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Entries Tagged 'Patient Protection and Affordable Care Act' ↓

Increased Transparency

Posted by ClearDirections on June 28th, 2011 in Accountable Care Organization, Hospital Management, Patient Protection and Affordable Care Act | No Comments

HIPAA, HHS, Affordable Care Act, ACO
Recently the Department of Health & Human Services (HHS) proposed new modifications to the more than decade-old HIPAA rules. The current proposal by HHS seeks to create a system that provides more information to individuals about who is accessing and using their healthcare information. These changes appear to be in line with the Affordable Care Act proposed rules, given they lead to greater accountability for entities in how they guard protected health information.

HHS proposes to alter the Privacy Rule by dividing it into two sections, one about the right of an individual to an accounting of disclosures and the other for the right of an individual to an access report. In doing so, HHS also has proposed to broaden the scope of information to be accounted for by including business associates, while at the same time narrowing the time frame to be covered when accounting for information from six years to three years. Also, currently entities are only tasked with listing the types of disclosures that are exempt from an accounting of information, but under the proposed rule, entities would also list each disclosure.

The provision would limit the protected information to be accounted for to information believed to be most important to individuals, which would include health care and payment decisions about an individual. These records would be maintained in a designated record set. Other information would remain protected under the Privacy Rule, even though tracking in a designated record set is not required. For covered entities to maintain such records, they will need to ensure that their EHR system is up-to-date and has the capability to access and create these reports.

These changes appear to better align the HIPAA Privacy Rule with the proposed Affordable Care Act and will be important to note for covered entities. For more information about EHR systems and IT development, feel free to contact us.

We have provided a general overview here of HHS’ proposed changes to the HIPAA Privacy Rule, For an in-depth reading of these changes, click here to access the proposal.

Could this be the IT ACOs need?

Posted by ClearDirections on June 22nd, 2011 in Accountable Care Organization, Hospital Management, Patient Protection and Affordable Care Act | No Comments

Microsoft has been refining its health IT offering, the Amalga system, which proposes to integrate information from many different health IT systems into one platform, which allegedly will ease the pain of shifting to an ACO.. Several components of this system have been in development for several years and are reported to answer most of today’s healthcare information needs:
• Microsoft Quality Measures Manager
• Microsoft Health Vault
• Medical Imaging Module
• Readmissions Manager

Once the information is integrated within Microsoft’s Amalga system, it can be viewed and utilized in many different ways depending upon who is using the information. This will reduce redundancy currently occurring in the healthcare industry by allowing all medical professionals within a particular ACO to access patient information and medical histories.

Several different applications comprise the Amalga health IT data integration platform. Microsoft Quality Measures Manager simplifies the quality data aggregation and measurement process. Another is the Microsoft HealthVault, which is a web interface patients use to store their health data and selectively share their medical history with healthcare providers. The medical imaging module for Microsoft Amalga organizes medical images and allows them to be viewed by other healthcare providers in an ACO. Another tool is the Readmissions Manager, which tracks details about readmissions of patients to aid in understanding the causes of patient readmissions.

This brief overview of Microsoft Amalga gives us a sense that the über IT solution for ACO may be here or is yet to come. In either case, it appears that this software platform may speed healthcare leaders’ move toward ACO readiness. Check it out at http://www.microsoft.com/en-us/microsofthealth/products/microsoft-amalga.aspx.

Do you have what it takes to be part of an ACO?

Posted by ClearDirections on April 9th, 2011 in Accountable Care Organization, Financial, Hospital Management, Patient Protection and Affordable Care Act | No Comments

Reading the 460+ pages of proposed ACO regulations (42 CFR Part 425 to be exact) has been a daunting task, but a necessary one for those of us who will lead the world of healthcare through this unprecedented sea change to our system. To help you wrap your organization’s strategy around this new concept, we will break down the salient parts of the regs for our readers, bit by bit.

One of the most important features of the new regs is the “three-legged stool” of the Shared Savings Program:
– to provide better care for individuals;
– to encourage better health for the whole population; and
– to lower the growth of healthcare expenditures.

The Shared Savings Program promotes accountability for a patient population’s health, coordinates patient care and encourages providers to invest in infrastructure and redesigned care processes for high quality and efficient service delivery. This Shared Savings Program will be in place by January 1, 2012, according to the proposed regs. Now, the key is how to qualify to participate in the Shared Savings Program.

The new regs outline several requirements to be eligible to be part of an ACO. Providers must be willing to:

1. Become accountable for the quality, cost and overall care of the Medicare FFS beneficiaries assigned to them;

2. Enter into an agreement to participate in the ACO for at least three years;

3. Have a formal legal structure that allows the organization to receive and distribute payments for share savings to the participating providers;

4. Include enough primary care ACO professionals sufficient for the number of beneficiaries assigned to the ACO, and each ACO will have a minimum of at least 5,000 beneficiaries assigned to it;

5. Provide CMS with any information the government deems necessary to support three things: the assignment of Medicare beneficiaries to the ACO, the implementation of quality and other reporting requirements, and the determination of payments for shared savings;

6. Have in place a leadership and management structure that includes clinical and administrative systems;

7. Define processes to promote evidence-based medicine and patient engagement, report on quality and cost measures, and coordinate care (i.e., telehealth and remote patient monitoring); and

8. Demonstrate that they meet patient-centeredness criteria specified by CMS (think HCAHPS), such as the use of patient and caregiver assessments or the use of individualized plans.

