Daylight Savings Time Ended – Did the hospital charge you less?

In the spring of 2014, I wrote a post about possibly getting over-charged for a hospital stay due to synchronizing EMR systems to the correct time. Similarly, this past weekend, when Daylight Savings Time ended, some patients may not have a second bed charge added for the hour that is repeated due to an occurrence in the system.

Many organizations may have the ability to manually update their charges in what is called the hospital billing account after a patient is discharged. This though is a step more than many organizations have the bandwidth to work on these days with all of the regulatory mandates that they are working on.

With Healthcare Payer organizations rejecting claims for even minor defects, this could be a major revenue loss for any provider and would need to have a consistent remediation for Patient Financial Services to be on track with their forecasts. It would be more than likely that they will not unless a patient reviews their charges more carefully. Data for the hour of the double 2am time on Sunday needs to be well documented and validated. Most responsible provider IT Revenue Cycle Management organizations have plans for the time change that have been scheduled far in advance and would be reviewed as I document this post. Is this another reason why we may not need to keep changing back and forth from Daylight Savings Time. Is this one of the reasons why the concept may be moot going into the 21st century? Time will tell.

Advancing Clinical Processes with Meaningful Use Stage 2

As provider organizations work on the completion of stage 1 and think about implementation of stage 2, they will have their hands full with how to implement these initiatives with the constraints on their resources and bandwidth. The CMS site states that:

“Stage 2 uses a core and menu structure for objectives that providers must achieve in order to demonstrate meaningful use.

Core objectives are objectives that all providers must meet. There are also a predetermined number of menu objectives that providers must select from a list and meet in order to demonstrate meaningful use.

To demonstrate meaningful use under Stage 2 criteria—

  • Eligible professionals must meet:
    • 17 core objectives
    • 3 menu objectives that they select from a total list of 6
    • Total of 20 objectives
  • Eligible hospitals and CAHs must meet:
    • 16 core objectives
    • 3 menu objectives that they select from a total list of 6
    • Total of 19 objectives

In a recent article in Healthcare IT News (dated 8/4/14), it stated that only 3% of eligible hospitals and 1% of eligible providers attested to stage 2, which is anything but great as we are in the middle of 2014, when all of the provider organizations were expected to be greatly involved in completing their attestations. Have we reached “MU Fatigue”? I can imagine. I met a nurse earlier today who has now been in IT for sometime and she said that she did not believe CMS anymore after the ICD-10 delay occurred. I think that set off a wave of disinterest in the ecosystem that is still feeling the repercussions of a twice delayed regulatory mandate. “It doesn’t pay to be first!” said one CIO to me a few months ago. Going by the frequent delays in the provider world, one can empathize with that sentiment.

Will CMS give out “Red Cards” to Eligible Hospitals and Providers and penalize them or will there be some relief for the regulatory weary? In the same article, it mentioned that “71% of hospitals plan to attest by the end of 2014 and 22% in 2015”.

What of the HIEs and their ability to give the prospect of intereoperability it’s day?If we are truly to believe the data from the news article, the next 13-14 months will be a busy period for many as ICD-10 comes back around; payer testing, dual coding, physician training and organizational communications will be again an extremely busy period for many provider organizations.


Physicians are people too…right?

When it comes to working with physicians,  we’ve seen their involvement in this healthcare technology world at opposite ends of the spectrum.

The younger,  more technologically savvier physicians who have been used to technology from the early 80s to now, seem to somewhat adapt to using EMRs. They are characterized by their comfort with all things digital and their disdain for a paper process and being eco-friendly. While this isn’t always the case, this is mostly attributed to younger, 45/50 and under physicians.

The older,  more experienced physicians who have been around practicing for 3 decades or more have generally been extremely resistant to the current change and have at times,  even retired rather than continue to use EMRs on the grounds that it takes away from their focus on the patient, which can make for an good debate. I’ve also heard that some of the older physicians don’t feel like they need to be “engaged with their patients” as “the way they have been practicing medicine all these years is fine”. Millennial physicians,  early to mid 30s take to technology as if they were born with it. As digital natives,  they have the ability to be the most productive and efficient when it comes to EMR usage.

Also, their has been a divide when it comes to adoption by small and large practices. Smaller practices have had to think about how they can deal with the process of purchasing EMR capabilities and this has not always been easy. During a project in California, we studied how we can get pediatricians to refer patients to the hospital I was working at and how to make sure the referral process was smooth for them; whether it was directly from their PC and their own EMR system or if they needed to login to a portal with their credentials and how it would then go to the correct clinic at the specialty pediatric facility I was working at the time.

For anyone in the care delivery IT arena, this is old news, but really needed to be said. The question is whether if the digital divide has an impact on the quality of your care and if this trend continues, will we lose our senior, experienced physicians to Meaningful Use?

According to an article out by USA Today (dated 6/30/2014), the United States is expected to need 52,000 more primary care physicians by the year 2025 based on research by the Robert Graham Center and funding for teaching hospitals expires in the latter part of 2015. Due to the Affordable Care Act, the need for family physicians to 8000. As a nation, we cannot afford to lose these experienced physicians at a juncture when more physicians are required than ever before.

MU gets a Breather! Healthcare Providers heave a sigh of relief!

MU breather1 Marilyn Tavenner, the CMS Adminstrator announced last Thursday at HIMSS ’14 in Orlando that CMS would be flexible on “hardship exemptions” for meaningful use requirements, which I am sure the healthcare industry heaved a collective sigh of relief.

Expectations were high for this to happen as it had been suggested earlier that this was to come.

