Promoting Interoperability: MU Fades to Black
Seeking to liberate the industry from its self-created morass of siloed data and duplicative quality reporting programs, the Department of Health and Human Services (HHS) issued 1,883 pages of proposed changes to Medicare and Medicaid. It renamed the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (known by all as Meaningful Use) to Promoting Interoperability Programs (PI).
As widely reported, it would eliminate some measures that acute care hospitals must report and remove redundant measures across the five hospital quality and value-based purchasing programs. It would also reduce the reporting period to 90 days. HHS will be taking comments until June 25, 2018.
HHS believes that APIs will solve all of the problems that patients and healthcare stakeholders have with data access. HHS also seems prepared to declare that TEFCA compliance and 2015 Edition CEHRT guarantees that those APIs are in place.
HHS believes that requiring hospitals to use 2015 Edition CEHRT in 2019 makes sense because such a large proportion of the hospitals are “ready to use” the 2015 Edition. Ready to use is not the same as using. 2015 Edition EHRs may not be as widely deployed as HHS indicates. The following 10 month old snapshot from ONC shows hospitals have not aggressively moved to adopt 2015 Edition CEHRT.
Current adoption levels by HCOs are undoubtedly better, and many vendors have 2015 Edition technology ready to go, but hospitals can only change so fast. The rush to get hospitals on the most current edition has to do with the most relevant difference between the 2014 and 2015 Editions – the API requirement. APIs will be the technical centerpiece of better, more modern interoperability but adoptions levels are still low. APIs, by themselves, offer the promise of better data liquidity. For this promise to become a reality, healthcare stakeholders need more than just a solid set of APIs.
HHS is also proposing that hospitals post standard charges and to update that list annually.
This is a nice thought, but it will take some heavy lifting to pull this off. For starters, HHS doesn’t even have a definition of “standard charge” and is seeking stakeholder input before the final rule is published. HHS also must determine how to display standard charges to patients, how much detail about out-of-pocket costs to include (for patients covered by public and private insurance), and what noncompliance penalties are appropriate.
Above all, there’s the thorny issue of establishing what a standard charge is in the first place. Charges vary by payer. Can a hospital truly state, without a doubt, the cost of an MRI or a colonoscopy? Most cannot – and technology alone will hardly solve this problem.
The existence of APIs will stand in the stead of the old view/download/transmit (VDT) requirement. Regarded as one of meaningful use’s most troublesome and fruitless requirements, this rule has been shed by HHS because of “ongoing concern with measures which require patient action for successful attestation.”
VDT is one of several MU Stage 3 requirements pertaining to patient engagement – along with providing secure messaging or patient-specific educational resources – that HHS has proposed dropping, under the pretense that it is “burdensome” to healthcare providers. While hospitals have struggled to get many patients to participate, the VDT requirement set the bar at one patient out of an entire population. What’s more, dropping the requirements fails to take into account how burdensome it is for patients to try to access their data, communicate with their physicians, and learn about their conditions and treatment options. It is also contrary to CMS Administrator Seema Verma’s remarks, first at HIMSS18 and again this week, indicating that the agency seeks to “put patients first.”
HHS says that third-party developed apps that use APIs will deliver “more flexibility and smoother workflow from various systems than what is often found in many current patient portals.” Whether such apps deliver “smoother workflow” is not a foregone conclusion.
HHS proposes “a new scoring methodology that reduces burden and provides greater flexibility to hospitals while focusing on increased interoperability and patient access.” The proposed scoring methodology uses a 100-point system (explained over 24 pages) in which attaining a score of at least 50 means there will be no Medicare (or Medicaid) payment reduction.
HHS is also mulling whether to abandon these measures altogether in favor of scores calculated at the objective level.
The biggest regulatory effort in recent months related to interoperability, other than this proposal, has been ONC’s proposed Trusted Exchange Framework and Common Agreement (TEFCA), required under the 21st Century Cures Act. TEFCA, well along in the planning stages, is a new set regulations from ONC whose goal is to catalyze better data availability using APIs. HHS in this regulation wants public comment on whether participation in a TEFCA-compliant network should replace the process measures in Health Information Exchange objective. Stated another way: Should TEFCA compliance replace 80 percent of the score for PI (75 percent in 2020)?
TEFCA is widely expected to provide a safe harbor from data blocking liability although ONC has been mum on this point. TEFCA then could do double duty: Eliminate the need to meet or report on health information exchange metrics and provide a shield from data blocking enforcement.
