hip and knee replacements procedures, and for the use of surgery checklists.

In addition CMS is proposing to add a new survey to measure the HCAHPS measures to assess the quality of patients’ care transition.

Following are some of the proposed ruling additions:

• A one-year extension of the existing moratorium on the “25 percent threshold” policy, pending results of an on-going research initiative to re-define the role of LTCHs in the Medicare program.
• To apply an approximate 1.3 percent reduction (first year of a proposed three-year phase-in) for a one-time prospective budget neutrality adjustment.  The proposed reduction would not apply to discharges occurring on or before December 28, 2012, because the law prohibits its application before that date.  The budget neutrality adjustment reduces the update from 2.1 percent to 0.8 percent.
• To reduce Medicare payments for very short stay cases in LTCHs to the IPPS comparable per diem amount payment option for discharges occurring on or after December 29, 2012.  The law prohibits application of this policy prior to that date

Are bedside tablets ready for full hospital deployment?

Patients who are admitted to the hospital for longer periods of time may benefit from having access to entertainment services as well as health information.    Information in a hospital room can be delivered via interactive TV sets, emails, phone as well as one-on-one with a clinician.  But as more and more patients turn to smartphones and tablets to receive information, hospitals may be able to take advantage of patients’ personal mobile platforms to deliver meaningful information effectively and efficiently.

As more tablets and mHealth apps are released in the market, health can organizations will continue to have more options than ever for bedside solutions to implement throughout their facilities.  Some EHR vendors have actually begun to provide bedside solutions that tightly integrate with mobile platforms.

The following is a list of useful functionalities that current and future bedside tablets should incorporate to ensure success in an inpatient setting:

• Connectivity to an EHR or PHR that will provide access to the patient’s full information
• Teleconferencing / telemedicine capabilities with family and care team
• Long battery life
• Remote TV control
• Social media engagement / connectivity
• Menu option information and nutrition services
• Interactive patient education tools
• Access to patient health information

There are many ways in which this type of device can have a positive impact in the hospital setting on the patient experience:

• Improving patient satisfaction
• Help educate patients on their condition and procedures
• Reduce entertainment device cost through consolidation
• Improve communication with patients
• Improve care through telehealth and telemedicine service
• Allow for an overall more positive patient experience

So far, there are very few platforms that support strong customization and integration.  Bedside solutions have been using Android and iOS platforms, where some software vendors have been utilizing Google TV to deliver information to patients that is integrated with their EHRs.  Unfortunately, the technology must mature a bit more and show a real ROI and prove itself to health IT executives. Hopefully part of the ROI equation is patient satisfaction and enhancing the patient experience.

How the cloud is changing what HealthIT is all about

For Healthcare IT, cloud computing has been the hottest subject which is helping by bringing more storage for health information, flexible infrastructure, reliable DR/BCP and ease of support and scalability.    While there are many additional advantages to the cloud, some of the most interesting areas of impact that cloud computing is bring will be to the shift that the technical roles will see in the next 4 to 5 years.

Many years ago enterprises including healthcare were using thin clients or terminals that connected to a mainframe.  This provided them with centralized data and easy access to the business critical applications needed.  That model did not require too many IT engineers to support desktops or in house servers.  But as Windows and Apple introduced the personal PC where you can install applications that resolve specific business challenges, software and hardware support needs increased, and with that increased the number of IT folks.

But in some cases we are seeing that old trend somewhat reemerging again.  In today’s model, any healthcare enterprises have an IT department made up of hardware, networking, communication, and software support.  This keeps the organization running and ensures all the systems are operational.  However this delicate balance is being challenged by current migration to the cloud.  Companies like IBM and DELL are working with different size organizations to be able to get them to the cloud and provide them with full IaaS. The timing happens to be just right.  Currently any organization can easily and quickly procure a private cloud or virtual data center that will ensure itself a fully operational cloud based environment for everything from:  Unified messaging, EHR applications, messaging, Intranet, productivity tools, and many more).  Products like vCloud and IBM smartCloud are also making too easy to manage an entire enterprise data center from one single application.  What used to take days to implement (domain controller, email server, database server and such), can take minutes to deploy by simply using some of the already created vApp Templates.

