Sunday, October 07, 2012

GOP Lawmakers call for suspension of meaningful use incentives

Its obvious that even the pending presidential election does not prevent the outbreak of a silly season on capitol hill. The letter sent by House Republican leaders to HHS Secretary Kathleen Sebelius is such an example filled with inconsistencies, falsehoods and fear mongering. The authors "believe that the Stage 2 rules are...weaker than the proposed Stage 1 regulations released in 2009. The result will be a less efficient system that squanders taxpayer dollars and does little, if anything, to improve outcomes for Medicare." They specifically point out that the Stage 2 regulation lower the threshold of compliance compared to Stage 1 meaningful use. The authors specifically criticize the fact that Stage 2 regulation "fail to achieve comprehensive interoperability in a timely manner" and claim that Stage 2 rules "eliminate the requirement to exchange information with other providers." They further claim that the alleged absence of interoperability standards represents a waste of $10 billion already spent for this program. To top it off they quote a New York times article claiming that EHR technology contribute to higher Medicare spending because EHRs " making it easier to bill for services, whether or not they [ hospitals and physicians] provide additional care." Based on the above arguments the Republican leaders call for a suspension of the incentive payments, significantly increase requirements for meaningful users, take steps to "eliminate the subsidization of business practices that block the exchange of information between providers." Now lets separate facts from fiction and ideology from reality. The Republican leaders and their staff seem to have omitted the fact that physician organizations asked CMS to lower the threshold of compliance and ease the requirements to achieve Stage 2 MU standards. In a letter sent to CMS by the American College of Surgeons,dated July 9th 2012, which was signed and endorsed by 24 medical specialty organization the authors emphasize that the Stage 2 rules may be too ambitious for small practices and " the significant initial price of implementation remains the greatest barrier to its adoption among small practices. For small practices, the high cost of EHR adoption is not offset by existing financial incentives. To the contrary, practitioners face uncertainty regarding the value they will receive. This is because the initial financial benefits of adoption, if they even exist, are difficult to quantify." Based on this request any further tightening of the compliance requirements will jeopardize the EHR implementation and a delay, or suspension, in incentive payments will make it nearly impossible for small practices to even comply with the Meaningful Use requirements. Until now more than seventy percent of hospitals have registered for the EHR incentive payments, and 55% have received their first-year payments. Healthcare organizations have made plans and are looking for that money to be paid to further invest in EHR technology and provider training. Nearly 294,300 physicians and other “eligible professionals” have enrolled for EHR incentive payments under the Medicare, Medicare Advantage and Medicaid programs and not quite 140,500 have been paid, according to the CMS. These funds represent a significant stimulus and provide desperately needed cash flow for financially strapped medical practices. Any suspension of those funds will especially penalize small business owners who will be forced to lay off staff and curtail purchasing. Is this what we need in our struggling economy? I am concerned that the Republican lawmakers, or their staff, have either not read, or misunderstood, the Stage 2 meaningful use objectives. Those clearly state that the test of “exchange of key clinical information” core objective from Stage 1 is eliminated in favor of a more robust “transitions of care” core objective in Stage 2; and the “Provide patients with an electronic copy of their health information” objective is also eliminated because it was replaced by the “electronic/online access” core objective. The final rule adds “outpatient lab reporting” to the menu for hospitals and “recording clinical notes” as a menu objective for both EPs and hospitals. There will be 20 measures for EPs (17 core and 3 of 6 menu) and 19 measures for eligible hospitals and CAHs (16 core and 3 of 6 menu). The final rule reduces some thresholds for achieving certain measures and modifies criteria for exclusions to respond to difficulties commenters identified in implementing certain objectives in certain situations. For example, for some objectives CMS has added exclusions based on broadband availability that allow providers in rural or underserved areas to achieve meaningful use with fewer hurdles. Initially, CMS also proposed two ambitious measures for the "Electronic Exchange of Summary of Care Documents " objective in Stage 2. The first measure required that a provider send a summary of care record for more than 65 percent of transitions of care and referrals. In the final rule CMS is reducing the first measure to a lower threshold of 50 percent. The second measure required that a provider electronically transmit a summary of care for more than 10 percent of transitions of care and referrals, and that the summary of care be electronically sent to a provider with no organizational or vendor affiliation. The intent of this second measure was to foster electronic exchange outside established vendor and organization networks. CMS is finalizing the 10 percent threshold for electronic transmittal, but eliminating the organizational and vendor limitations. Instead, CMS is requiring at least one instance of exchange with a provider using EHR technology designed by a different EHR vendor or with a CMS-designated test EHR. Yes, interoperability is important and we should not relent our focus on this essential issue. But Stage 2 builds on the current phase and starts to emphasize data sharing. The main focus areas is the new requirements and enhanced standards for exchanging information. These rules are a true game changer in advancing interoperability between providers and patients. The goal of these rules is to improve patient outcomes by providing right information at the point of care. Highlights of improved/changed interoperability rules include: Provide summary of care document for transitions of care and referrals Provide online access to health information to patients with more than 5% of patients actually accessing the information Transmit structured electronic lab/image results to ambulatory providers Use secure messaging with patients A major one - use of data portability standards. Standards for coding structured data that is sent in the summary of care documents or other documents. Not only these standards will reduce errors but also will accelerate the use of analytics and secondary uses of the data. Transmission of information to cancer registries. Claiming that EHR technology contribute to higher Medicare spending because it easier to bill for services, whether or not they [ hospitals and physicians] provide additional care, is an insult to all decent physicians and other healthcare providers who, until now, had to accept dwindling insurance payments and intrusive insurance audits. EHR technology provides better documentation and coding tools which guarantees that a physician is being paid for what he does and not for what the insurance company decides he is worth receiving. EHR technology empowers physicians to be paid fairly and not arbitrarily. Its obvious whose side those Republican are representing. Its also obvious that insurance company lobbyist have contributed to the content of this letter and are now trying to scuttle any gains physicians made in achieving fair reimbursement. This letter should be rejected as an example of cheap propaganda and physicians bashing. Yours Bernd

Tuesday, October 02, 2012

Medicaid in Florida

I just returned from Germany where I attended a conference in Berlin. Read the attached excellent article by John Dorschner online in my hotel room and, what a coincidence, that same weekend an article in a German magazine highlighted healthcare cost control measures within the German universal healthcare system. In my opinion the Medicaid reform measures are doomed to fail as long as physician practices are incapable to measure the quality, outcome and costs of care rendered. The fee-for service model rewards volume above value of care and the participating physicians have no other choice but to apply this doomed treatment paradigm to keep their practices afloat. In a recent New England Journal of Medicine article the authors called for reengineering prevention into the U.S. System to accelerate the transition from Sick Care to Health Care. The Patient Centered Medical Home (PCMH) represents the foundation of such a new approach to health care including reconnecting medicine to public health services and integrating prevention into the management and delivery of care. Furthermore, the utilization of information technology tools within a PCMH allows for the value stream mapping for healthcare delivery to determine if what we spent for healthcare translates into cost-efficient, high quality and patient centered care. Eliminating administrative waste, i.e. insurance companies, is part of the value stream mapping process and must be addressed to transform our highly inefficient sick care system into a patient centered health care model. Bernd