Just a few things … right? Well, take a day to digest this portion of the regs and we’ll explain later how CMS has proposed very detailed specific formulas to determine how the Shared Savings Program works. Hint … providers won’t receive a portion of ALL of the savings they deliver to Medicare. CMS has proposed a Minimum Savings Rate or MSR that ranges from 2.0% to 3.9% before an ACO can begin sharing in the savings. More to come on this in future posts.

If you enjoyed this material, please share it with other healthcare executives you know, so we can help them get their heads around ACOs quickly and painlessly to position them to compete better in the brave new world of ACOs.

Healthcare Innovation … Where Does It Exist?

Posted by ClearDirections on February 26th, 2011 in Accountable Care Organization, Communication, Innovation, Legislation, Patient Protection and Affordable Care Act | 1 Comment

“For innovation to be meaningful, it must always take the customers’ point-of-view. … Innovation simplifies your business to its critical essentials. … It should make things easier for your people in the operation of your business, otherwise it’s not innovation but complication.”

-Michael E. Gerber,The E-Myth Revisited

Innovation in an industry that is being rocked by the most wide-sweeping change since the advent of Medicare on July 30, 1965, is not only important – it is imperative. With the new and continual change on the horizon under the Patient Protection and Affordable Care Act (PPACA) signed into law by President Obama nearly one year ago, all product and service providers to the care of the human body need to examine all the leverage points for their businesses/organizations. These industries that help us keep our human chassis in top shape or attempt to repair them when they are “run down and broken” stand to offer value under the proposed delivery chain of the Accountable Care Organization (ACO).

According to Elliot Fisher, MD, MPH who is credited as the father of the term, ACO, defined an ACO as such in a 2010 article on he co-authored:

ACOs consist of providers who are jointly held accountable for achieving measured quality improvements [note that “measured quality improvements” is synonymous with report cards] and reductions in the rate of spending growth. Our definition emphasizes that these cost and quality improvements must achieve overall, per capita improvements in quality and cost, and that ACOs should have at least limited accountability for achieving these improvements while caring for a defined population of patients.

So, if PPACA and ACOs stand the test of Congressional time, gone are the days of finger-pointing on why a patient’s health status doesn’t improve, and finally patients and their family members might have a prayer of a chance of better “hand-offs” (as I like to call them) through stronger accountability and communication between care providers. In fact, just this morning I helped a group of MBA students at Kellogg Graduate School of Management review their business plan for a cool new communication tool that would help hold patients and their post-acute discharge caregivers more accountable for compliance with their prescribed regimen. It’s these types of business innovations that will create the proverbial win-wins for American healthcare. So, we know healthcare innovations are emerging from America’s top business schools. Where else does innovation exist?

Few likely know that Don Berwick, MD, head of the Centers for Medicare and Medicaid Services, is overseeing the new Center for Medicare and Medicaid Innovation. The Innovation Center claims it will “consult a diverse group of stakeholders including hospitals, doctors, consumers, payers, states, employers, advocates, relevant federal agencies and others to obtain direct input and build partnerships for its upcoming work. This dialogue will center on three areas of emphasis consistent with the Innovation Center’s goals.

* Better Care for Individuals: Improving care for patients in formal care settings like hospitals, nursing homes, and doctors’ offices, and developing innovations that make care safer, more patient-centered, more efficient, more effective, more timely, and more equitable. The Innovation Center will also promote the use of “bundled payments,” a more efficient approach to paying for care where providers collaborate to manage multiple procedures as part of a single episode with a single payment, rather than the current fee-for-service method of submitting separate bills for each procedure, which leads to higher costs.
* Coordinating Care to Improve Health Outcomes for Patients: Developing new models that make it easier for doctors and clinicians in different care settings to work together to care for a patient. Examples include identifying and widely deploying the best advanced primary care and health home models, and supporting innovations in accountable care organizations.
* Community Care Models: Exploring steps to improve public health and make communities healthier and stronger. The Innovation Center will work to identify and address major public health crises and the appropriate interventions for areas of great concern, such as obesity, smoking, and heart disease.”

Sounds wonderful, right? Well, if the “freshness” of the site for The Innovation Center is any indication of how innovative this new entity will be, I’m a bit concerned. The events page doesn’t even display a February calendar and it’s nearly March. And, the latest blog post is dated Nov 16, 2010. If those like us who deeply care about the healthcare system we leave to future generations abdicate the charge for innovation to the government, this sweeping change will not happen. And, the business thought leader Michael Gerber’s definition of innovation just becomes another jargon-ridden alphabet soup served by Congress. As Gerber said, it will not be “innovation, but complication.” Innovative business leaders in this country absolutely need to step forward to help create the new American healthcare system. Maybe Michael Gerber will join the conversation with us?