But there are, as yet, unanswered questions about TEFCA:
HHS is also considering doing away with Public Health and Clinical Data Exchange objective. It floated the idea that a provider that supports FHIR APIs for population-level data would not need to report on any of the measures under this objective. This would replace 90 percent of the score for PI (85 percent in 2020) when combined with the TEFCA knockout.
The specific API mentioned, called Flat FHIR and still in development, will probably contribute to part of the complex process of public health and registry reporting. This activity currently requires highly skilled data hunter-gatherers, usually with clinical credentials. In many organizations, these hunter-gatherers manually sift and collate multiple data sources to meet the varied requirements of the recipients of different registries. Flat FHIR, assuming it were production-ready, will certainly help, but it is unlikely that it could provide all, or even most, of the information needed for the range of public health reporting programs.
HHS acknowledges that providers are less than thrilled with aspects of the Quality Payment Program (QPP). HHS wants to know how PI for hospitals can better “align” with the requirements for eligible clinicians under MIPS and Advanced APMs. In particular, it wants ideas about how to reduce the reporting burden for hospital-based MIPS-eligible clinicians. It is undoubtedly looking for market-acceptable ideas to reduce the reporting burden where it is arguably more deeply felt – among non-hospital-based MIPS-eligible clinicians. While reducing or eliminating the reporting burden would help such providers, the big unanswered question, as it is with hospitals, is the burden of getting to 2015 Edition CEHRT.
HHS also asks the industry how it could use existing CMS health and safety regulations and standards to further advance electronic exchange of information. It is ready to change Conditions of Participation (CoPs), Conditions for Coverage (CfCs), and Requirements for Participation (RfPs) for Long Term Care Facilities regulations to this effect. It wants to know whether requiring electronic exchange of medically necessary information in these regulations would move the interoperability needle.
HHS believes that APIs will solve all of the problems that patients and healthcare stakeholders have with data access. HHS also seems prepared to declare that TEFCA compliance and 2015 Edition CEHRT guarantees that those APIs are in place. It roundly ignores the mesh of incentives that make stakeholders unwilling to share data and patients unable to access data. The industry has cried out for less process reporting and better insight into outcomes for years. This will accomplish the former but set the industry back with respect to the latter if interoperability is declared solved based on technology alone.
Matt Guldin · 1 year ago
John Moore lll · 2 months ago
Chilmark Team · 1 week ago
John Moore · 3 weeks ago
Podcast: The Convergence of Providers and Payers
Chilmark’s founder and president John Moore recently took some time to speak with the producer of the Relentless Health Value podcast, Stacey Richter, to discuss current strategies of one of the biggest trends in healthcare right now, provider-payer convergence.
The discussion begins by outlining how convergence is unique compared to the many other changes and initiatives sweeping through American healthcare. Most organizations enter into these partnerships as an answer to high administrative costs, the wave of recent consolidations, and unsuccessful provider-sponsored health plans. Most importantly, a successful convergence partnership requires a deep understanding and commitment to the local market served and trust between the organizations. John also outlines some of the challenges to creating successful partnerships and suggestions to overcome or avoid them entirely. For widespread convergence success, health care organizations (payers and providers) will need to systematize both the business processes and IT infrastructure to support data sharing and actionability.
Listen here and be sure to scroll to the end of this post to see some of the content discussed:
00:00 Convergence and the delivery of health care.
02:20 “How do we deliver greater value?”
03:00 Why establishing health plans within a provider organization is often not the best idea.
04:30 How you can get around needing prior authorization and subsequently cut costs.
05:50 The motivation for a payer and provider to form a partnership.
08:00 Why consolidation doesn’t necessarily drive down costs.
08:50 Payer-provider population health management.
09:20 Understanding where the patient might be going outside of the network to get their health care.
10:00 What does it take to be good at collaboration?
10:30 “What is the opportunity here?”
10:40 “Is there a level of trust between the payer and provider?”
18:00 Advice for payers looking to partner with providers.
18:50 Look for someone wanting to deliver high-value care.
19:30 “Trust, then verify.”
23:00 New and interesting innovations coming out of current convergences.
24:00 Things still being worked out in the market today.
25:25 The innovator’s dilemma.
26:30 “How do you scale quickly?”
27:20 “Is that scalable?”
30:20 The path forward for most markets in the United States.
Throughout the program, John and Stacey touch on several Chilmark publications, available here:
John emphasizes how prior authorization requirements are driving up admistrative costs for both providers and payers. Even outside of a full convergence partnership, both parties can begin to work together to reduce these costs and share the benefits.
As a population health management becomes more essential to healthcare, robust solutions are incresingly important for sharing and analyzing data from several sources, including payers, for sustainable value-based reimbursements.
Stacey mentions how difficult, yet important successful behavioral change can be for improving overall health. This report covers both factors driving adoption plus profiles for leading solutions for a variety of conditions and users.
John talks a little about his predictions for the future of the CVS-Aetna healthcare offerings in the podcast, including how MinuteClinics might become the first point of care. Read more in our blog about MinuteClinics, the implications for Epic Systems’ EHR, and challenges both companies face as they ambitiously attempt to transform how Americans seek healthcare.
PHM Market Trends Report Coming Before HIMSS
The Chilmark Research 2018 Population Health Management Market Trends Report, long in development, will be released immediately before HIMSS in March. This report profiles 25 vendors and describes the technology landscape for enabling a population health management (PHM) strategy.
Why a PHM Market Trends Report Now?
We hesitated to release a report on this emerging market for several years. Until recently, most available solutions were not able to fully address the range of provider requirements for PHM. The earliest solutions focused on the needs of Healthcare Organizations (HCOs) caring for Medicare Shared Savings Program (MSSP) patient panels. Over time, vendors added functionality to support bundles and private payer requirements requiring a good understanding of quality, costs, and utilization.
Another reason we held off with this report had to do with provider readiness. Healthcare delivery organizations needed time to incorporate these capabilities into their processes and workflows. The earliest HCO adopters of PHM relied on a variety of manual processes to conduct their PHM programs. Most HCOs lacked extensive experience with one or more of the constituent functional domains of PHM to fully utilize and benefit from the technology.
By early 2018 vendors had amassed significant experience building, managing, and supporting PHM enabling technology for providers and payers. Virtually all HCOs realize that PHM will be an increasingly important part of their operations and influence a significant percentage of their future revenue streams.
Virtually all HCOs realize that PHM will be an increasingly important part of their operations and influence a significant percentage of their future revenue streams.
Uncertainty About Value-Based Healthcare Makes Providers Pause
PHM’s close association with value-based care and payments cements its reputation as both a key strategy and technology enabler for transforming the U.S. healthcare system to achieve the goals of the Triple Aim. The PHM market’s growth closely mirrors the growth in value-based reimbursement (VBR). The pace of transformation to the payment system has not been smooth, and the Centers for Medicare and Medicaid Services (CMS) has sent mixed signals about its future in 2017. The business mandate for providers to embrace PHM slowed in the last 12-18 months. Provider concerns about revenue or market share losses have dampened enthusiasm for changing the fee-for-service (FFS) status quo. But the overall trend is moving in one direction: Away from FFS.
While uncertainty about the fate of value-based payments restrained provider’s embrace of PHM, the number of accountable care organizations (ACO), clinically integrated networks (CIN), and other risk-bearing programs continues to grow. Providers of all sizes have come to terms with the inevitable move to value-based contracting. ACOs will serve 10.5 million Medicare patients this year, a 17% increase over 2017. Delivering care to this expanding panel of patients requires providers, and in particular primary care providers, to organize themselves to make their PHM efforts successful. A variety of community based organizations, such as regional or state-level health information exchange organizations and to some extent payers, are also beginning to see the need to build and run PHM programs for, or in concert with, their provider partners.
Evolving Perception of PHM and the Four Technology Domains
PHM means different things to different people in 2018. Vendors built on products for pay-for-performance (P4P) programs to support CMS’ original set of ACO programs. Vendors, as a result of both organic development and acquisitions, now offer more PHM related functionality then they did a few years ago. While it is too early to say that PHM requires an established and fixed set of capabilities, the general outlines of the technology to enable a PHM strategy are broadly understood to fall into four technology domains:
Most of the vendors in this report have special expertise with one or a few of these domains.