It does not stop there, clearly with the advantages of virtual desktops as well; client or end user support just became easier than ever.

Today, it is completely possible to purchase a private cloud or even a data center (IBM PureSystem or DELL’s Cloud), which happens for some to be a fully operational environment that can even self heal.  Just to recap, for a medical organization with 40 physicians, who has recently purchased a new EHR.  The complete infrastructure can be fully cloud based and up and running within a day.  Not only it can quickly be deployed, but also is fully scalable and has High availability.  All the costs will be subscription based.

One change that this trend is bringing to many third-party IT service providers is the sense of urgency for them to push more aggressively toward more cloud based service offerings.  This would in turn reduce the significance of services relating to big physical server deployments as well as workstation support.

In few years, similar to how when we purchase a smartphone we have the ability to purchase or install with a single clicks all sorts of Apps, the infrastructure as a service and cloud computing will enable physicians and health organizations to customize the entire infrastructure simply by selecting all the needed modules and components (HIE services, EHR, Radiology, SharePoint, Email, Messaging, Patient Flow and more) and then have the infrastructure available within hours.

CMS announces 1.1 million participants and more to come for ACOs

On April 10, 2012, the Centers for Medicare and Medicaid Services (CMS) announced that over 1.1 million Medicare beneficiaries have been served by ACOs (Accountable Care Organizations), a statistic that shows a strong positive start to the proliferation of the ACO framework.

There have been 27 participating organizations in ACOs thus far under the Medicare Shared Savings Program, all serving an estimated 375,000 beneficiaries across 18 states.

“We are encouraged by this strong start and confident that by the end of this year, we will have a robust program in place, benefitting millions of seniors and people with disabilities across the country,” said CMS Acting Administrator Marilyn Tavenner.

For many of these participating organizations, and those who will join in the future, there are several criteria that must be met in order maintain membership.  Over 33 quality measures must be met, relating to care coordination, patient safety, preventative health services, improvement in care for at-risk population and the experience of both the patients and caregivers.

In addition to the 27 participants, CMS has also announced that there will be five additional ACOs participating in the Advanced Payment ACO model program.  It seems that CMS has had success thus far encouraging more physicians to participate in this initiative and become part of the care coordination team. It will be interesting to see the progress and how the model continues to develop over the next 6-12 months.

Some of the highlights of collaborative tools available today

For some time now, enterprise users and healthcare organizations have turned to different intranet tools (Open Source, commercial products) to help manage internal document storage, authoring and project collaboration. But one trend I’ve noticed in the recent months is that there continues to be a higher useage of Microsoft solutions, such as SharePoint. 

Some of the reasons for this increased rate of engagement is because the platform can play well with many other products and solutions available through Microsoft, which offers tremendous flexibility when it comes to customizing the solution to fit and resolve the specific needs and challenges of various organizations.

Healthcare has some pretty unique challenges that require specific ways in which to resolve them.  Many result from some of the inefficiencies in workflows and lack of automation.  Some of the functionalities included in the latest version of SharePoint server proves to enable many IT executivse to implement creative solutions that have been able to significantly improve workflows and create new efficiencies.

There are many advantages to a platform such as Microsoft SharePoint for healthcare organizations:

Office Integration: Office users will be able to take advantage of many of the capabilities offered through the integration of SharePoint and Office tools. This tight integration with Office productivity tools is useful for many of the hospital back office staff.  With its file menu integration, document check in/out, document version tracking and workspaces, hospital teams can collaborate on complex projects, such as ICD-10, EHR adoption meaningful use compliance, and many others, with ease.

