ONC & CMS are mandating Interoperability – as soon as they have a definition…
This year’s Summit was refreshing – more protein, less cotton candy. