HIMSS’19: Maturing Market Drives Pragmatism

Even the exhibit hall was calmer with vendors focused on solving specific problems instead of the latest buzzword

Frankly, I was dreading attending HIMSS this year. I’ve grown tired of the hype, the noise and just how little we have accomplished as an industry in the past few years. We have not contained costs, but have increased clinician burnout. We have made only a modest impact on quality, but the lack of interoperability has hampered care coordination. I had become increasingly cynical every year as we approached the big event, dreading more of the same, which is never a good thing.

Yet at the outset, while waiting to board my flight to Orlando, I started meeting many a compatriot in healthcare IT. This did not stop until I landed back in Boston five days later. Those brief meetings always included a hug, checking in with how each other is doing personally and then proceeding to talk about the industry – in that order. I have worked in a wide range of industries over the course of my career, only in healthcare have I experienced such genuine warmth and caring. These brief encounters renew my spirit pushing that cynicism back for this industry is more than just a business, it is about health, and it is about life.

HIMSS’19 Reflections

For the last eleven HIMSS conferences I have attended, there has always been one buzzword or acronym that virtually all vendors on the exhibit floor would latch onto, whether they could deliver those capabilities or not. There was no such word or acronym this year. The hype, the buzz may be behind us, which is welcomed by this analyst and I’m sure most in attendance.

I also noticed that conversations were less about whiz-bang features. Instead, conversations focused on specific problems that can be solved and value delivered to an organization. The industry is quickly moving beyond being strictly regulatory-driven (albeit CMS’s NPRM dropped Monday at HIMSS goes against that) to a more pragmatic market, which is a healthy sign of a maturing industry.

It was clear this year that the EHR war for buyers is over. Those EHR vendors offering a fairly limited, EHR-centric product with few extensions (e.g. analytics, RCM, PHM, etc.) were eerily quiet. EHR vendors with broad capabilities had their fair share of visitors, but the discussions focused on the extension apps and equally important, how to extract value from those significant EHR investments.

In speaking to one of the largest EHR vendors, they were surprised by the interest in PHM among their clients, which has been tepid in recent years. Clearly, CMS’s recent moves to get provider organizations to get serious and start taking on downside risk are being felt. But this vendor went on to say that most prospects simply want someone to tell them what to do to be successful. For companies like Aledade and Evolent this must sound like mana from heaven.

Some quick outtakes from HIMSS’19

  • Acute and ambulatory have been by and large taken care of, yet we still do a very poor job as an industry addressing the “community of health.” Good opportunity for a truly visual, intuitive platform.
  • Ada Health, a Berlin-based small company using AI for self-triage is just entering the US market and has landed Sutter Health as its lighthouse customer. Keep an eye on them – they are interesting.
  • Significant shift among provider-centric vendors who are now signing large deals with payers. Still plenty of mistrust between providers and payers, but if incentives are aligned – it can work.
  • Collective Medical out of Utah has been operating in stealth mode and racked up several payer and provider clients. Compelling value-prop but they will have to move fast as several much larger vendors are looking to do something similar.
  • Many a large health IT vendor does a poor job at data aggregation and digestion (normalization) and are seeking partnerships with a number of small innovative companies that focus on this problem.
  • Apervita, a company that has been around for several years with a business model I never was fond of has completely changed direction. I like what I saw at HIMSS this year. Their work with NCQA is pretty impressive.

The Wrap

HIMSS this year reflects a maturing market. With any maturing market, conferences like HIMSS begin to lose their luster, despite their own self-promotional hype. But what HIMSS does well is to bring together a broad cross-section of the industry and remains a fabulous place to reconnect and network. Does it need to be three and a half days (plus!), I do not believe so. In five years, HIMSS will still be here, but the high water mark was likely last year (barring any major federal incentives a la HITECH). The tide is going out.

Stay up to the minute.

Did You Know?

Promoting Interoperability: MU Fades to Black

By Brian Murphy and Brian Eastwood

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.

Certified EHRs as Enablers of Interoperability

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.

Figure 1: Adoption Levels of 2015 CEHRT
Source: Office of the National Coordinator for Health Information Technology. ‘Certified Health IT Developers and Editions Reported by Hospitals Participating in the Medicare EHR Incentive Program,’ Health IT Quick-Stat #29. Available at https://dashboard.healthit.gov/quickstats/pages/FIG-Vendors-of-EHRs-to-Participating-Hospitals.php.

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.

Price Transparency: Easier Said Than Done

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.

Patients (Not) Using Their Data

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.

Reporting Burden Reduction

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.

Table 1: Proposed Scoring Methodology for Promoting Interoperability Program (PI)

HHS is also mulling whether to abandon these measures altogether in favor of scores calculated at the objective level.

The TEFCA Angle

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:

  1. How much will it cost providers to comply and can they make money for providing access to their data?
  2. Will TEFCA compliance, as a practical matter, accomplish anything? Will it make it easier for healthcare stakeholders to use each other’s data?

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.

MIPS and APM Concerns

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.

Mandating Interoperability with Other Regulations

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.

Bottom Line

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.

CMS Drops MACRA Rules – 5 Things to Know About MIPS

qualityBig news this week when on Wednesday CMS dropped the draft rules for MACRA, all 962 pages worth. These rules are the outcome of legislation that passed a couple of years back to replace the flawed SGR reimbursement model for physicians and hospitals. In its place, CMS is proposing two dominant reimbursement models:

  • APM, short for alternative payment models, is primarily targeted at hospital systems.
  • MIPS, short for merit-based incentive payment system, is primarily for ambulatory providers, otherwise known as eligible providers (EP) under Meaningful Use (MU).

In the conference call on Wednesday, acting head of CMS, Andy Slavitt, made it clear that the intent of MACRA is to move towards a model that provides flexibility for physicians to deliver quality care and enable the free flow of information across the sector in support of patient care and more broadly population health.

Plenty to talk about regarding both APM and MIPS, but for brevity’s sake, let’s focus on MIPS and we’ll do a follow-up post on APM in near future.

Five Things to Know About MIPS
Unpacking 962 pages of proposed rules in not for the feint of heart. No, we have not gone over every little nuance of the rules but in our cursory review we have identified five key points that really are the crux of the rules for EPs as it pertains to MIPS. These are the things that define the intent of MIPS and also where we are likely to see some push-back, after all, these rules are not quite set in stone – yet.

1) Quality and information exchange are top priorities. MIPS reimbursement will be based on a composite score of four key components: quality, resource use, clinical practice improvement activity, and advancing care information. Quality and advancing care information will be 75% of total weighting. Thus, it is quite clear where CMS wants physicians to focus in the near term – improving quality of care delivered and accelerating the use of IT to facilitate the flow of PHI in support of care quality.

2) Move from highly prescriptive to more flexible model. Under MIPS, MU is effectively dead for EPs under Medicare – the odd twist though is that MU is still in place for hospitals and Medicaid EPs, though CMS has expressed its intent to modify these areas as well in the future. CMS is giving quite a bit of flexibility to EPs in reporting out what measures are most important and relevant to their practice. Gone are the prescriptive, strictly defined measures that were part and parcel of MU, measures that often did not align with other CMS programs.

3) Be careful what you wish for – flexibility may breed complexity. While physicians now have a range of options as to what they will report out on as part of MIPS, this flexibility has a way of compounding itself in a nearly exponential way. Eligible physicians will need to wade through the many permutations of MACRA reporting requirements to settle upon what is best for their practice. This will create a lucrative opportunity for consultants serving this market. We also wonder how CMS will keep track of all of this as well – this is a non-trivial issue.

4) No time to waste – one year reporting period, begins January 1, 2017. Due to legislative requirements, CMS’s hands are tied as to when the switch to MACRA begins – but Jan. 1 2017 is only a short six months or so away from when rules will be finalized. What CMS does have flexibility on is the reporting period and they have chosen to go with one year, versus the more popular 90-day reporting period. CMS will get some heavy pushback here and likely acquiesce to 90-day. Would also not be at all surprised if the whole program gets push back a full year – just remember what happened to switch from ICD-9 to ICD-10.

5) Trust then verify is the mantra. Under MACRA’s new reporting requirements CMS recognizes that it will need to trust EPs to do the right thing. That being said, the proposed rules also have a significant amount of language pertaining to surveillance. How that surveillance will occur, how much will big brother be looking over a physician’s shoulder is up for interpretation,

While there are aspects to MACRA that have cause for concern, as outlined above, we are quite impressed with what CMS has put together. Clearly, a lot of hard work has gone into these proposed rules. CMS has reconciled many of the past ills – from the defunct SGR reimbursement model, to the oft-maligned MU program – with the desire to align the program to how physicians actually practice care that will lead to improvement in quality of care provided and value for the U.S. citizen. This is a Herculean task and for that CMS, Andy Slavitt, Karen DeSalvo, and countless others that have contributed to this effort deserve applause.


Some Additional Resources:
HHS Secretary Burwell’s take, with a pretty slick video giving high level overview of MACRA
The proposed rules, all 962 pages
Nice, digestable summary of MACRA
Similar to previous, but takes closer look at Advancing Care Information – the replacement to MU
Politico’s, Dan Diamond’s, interview/podcast with Andy Slavitt about MACRA


Health IT for Behavioral and Mental Healthcare

Coaching Technology

While the landmark health reform laws enacted in 2009 (HITECH Act) and 2010 (Affordable Care Act, or ACA) have begun transforming certain aspects of the US healthcare system, they have not had a meaningful impact on behavioral and mental health care delivery. Patients in need of these services already face an uphill battle in terms of social stigma and making a decision to seek out care, yet our system compounds such challenges through poor benefit design, uneven IT adoption, and lack of care coordination. An emerging fleet of technology solutions focused on behavioral health care has the potential to improve care, though they are not without their own set of challenges.

> Providers lack adequate incentives to adopt patient-facing digital mental health care tools. This is due both to omission of non-psychiatric mental health specialists in the Meaningful Use program as well as the slow adoption of value-based contracts.
> Vendors of new technology have not placed a premium on making their platforms interoperable with legacy software. New startups have focused most of their efforts on developing self-contained tools geared towards the employer market rather than emphasizing document exchange, shared care plans, or tools for the population health manager to manage mental health needs.
> Given the fragmented nature of the delivery system for mental health care, the market for mental health care IT is quite immature. While there are ample opportunities for one-off improvements (primary care, substance abuse facilities, Veterans Affairs, higher education, employee programs, etc) – only those health systems who can underwrite their own reforms will be the ones taking action.

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WWBR Week of October 6, 2014

Dallas hospital blames ‘flaw’ in ‘workflow’ for release of Ebola patient as a more complete picture of his travels emerges
Lindsey Bever for The Washington Post
“The Ebola patient in the Dallas hospital seems to have been missed because workflow integration doesn’t mean much when workflows are separately integrated. An intake nurse documented the patient’s travel to Africa in the patient’s chart. That data appeared nowhere in the physician’s workflow. The hospital has hurriedly changed physician workflow to include travel history. Pity the poor IT departments that have to foresee all possible contingencies and build these into clinician workflows. Pity the poor clinicians who have to wade through documentation that has no current relevance. Is it realistic to expect every hospital, clinic, and office in the U.S. to have been ready to raise the alarm for the first patient to present with Ebola symptoms?” – Brian

Mass. Becomes First State To Require Price Tags For Health Care
Martha Bebinger for WBUR’s CommonHealth
“In another revolutionary move, MA became the first state to require that health plans divulge the prices of their information on public websites. As this piece points out, there are still wrinkles to iron out, including consistency of prices, common definitions of what’s included, and more. Yet this is a bold step we hope to see mirrored across the nation. Interestingly, health plans contracted with Castlight, Vitals, and others in order to get these lists up and running.” – Naveen

Walmart and the End of Employer-Based Health Care
David A. Graham for The Atlantic
“Wal-Mart announced that they are going to stop offering insurance coverage to ~30,000 part-time workers (workers who work 30 hours or less a week) and follow suit with other large employers including Target, Trader Joe’s, and Home Depot. Whether or not these part-time workers will be better off will largely depend on what state they live but it certainly marks a milestone in the inevitable decline in employer-sponsored health care in the U.S.” – Matt

A Need for Stage 3?
Greg Gillespie for Health Data Management
“As fallout from Stage 2 continues, HDM offers up a handful of questions to some leading CIOs around provider motivation, vendor readiness and the future of the program.” – Naveen

Few ACOs Pursue Innovative Models That Integrate Care For Mental Illness And Substance Abuse With Primary Care
Valerie A. Lewis, et al., in Health Affairs
“Survey results from a national survey of ACOs and followup detailed interviews with a select number of ACOs that looked at the issue of behavioral health and ACOs. While most ACOs are responsible for assuming behavioral health costs, there still remains a lot of work to improve the traditional siloed and fragmented approach of primary care and behavioral health. Some ACOs are practicing innovative care models to better integrate the two but only a small handful had fully integrated behavioral health programs in primary care services delivered by the ACO.” – Matt

Improving Medicare Post-Acute Care Transformation Act of 2014 (PDF link)
US Senate
“Everyone know that Congress does nothing, right? Amazingly, two weeks ago the Senate passed something called “Improving Medicare Post-Acute Care Transformation Act of 2014”. This bill aims to standardize reporting for the major categories of post-acute care providers – home health, inpatient rehab, skilled nursing, and long-term care. It would standardize reporting for patient assessments, quality, and utilization across these disparate care disciplines. It is probably about time that more data be used to help determine the comparative effectiveness of these care venues and for which patients. The bill now goes to the President for his signature.” – Brian

Can Patrick Soon-Shiong, The World’s Richest Doctor, Fix Health Care?
Matthew Herper for Forbes
“An interesting deep-dive on LA billionaire-doctor Patrick Soon-Shiong. The author doesn’t include a whole lot of detail on Soon-Shiongs’s efforts at NantHealth, but it’s not for a lack of trying – as described by John Halamka in the article: ‘The marketing is three years ahead of the engineering.'” – Naveen

#WWBR Week of September 29, 2014

Doctors Find Barriers to Sharing Digital Medical Records
Julie Creswell for The New York Times
“A non-technical overview at the issue of Interoperability, with a focus on everyone’s favorite bad-guy vendor, Epic Systems. Nothing we don’t already know, but some of the details – like Epic’s recent hiring of a DC lobbyist – show just how far down interoperability truly is on their list of priorities.” – Naveen
“Yet another article about interoperability or lack thereof across the healthcare landscape. All share the blame here, from EHR vendors desiring high switching costs, to providers looking for low cost solutions but with poor interop capabilities, to administrators not investing in user training and regulators that did not make this a primary requirement from the beginning of the MU cycle. It will take years to sort this one out.” – John
“When articles about healthcare interoperability impossibilities make into mainstream newspapers, I always pay attention. This one quickly turned into a critique of Epic and its ambitions re the DOD’s HIT revamp. While it focuses on Epic, it does point out that it is but one of the EHR vendors to benefit from $24 billion in EHR incentives. I am pretty sure that this kind of coverage does not really cut through the noise of routine political coverage and engage the average non-healthcare reader.” – Brian

What’s Behind the Slowdown in Health Care Costs
Kimberly Leonard for US News
“A look ahead at future healthcare costs finds that the silver tsunami that many feared would completely crash the US economy, may not be so bad after all. What is surprising in this analysis is that the mix of spending remains constant.” – John

Changing my mind on SES Risk Adjustment
Ashish Jha An Ounce of Evidence (blog)
“Harvard professor, Ashish Jha, has a change of heart regarding the use of SES (social economic status) data for calculating readmission scores and subsequently penalties. A more nuanced topic than what appears at first blush.” – John
“A worthwhile read about how introducing SES data into the risk adjustment process might play out. As analytics engines develop capabilities to layer in additional data, reimbursement based on that deeper context will become the next step. The issue there is how to strike a balance between penalizing hospitals for seeing poorer (and sicker) patients, versus getting them off the hook for delivering substandard care just because someone is poor. ” – Naveen

The Payment Reform Landscape: Value-Oriented Payment Jumps, And Yet…
Suzanne Delbanco for Health Affairs Blog (see also: Forbes article on VBR)
“Insight blog post by Suzanne Delbanco regarding the 2014 National Scorecard on Payment Reform survey by the Catalyst for Healthcare Payment Reform. Survey found a huge shift in ‘valued-based payments’ among commercial plans to ~40% but also noted some key limitations too including that less than half of this was really risk-based (downside risk) and most of the payment reform has focused on hospital payments. Delbanco also points out that ‘pay for performance’ programs both in the US and UK over the past decade have had very mixed results. The other issue that it is quite difficult to evaluate the effects of these payment reforms because the current infrastructure to report and collect quality and safety information based upon actual clinical data is insufficient and burdensome.” – Matt

Hospital Group Sees Diseases of Rich Spurring Health Spending
Choong En Han for Bloomberg
“While we may not be in position to export US-style healthcare, we are apparently exporting US-style health concerns. This translates into opportunity for providers operating in economies where affluence-related obesity and metabolic disorders are increasing and where infectious diseases and malnutrition still are common. The sick who can pay are a growing segment of the population. We can only hope that the ongoing transformation of our healthcare system can help us turn care protocols for these problems into a legitimate export.” – Brian

Set Your EHR Data Free
Arcadia Solutions Blog
“For many healthcare organizations, predictive analytics may still sound like science fiction. But this post shows a few examples of how mining existing EHR data before an actual diagnosis is made, as indicated by claims data, can unlock existing value that goes deeper than crunching CCDs.” – Naveen

CMS: 44,000 Have Applied for Hardship Exemption
Gabriel Perna for Healthcare Informatics
“Approximately 44,000 eligible providers (EPs) have applied for a meaningful use exemption, the CMS or roughly ~14% of the EPs who have registered. The exemption is for providers who will not attest to meaningful use in 2015. CMS is sorting through the applications and notifying each provider of their status. CMS stated the majority of exemption requests are coming from first-time attestations that are experiencing issues with their 2014 certified electronic health record technology (CEHRT).” – Matt

HCA: The Bashful Giant
Jeff Goldsmith for The Healthcare Blog
“This short blog does a quick and dirty compare of HCA’s market approach to the rest of the world. It concludes that HCA is doing just fine even though it has not embraced many of the changes to care and payment. Could HCA be right?” – Brian

Benefits innovation ‘stuck in neutral’
Andrea Davis for Employee Benefits News
“Keynote speaker from a Benefits conference this week in Florida noted that employer wellness programs have seen little innovation of the past decade. Noted that these programs consist of the same components including biometric screenings, health risk assessments, telephonic coaching based on the results of the screening and HRA, and participation-based incentives and that ‘one size does not fit all’ in regards to wellness programs.” – Matt


What Lies Ahead for Meaningful Use?

matts2After much speculation and mounting criticism of Meaningful Use (MU), two recent developments provided some clarity on the future direction of the program and indications of how rocky a road it will be for providers in stage 2.

Fleeting Relief
After a summer filled with mounting criticism and a litany of responses & comments on how to modify the program, CMS issued their much anticipated new final rule for Meaningful Use (MU) Stage 2 on August 29th. For providers who were hoping for some relief, they did not get much.

While providers have greater flexibility for 2014 in terms of using 2011 or 2014 certified EHR technology (CEHRT) to meet the 2013 or 2014 objectives and measures, many were critical CMS did not go far enough in relaxing the rules for 2015. In 2015, providers will be required to use 2014 CHERT and report for the full year (vs. only one quarter in calendar year 2014).

Making matters worse, this is based on the federal calendar year which begins Oct. 1, 2014. This leaves providers with little time to get their bright shiny CEHRT for stage 2, in operation, workflows mapped to support new guidelines (more eCQMs) and staff trained to insure the right metrics are collected for future attestation. It also continues to place a heavy burden on providers who are struggling with MU menu objectives that relies upon cooperation from third parties (e.g. patients, labs, post-acute providers) to meet threshold objectives.

Tepid Attestation – Will it Continue?
Last Wednesday’s HIT Policy Committee monthly meeting also provided an update on electronic MU attestations thus far in 2014. Year-to-date figures showed noted improvement since the last meeting in August but overall adoption of stage 2 remains lackluster.

Through August 25th, 8,024 (vs. 2,823 as of July 1) eligible professionals had attested for the 2014 reporting year with 3,152 (vs. 972 as of July 1) attesting for stage 2. For eligible hospitals, 436 (vs. 128 as of July 1) had attested for the 2014 reporting year with 143 (vs. 10 as of July 1) attesting for Stage 2.

Eligible Providers_Stage 1 MU Hospitals_Stage 1 MU

To put that in perspective, only ~3.5% of hospitals of eligible hospitals and ~2.5% of eligible providers who have successfully attested for MU stage 1 have attested for stage 2 to date. As of this writing, an estimated 85% of all hospitals in the US have yet to meet stage 2 requirements. That is a very big percentage.

Cloudy Forecast for MU
From a payment perspective, MU is entering a period where penalties will potentially become larger for hospitals than incentive payments. The numbers disclosed at the monthly HIT Policy Committee meetings will be very important to monitor through January. If stage 2 attestations remain tepid, it will be an early indicator of waning provider motivation regarding stage 2 MU and likely the whole MU program.

Several key questions regarding MU also remain. What happens if the initial funds that were authorized by the HITECH Act are exhausted this year? What is the political will today in Congress to actually implement the penalty phase of MU? Will the rumors of stage 3 being permanently shelved if stage 2 attestation rates remain low through 2015 come true? Then there is always the issue with a pending change in the administration and just how much the next administration will continue to invest political capital in this program, which frankly has met its initial objective of driving the adoption and use of EHRs.

The net takeaway is that these particular MU announcements will have little real impact on providers or health IT vendors. Providers committed to stage 2 MU will continue to invest in solutions and services through 2015 in order to attest. Providers who have yet to upgrade or purchase 2014 CEHRT technology or are struggling with quality reporting and meeting menu objective thresholds will face a difficult decision:

Is it worth the time and capital to get on the stage 2 bandwagon or place the bet that future penalties for not meeting stage 2 requirements will be small if not non-existent?

Regardless of what a provider/HCO may decide, health IT vendors who offer CEHRT-related solutions, will have to remain committed to spending a significant amount of their R&D budgets on MU for the foreseeable future. Vendors who cannot meet this requirement will have to make some difficult strategic decisions over the next year including whether to exit the market entirely.

Consumer Health Data Plays: Vision? Yes. Value? Maybe…

Challenges & Opportunity

In an otherwise slow summer, health IT got caught up in a whirl of excitement last month when Apple, Samsung, Google, and a few smaller players announced their own forays into the digital consumer health space. Each of the three tech titans presented its own unique offering for consumers to store, share, and otherwise manage health-related data about themselves, using a combination of built and partnered hardware and software.

With a macro shift in care delivery away from episodic visits towards data-driven population health management, the health care industry is increasingly interested in a go-to solution that will get patients more directly involved in managing their own health. While the dust has not fully settled, it has become clearer in the wake of initial fervor that these new platforms have a substantial set of challenges ahead of them. In this month’s Domain Monitor, Chilmark Research outlines these challenges and extrapolates their implications for the rest of the industry.

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