As recently as a few years ago, analytics products provided the key enabling function for most PHM programs. While this functionality has an indispensable role in PHM programs, its core functionality – cost and utilization analytics and clinical quality monitoring – is arguably the most mature aspect of existing PHM solutions. Attention has shifted somewhat to care management. The value proposition for care management stems from a perception that these workflows are the “tip of the spear” for PHM generally. Care management products are often the central tool for organizing and running PHM programs on a day-to-day basis. Payer-oriented solutions with case, utilization, and/or disease management legacy have transferable skills for clinically oriented PHM. These vendors are beginning to make inroads into provider markets. Care management capabilities are less mature than analytics but are undergoing the most rapid pace of change by vendors.
The least mature aspect of PHM from a functional standpoint is patient engagement. In most of the solutions described in this report, the care management product supports some level of interaction between patients and a care team, mostly relying on a patient portal or app. Telephonic interaction with patients still seems to be the dominant method for most providers.
Data aggregation and data source management are core competencies for PHM. They form the foundation for all of the other domains of PHM. Managing diverse data sources is complex in all PHM sub-markets and for every organization developing PHM programs. Transactions, messages, documents, and files flow in from different organizations. These sources need to be reconciled, deduped, monitored for quality, and have all of their various records matched to patients, providers, organizations, health plans, and contracts. Organizations express this data using a multitude of formats and vocabularies. Vendors must constantly monitor these transfers and streams for quality, timeliness, and completeness. Every vendor in this report has skills in this regard but they differ in the scale at which they can operate. The number of organizations and sources from which they can ingest and process data is shaping up to be an important differentiator for providers. This set of capabilities is marked by fairly mature technologies and techniques but they are being deployed against a rapidly expanding universe of health-related information.
EHR Vendors Do Not Own the PHM Market
No vendor today has anything like a “PHM Platform.” The largest EHR vendors aspire to develop such an offering and have the resources to pull it off. Hospitals and health system turn to these vendors for all of their PHM needs, but it is not unusual for them to assemble their own solution from a variety of vendors supplemented with internally developed capabilities.
But these offerings come with price tags with little appeal outside of the large HCOs. Independent physician practices, most with limited budgets and no significant IT development staffs, are more interested in turnkey capabilities from a single vendor. Often this means their EHR vendor, but just as often it means an independent vendor with a full range of PHM capabilities. While EHR vendors are fielding increasingly full-featured solutions, they have not cornered the market.
Not all providers and payers have fully embraced value-based care and payments but the need for, and interest in, enabling solutions for PHM continues to grow. Armed with this report, providers can distinguish between the capabilities and services needed to help them meet their complex information and workflow needs for multi-disciplinary, multi-organizational teams striving to optimize the health of populations. This report will help providers sort through the different vendors and solutions in this confusing market.
What We’ve Been Commenting On
Lately, there have been quite a few big developments in healthcare, including Allscripts acquiring Practice Fusion, Apple’s PHR, and the mysterious Amazon-JP Morgan Chase-Berkshire Hathaway healthcare company. Not all of these developments have enough detail yet for Chilmark to analyze the impact on the future of the health IT market in-depth, but we are commenting elsewhere on the wider possibilities for the healthcare industry.
Blockbuster digital health funding to spill to 2018
Brian Eastwood in HealthcareDive
“’We think next year is when we’ll begin to see [predictive analytics] go beyond simply accounting for and noting social determinants of health and barriers to care and start to use that information to inform care plan decisions,’ Eastwood said. Vendors able to adequately take this on will emerge as key players in the care management and population health markets as the year progresses, he added.”
Health IT eyes M&A as market grows up
Ken Kleinberg in HealthcareDive
“The EHR market is saturated [and] consolidation is very clear…The movement to analytics and population care, that’s where the action is now,” Kleinberg said. “There’s a tremendous amount of innovation still possible.”
Apple debuts medical records on iPhone
Brian Eastwood in HealthcareDive
“Apple is widely accepted as understanding the user experience,” Eastwood said. “If all of the sudden, a substantial chunk of the population has the capability to tap into a patient portal in a way they haven’t before, then it could be a gamechanger.
Why AI tools are critical to enabling a Learning Health System
Ken Kleinberg in HealthcareIT News
“The Learning Health Systems continually improve by collecting data and processing it to inform better decision making. As the amount and complexity of big data continues to increase, organizations are challenged to fully take advantage of it,” said Kleinberg. “AI systems are particularly suited to analyze huge data sets to discover meaningful and actionable insights, and even to carry out actions.”
Apple steps into Epic System’s arena with medical records iPhone app
Brian Eastwood in The Capital Times
“(Health record companies) will still be building their core products,” said Eastwood. “They’ll still be maintaining the records…[Regarding rumors of Apple or Amazon creating EHRs], right now, it’s still a little bit in the realm of fantasy.”