Workflow Engine: SharePoint engine provides an incredibly powerful workflow engine.  It uses Windows Workflow Foundation (WWF).  This server side engine provides the ability to convert an existing organization’s workflow processes into a digital workflow format that can be applied to everything from documents, tasks, items, and many other entities in SharePoint.  Things such as routing specific forms based on content to the appropriated users can provide a robust way to handle automatic document routing and approvals.

Collaboration: With the ability to create centralized locations for different team members to access contacts, links, calendars, announcements and documents SharePoint helps increase the productivity of teams from all departments in a health organization.

Performance Dashboard:  A tight integration of PerformancePoint Services and the latest SharePoint Server 2010 provides a perfect combination that delivers an integrated performance management service that can assist with monitoring, and analyzing healthcare data.  The system gives access through the portal to financial performance, hospital payer mix, compliance stats, or simply reviewing the clinical outcomes.

For healthcare organizations, the focus continues to be on the delivery of the highest quality of coordinated care. But in order to also successfully reduce operational costs, there are many available solutions in the market place that can – and should – be implemented.  These products provide the right tools that make sharing information, and access to data, easier and attainable.  I believe that SharePoint provides tangible benefits and enables organizations to streamline their processes and provide access to data, helping the care delivery process and improving outcomes to boot.

Should health organizations consider cloud based storage?

Every year technology trends continue to impact our decisions concerning the emerging solutions and technologies that we will explore.  But the more health organizations that officially start their journeys toward electronic health information, the more their storage needs are significantly, immediately increased.  Data associated with digital imaging, structure documents, unstructured documents, lab results, and several other data sets have required many to continuously reexamine their storage strategy and expand their capacity.

In recent months, a natural disaster in Asia  caused significant downtime for some of the country’s leading storage and drive manufacturers, sending storage costs up.  While this subtle change has not decreased the demand, many are beginning to plan for alternatives and potentials for future models that will provide a more cost effective way to store information.

Cloud-based storage is seen as the next destination for home and enterprise users when it comes to storing their data without the need of physical drives or servers locally.  Similar to what DropBox, Dell, iCloud and now the new Google cloud-based storage platform, many have recognized the clear advantages to this new data destination.

Centralized Storage:

Most cloud-based services provide a single destination for all data needs.  With this model, information can be accessed from any Internet enabled device ranging from smartphones to traditional desktops.  This has been one of the biggest drivers in the consumers market.  With the high rates of usage of devices such as tablets and smartphones, which offer limited storage capabilities, many have pursued centralized storage solution to help maintain all their private data stored in one place.

Protected Data:

In healthcare, the majority of data must be secured and protected against any unauthorized accessed.  Organizations must be HIPAA compliant to ensure that they have actively adopted and taking the appropriate steps to secure and protect health information.   Cloud-based solutions provide the extra layer of security, as the information is not physically stored in local storage devices inside the facilities.

Scalability:

Similar to cloud computing, cloud-based storage is very scalable.  An organization may start with very small storage needs, and as soon as a health organization merges or acquires additional entities the storage needs can easily double or even triple over a short period of time.  With Cloud based storage, increasing the capacity is a quick and easy step for the Health IT engineers.

Cost:

Traditionally storage devices, such as SAN and NAS, require up front capital investment.  And as features are added to these devices and capacity is increased, the cost follows.  With cloud-based storage, an organization is able to pay for what it is using, only.  This provides a way to reduce the up front costs and an effective way to pay for only the used space.

Cloud-computing:

There are several vendors in the marketplace that go beyond offering just simple cloud-based services.  For example, Dell and Amazon are able to add cloud-computing capabilities to their cloud storage solutions. This makes the data accessible for cloud computing. This can be a valuable bundle of services especially when a hospital or health system is seeking to warehouse large data sets and perform analysis on it.

Whether an organization is seeking to eliminate the need for internal data management and eliminate the need for complex backups and disaster recovery procedures and processes, or simply looking for predictable costs and limitless scalability, cloud-based storage is ultimately here to stay.   And as adoption increases, so will the concerns surrounding the security of the data and speed. The fun never ends.