In reviewing the CMS document titled “Payment Adjustments & Hardship Exceptions Tipsheet for Eligible Professionals” that was last updated in  October 2013 has hardship exemptions for eligible professionals with the following information:

EPs can apply for hardship exceptions in the following categories:

*Infrastructure — EPs must demonstrate that they are in an area without sufficient internet

access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).

 New EPs

— Newly practicing EPs who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments. Thus EPs who begin practice in calendar year 2015 would receive an exception to the penalties in 2015 and 2016, but would have to begin demonstrating meaningful use in calendar year 2016 to avoid payment adjustments in 2017.

Unforeseen Circumstances

—Examples may include a natural disaster or other unforeseeable barrier

Patient Interaction:

1.  Lack of face-to-face or telemedicine interaction with patients

2.  Lack of follow-up need with patients

Practice at Multiple LocationsLack of control over availability of CEHRT for more than 50% of patient encounters 

With the number of initiatives currently under way at every single care delivery organization, ICD-10, optimization, Patient Portals, Patient Engagement, workflow optimization and so on, we continue to move at, what can only be considered, lightening pace through this decade as we regain American dominance in the healthcare technology sector and then shift our focus to lowering the cost of care delivery and leverage process improvements, better preventative care options.

With current clinician retirement trends the way that they are, I also foresee a great need for qualified physicians and clinicians over the next few years and migration to the United States for technology savvy medical professionals from other countries could assist with this demand in major population centers across the country.

Looking back at 2013

As we come to yet another year end, we reflect back on the year. There is a new leader at ONC, the ICD-10 transition is truly happening, Meaningful Use Stage 2 has had some changes, more healthcare provider organizations in the United States have implemented an Electronic Health Record and Patient Engagement initiatives are off to the races. IT Departments within provider organizations are busier than ever and many EMR experienced resources continue to turnover as the industry slowly matures.

With 2014’s imminent arrival and initiatives culminating during that time, good advice would be to stay focused, remember that stay ahead of the game and make sure to try and get as much done in advance as possible so that there is time for adjustments as you get closer to the dates that projects are required for completion. For ICD-10, vendors really need to bear in mind that they are holding up project completions across the country and need to be aware that if they want to charge customers to be ICD-10 compliant with their software, they risk potential loss of relationships with those customers. Most vendors have not charged their provider customers with an ICD-10 compliant version and that is the best thing that they could have done. If you don’t have an ICD-10 compliant version of your software by now or have a statement of readiness, recommendation would be to re-evaluate your vendor and product and think about alternatives.

Think about the cloud, think about what it would take to get there. This year is also about analytics. With all of this information now at your fingertips, think about how the organization can leverage this information to achieve better outcomes. XP to Win7 migration is around the corner. Be mindful of the risks associated with HIPAA. Think about the enterprise architecture your organization has. In 2014, this blog will discuss these topics, including a topic covering areas that cover the patient experience and security as well.

Until then, stay safe, enjoy your New Year’s celebrations and see you in 2014.

HIPAA and the Art of Security Maintenance

After the HIPAA Omnibus Rule went into force on September 23rd, 2013, the focus on security and compliance became that much more important for healthcare organizations around the country.

The U.S. Department of Health and Human Services Office for Civil Rights announced the final rule that asked for the implementation of a number of provisions of the HITECH Act, enacted as part of ARRA in 2009, to strengthen the privacy and security protections for health information established under HIPAA.

The press release said that the changes that were announced expanded on many of the requirements to business associates of entities that receive protected health information, such as contractors and subcontractors. Some of the largest breaches reported to HHS have involved business associates. Penalties are increased for noncompliance based on the level of negligence with a maximum penalty of $1.5 million per violation. Also patients can request a copy of their electronic medical record in an electronic format and when you pay by cash you can ask your provider not to share information about your treatment with their health insurance payer.

In addition, the Omnibus rule makes it is easier for parents, guardians and others to give permission to share proof of their child’s immunization records with a school and gives covered entities and business associates up to one year after the 180-day compliance date to modify contracts to comply with the rule. Security Officers and legal departments within healthcare organizations have certainly been occupied with this and other compliance initiatives including proper discarding of paper documentation within an organization. Initiatives such as shredding of unused paper copies of manuals which do not need to be around an organization in this day and age and usage of electronic copies of documentation, would assist in streamlining organizational workflows and start to see the true benefits of electronic medical records.

What was the 80/20 Rule in the Affordable Care Act?

Has the 80/20 Rule delivered  value? What was it? It is a rule in the Affordable Care Act that holds healthcare payers  accountable to consumers and is supposed to ensure that families receive value for their premiums paid.

Due to healthcare reform, payer organizations now must disclose how much they spend on health care and how much they spend on administrative costs, such as salaries and marketing. If a payer spends less than 80% (85% in the large group market) of the premium on medical care and efforts to improve the quality of care, they must send a rebate check for the portion of premium that exceeded this limit to the consumer.

This rule is commonly known as the 80/20 rule or the Medical Loss Ratio (MLR) rule.  

Consumers are supposed to benefit from the 80/20 rule in two ways:

1)  Benefit upfront because payer organizations now keep premiums lower and operate more efficiently in order to meet the 80/20 rule.

2)If a Payer doesn’t meet the 80/20 rule, then the consumer benefits anf receives a rebate for the amount that exceeds this threshold.

According to CMS, in 2012, the 77.8 million consumers in the three markets covered by this 80/20 rule saved $3.4 billion on their premiums (I got a surprise check from my payer so I can vouch for this)  because of the 80/20 rule and other Affordable Care Act programs.

Payer organizations should have paid the rebates by August 1, 2013.