How Amazon, JPM and Berkshire could disrupt healthcare (or not)Health IT eyes M&A as market grows up
John Moore in HealthcareDive
“‘I’m not holding my breath for big changes,’ Moore said. Instead, he expects incremental change are more likely over the next three to five years.”
Will Amazon’s push into health care impact Epic Systems’ future?
Ken Kleinberg in The Capital Times
“Software to power the applications for health care providers come predominantly from a few large players like Epic and Cerner,” Kleinberg wrote. “It’s a great question to ask to what degree they can take their provider and software application expertise and apply it to the needs of payers.”
Plainly Speaking: A hitchhiker’s guide to the [Healthcare IT] galaxy
I am always struck by how industries evolve language for the benefit of, and use by, its members. But membership has its privileges and its drawbacks. While simplifying ways for insiders to communicate, it excludes, or at least distances itself from, those not part of its club.
Such is the state of healthcare IT, breeding an entire cottage industry of acronyms worthy of their own syllabus. Health IT is one link in the healthcare supply chain of interoperable links, and its value lies in its ability to push and receive information to and from its fellow linked parties. Perhaps if challenges and achievements in health IT were discussed in plain English, it would be easier for physicians, employers and the consumer public to digest. Our representatives in DC could also better understand how legislation helps or hinders patient care; the repeal of Net Neutrality is a timely example of the health industry failing to persuasively advocate.
Perhaps if challenges and achievements in health IT were discussed in plain English, it would be easier for physicians, employers, [our DC representatives] and the consumer public to digest.
Being somewhat versed in this code, when my physician couldn’t locate my patient record, I asked him when he subscribed to his current vendor. As the lightbulb went off in his head, he quickly navigated to a “separate patient records portal prior to EMR” subscription and found me, explaining the 30-minute delay. Further conversation revealed my practitioner was unfamiliar with much of the acronyms health IT relies on (e.g., HIE for Health Information Exchange, HISP for Health Information Service Provider), and reported he is frustrated that his EMR vendor can not integrate his practice’s earlier patient records, nor does it provide follow-on training to him and his predominantly new staff. He added that his vendor offers no means of direct communication nor does his Accountable Care Organization have a channel or procedure for him to report deficiencies. Consequently, his pain points remain, as does a lack of guidance to his to his staff on its usage. I can’t verify the accuracy of his statements, but the fact that he believed them to be true indicates little chance of resolving his needs, his office turnover declining, or preventing more of his patients from needlessly waiting while donned in paper gowns.
Like much of the population, I am cramming in my family members’ visits before year-end to use up my HSA dollars. As a new member of the Chilmark team, I have a few questions, in addition to my usual, of the doctors I visit. So far, the same experience noted above was reported by two other physicians. A couple more on my schedule before the year is out and I may wind up with a straight flush!
The EMR vendor’s relationship is with the larger ACO entity, but patient care is in the individual practices by the professionals administering care, and the few I spoke with reportedly felt their workflow issues remained unaddressed. All were surprised and genuinely appreciative that I sought their opinions and experiences in accessing the data they require. We should be mindful that by creating our vernacular for health IT professionals, we do not omit other stakeholders in the conversation whose participation is required for improved and engaged patient care.
Author’s Caveat: This is just my casual survey from a suburb outside NYC but I am eager for others to conduct and comment on their own.
Deriving Value from Enterprise Systems
Years ago, when I was working as an analyst in the manufacturing vertical, the stories were legendary of ERP deployments gone awry and countless examples of cost overruns. In fact, it was nearly impossible to find an enterprise deployment that stayed within budget.
Is it any surprise then that the healthcare sector has suffered its own share of enterprise software (EHR) woes? Hardly not.
But that is not to say let’s pull up the stakes and forget about digitizing health and revert back to clipboards and row upon row of filing cabinets – we are far beyond that now. The healthcare sector will become, like countless others, digitally-driven. The challenge for the senior leadership at healthcare organizations (HCOs) is to derive value from these deployments, value that requires investment well-beyond the install of that bright and shiny new EHR.
Unfortunately, for many HCOs, insufficient forethought was given to what they hoped to accomplish, what value they hoped to derive (beyond MU compliance) in adopting that new EHR. I have yet to see an enterprise-wide deployment go well, or meet objectives if the organization did not adequately prepare at all levels. The most overlooked aspect is sufficient attention to workflow design and training end users to facilitate adoption and efficient use of a new system.
