CMS’ Proposed PI Rule Changes Is A Good Start, But Does It Address Enough?
By Thanh Tran, CEO, Zoeticx.
Federal healthcare organizations, such as CMS, have spent billions of dollars over the years trying to bridge the gap between medical data and quality patient care with interoperability requirements and data integration, the mesh used to try and bridge the gap. Many government rules have been written to address the type of mesh needed and many EHR companies have claimed to meet these government requirements and claim the throne of the ultimate mesh maker.
However, hospitals and clinics found the mesh contained many holes, such as enabling hospitals to customize EHRs, but only if the EHR customers purchased the EHR systems for the manufacturers for millions of dollars that hospitals could ill afford. Also issues such as proprietary connectivity to their own brands that left the hospitals’ other EHR systems to serve as dead-end data silos. Rules and solutions came and went, but few had any teeth until now.
Anyone for A Slice Of PI?
To end the lack of interoperability morass and data duplication, the Department of Health and Human Services (HHS) issued 1,883 pages of proposed changes to Medicare and Medicaid. The changes rename the Merit-Based Incentive Payment System (MIPS) Advancing Care Information performance category to Promoting Interoperability (PI).
CMS announced the change as part of a proposed rule that will transform the EHR Incentive Programs commonly known as meaningful use under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS). The proposed policies are part of the MyHealthEData initiative, which prioritizes patient health data access and interoperability improvements.
But this time the name change wasn’t just that. For the first time a new CMS rule specifically requires providers to share data to participate in the life blood of hospital reimbursement—Medicare and Medicaid. The rule also floats the idea of revising Medicare and Medicaid co-pays to require hospitals to share patient records electronically with other hospitals, community providers and patients — a clear-cut demand for interoperability.
PI also reduces hospital interoperability requirements from 16 to six, revamping the program to a points-based scoring system and is requiring that hospitals make patients’ EHRs available to them on the day they leave the hospital beginning in 2019.
Does Your EHR Have the Right Stuff?
While this news from CMS appears to be a step in the right direction to solve a problem that has plagued the healthcare industry for many years, it must first be made a reality by those ultimately responsible for its implementation—hospital HIT organizations. The days of data obstruction and silo logic must end with a focus on new EHR markets built on interoperability.
Interoperability requires multiple layers to demonstrate an EHR system can be accessed. Meanwhile, every EHR system claims to support some form of interoperability, ranging from web interfaces to API protocols or to the lowest and highest cost HL7. However, healthcare systems will have to demonstrate their operability to CMS to abide by PI and therefore allow access of their EHR systems. Hospitals and clinics can encounter many challenges with this, such as HIPAA compliance and support for their infrastructure for open secure access, requiring an HIE and the funds to support data synchronization and IT support.
CMS Needs to Offer More Than Just PI
As interoperability rules are opening to the benefits of providers, health institutes and patients, it is also a good time to consider the growing need for interoperability, integration and convergence in healthcare across clinical, financial and operational systems. When you consider the massive amount of data held in EHRs that can be transformed into information and knowledge, there is a lot at stake across the healthcare continuum.
The road to releasing this data is not difficult and can lead to curing diseases, enabling doctors to spend more time with patients and saving health carriers billions of dollars. One of the easiest HIT methods for integrating the data is with simple, cloud-based apps that can also optimize patient data while driving healthcare facility financial incentives such as identifying cost savings and streamlining insurer payments.
Integration of Physical and Behavioral Health
The healthcare industry is now looking at revenue that can be generated through the interoperability of treatments, such as AWVs, chronic care and service care transitions between physical and behavioral health services. Hospitals and healthcare clinics that can connect these services with technologies such as bi-directional information flow will benefit by creating new profit centers of revenue through reimbursements by CMS and private insurers. This benefit alone is a great incentive for consideration by the healthcare industry and CMS.
AWVs were first introduced by private insurers and then by CMS in 2011 as part of its preventive care initiative under the Affordable Care Act (ACA). AWV’s are designed specifically to address health risks and encourage evidence-based preventive care in aging adults. AWV data is a key healthcare growth catalyst for medical institutes with its treasure trove of patient data. That data, when streamlined, can enable expedited payments to government and private insurers.
Another candidate in the care continuum of data integration is treatment for chronic diseases, ranging from diabetes to dementia and behavioral and mental health issues, such as the opioid epidemic, heroin addiction, alcoholism and PTSD suicide. Patients in these situations are often unable to receive the care they need to address physical or mental health issues let alone integration of services.
Meanwhile, the final set of data for integration consideration is mental health and physical care, a traditional challenge. Treating the whole person through the integration of behavioral health and general medical healthcare can save lives, reduce negative health outcomes and facilitate quality care while promoting efficiency and cost savings.
A good example of the importance of the linking of mental, behavioral and physical health is when a patient completes a full behavioral health treatment, they still must often contend with medical issues like hypertension, diabetes, depression and possibly more. Patients can easily fall back into drug addiction and alcoholism if surrounding symptoms are not treated, placing even greater importance on collaboration.
We are at the inflection point where involvement with building useful workflows that are in sync with the needs, values and channels through which patients and providers interact with the healthcare system. When we integrate data, we understand the technology is not only to make our lives easier, but ultimately to enhance the care we can deliver, as measured by the outcomes and functionality to the patients we deliver our care.