But there is value in these systems if done right and with the accelerated migration to value-based care (VBC) and associated reimbursement, this will only increase.
At this year’s HIMSS conference, the best presentation I sat in on was by Steve Allegretto of the Yale New Haven Health System. His talk was on their organization’s effort to get a true understanding of costs of delivered care and optimizing for outcomes. He presented some very compelling evidence on how they reviewed their various clinical pathways, supply chain, procedures to uncover unwarranted variabilities to rectify. The result was not only an ability to decrease the cost of care delivered, but in doing so they improved their quality scores. Truly a win-win. When I asked Steve during the Q&A as to what role their EHR had in this analysis – he was adamant: “We simply could not have done this without an enterprise-wide EHR across all of our hospitals to understand variances and then modify them with consistent, clinical pathways across the institution.”
More recently when I was in Colorado for the World Cup Finals, I met a geriatric physician on the lift up the mountain. Our conversation quickly turned to healthcare, the massive transformation that is ongoing and how he, as a physician, was coping with it all. Being in his mid-forties he’s seen quite a bit of change in his career. What I was most struck by though was his enthusiasm for being a physician – he truly loves what he does and secondly, his enthusiasm for his EHR.
As a geriatric physician, virtually all of his reimbursement comes from CMS, which has placed an increasing emphasis on quality reporting. His organization takes part in CMS’s MSSP (Medicare Shared Savings Program). The physician has a scribe that does all the EHR data entry for him while he interacts with the patient. The EHR tracks and reports the various quality metrics CMS is looking for and his organization has been getting quality bonuses ever since, more than paying for the scribe, and he finds he has more time for his patients.
Adopting a new enterprise software system is not for the feint-of-heart, but if done with sufficient forethought and a clear understanding that the investment doesn’t stop upon deployment, but much like raising a child requires a long-term investment, the benefits are very real and sustainable.
Looking Back – Assessing Our 2016 Predictions
As has become a tradition here at Chilmark Research, it is time once again to look back at our predictions for 2016 and make an honest assessment of just how accurate we were. We do like to go beyond the blatantly obvious predictions that seem so prevalent – we push the boundaries. While this is a good exercise for us and hopefully insightful for you, it does create some challenges in assessing how on target our predictions were. But alas, no pixels were killed in this exercise, no harm done and we take what we learn and move on.
Without further ado…
HIT: Cyber-security Hacks Increase as Value Escalates
No lack of cyber-security hacks and breaches during 2016 as the value of personal health information (PHI) far exceeds the cost to obtain it.
MISS: EHR Vendors Begin Taking Big PHM Market Share
At the top-end of the market, Cerner and Epic are definitely making some in-roads. In the ambulatory market, athenahealth and eClinicalworks are gaining some traction. However, none of these vendors have really taken the market by storm and there are a slew of other EHR vendors still pulling a PHM solutions suite together (e.g., Allscripts, NextGen) and others seemingly out-to-lunch (e.g., Meditech, Evident, PracticeFusion).
MISS: Telehealth Matures, Consolidates
In a sense we were partially right on this one as telehealth services continue to grow. But we were wrong on two other counts: In the total market for ambulatory health services, telehealth still makes up an exceedingly small percentage. Second, we have not seen any significant consolidation in this sector – maybe 2017 will be the year.
MISS: Physicians Flock to Direct Primary Care
Yes, there is growth in the number of physicians that are choosing to take the path of DPC and that may accelerate under a Trump administration, yet most small practices are simply opting to sell their practice to the highest bidder among local HCOs as those HCOs seek to build out their clinically integrated networks (CINs).
HIT: APIs Gather Steam but FHIR APIs Doesn’t Become Mainstream —
The promise of FHIR has yet to be realized as the standard does not become “official” until 2017. As we predicted, no major EHR vendor released a comprehensive set of production-ready FHIR profiles and resources in 2016.
HIT: CCM Code Underwhelms
CCM code adoption by primary practices in 2016 was poor. The administrative burden combined with the patient co-pay provision was more than most, small practices wished to deal with. In April 2016, CMS put forward CPC+, which if it gains APM status under MACRA, will see far stronger adoption.
MISS: Increased Attention on Referrals Transactions
Standalone referral management market still hasn’t really materialized with a lot general inertia to keep the status quo (e.g., fax machine). Today, only a very small percentage of overall initial referrals are electronic (10%-15%) and closed loop referral remains in PowerPoint from a full feature standpoint with new updated info sent back to referring physician.
MISS: Digital Health Investing Sees Steep Decline
Investment firms continue to pour inordinate amounts of cash into the digital health sector. This being a $3T plus market, a few billion in investment for 2016 is still pretty modest in the grand scheme of things.
HIT: Data Governance, Ethics and Consent Stymie Interop
No doubt, connecting disparate systems in support of interoperability is a Herculean task. That being said, technology is not the main culprit behind the lack of interoperability today – it is cultural.
HIT: Pharmaceutical and Med Device Companies Expand Outcomes-based Pricing
Last year we gave a caveat to this prediction: “Yet, we will only see very limited expansion in 2016 due to challenges associated with measuring and attributing outcomes to a given therapy. The ability of today’s heath IT systems to effectively measure such outcomes will be a key sticking point.” This was spot-on and will continue to hold true in 2017.
MIXED: CCJR Sets the Direction and Care Coordination Benefits
Half right only because CMS had to go with a stick approach after initial enrollment was tepid. Care coordination still dominated by readmissions programs and the 30/90/120 day follow-up periods that are utilized for various readmissions programs including CMS. Very rare to see true continuous care coordination that is longitudinal and open-ended across a cohort of patients or specific geographic region. It is almost entirely episodic, event-based, and limited follow-up duration.
HIT: PGHD Meets Wearables with Mixed Success
As we stated in the original prediction: “To the chagrin of many, 2016 will not be the year we see this industry leverage these data to augment risk scores, conduct proactive engagement, or do much beyond following marching orders from DC.” Don’t hold your breath expecting an uptick in 2017.
MIXED: Mergers and Acquisitions Accelerate While Facing Increasing Scrutiny
M&A activity continued throughout 2016, especially among healthcare providers as large HCOs seek to build out their CINs to create more comprehensive care networks. The M&A activity we were expecting in the HIT market and in particular across EHRs failed to materialize.
While this may be a great batting average for the MLB, for an analyst firm, not so good – we’ve done better. Next week we will post our predictions for 2017. With a new administration coming in under the mantra of repealing ACA – 2017 predictions will be interesting to say the least.
Changing of the Guard: Implications to Health IT Market
After a brutal election cycle, we are now on the other-side. The Republicans have taken control of the Hill and the White House. The many healthcare programs rolled-out under the Obama administration will now be put under the microscope.
While we try to stick to IT-related topics, in healthcare one cannot divorce policy from technology adoption as federal policy has been and will likely continue to be one of the key macro-economic forcing factors to IT adoption in the healthcare sector.
Certainly, the ACA (Obamacare) will see an overhaul. It is unlikely that there will be a full-blown repeal of ACA as many of the programs within ACA have become part of the fabric of healthcare and would be too difficult to unravel (e.g. MACRA). But make no mistake; significant changes will be phased in over the next few years. It is also important to look beyond just the changes that will be made to ACA as the healthcare sector touches just about every sector of the economy.
During the election campaign, Trump rose to President-elect without divulging any real details as to how he would actually implement his proposals. One must look beyond Trump to the core Republican value of letting market forces lead the way with little government oversight to determine where we might be heading. The Chilmark Research team met collectively to discuss what are the implications of this new Republican leadership team in Washington on the healthcare sector. The Table below is a summation of those discussions of likely policy changes.
As mention previously, in healthcare, IT adoption has been tightly linked to federal policies. That will not change going forward. Looking ahead, Table 2 provides a brief analysis of how the healthcare IT market will fare under this new administration.
Looking Ahead Regardless of who ultimately took office in the 2016 election cycle, the overarching impact to IT adoption is modest. HCOs will still need to continue to increase their investments in analytics to reign in costs and improve quality. The move to a more consumer driven market will also herald yet another round of investments in new care delivery models and software to support. However, mandated models and regulatory approaches to solving some of the ills in healthcare will fall to the wayside. For example, data exchange/interoperability will pull back from being a social/medical need that is mandated to being a business/market need that is economically driven. Our advice to HCOs, do not wait for the dust to settle in Washington. The need to continue to improve costs and quality metrics will continue unabated requiring a long-term investment strategy in IT to facilitate cross enterprise care delivery.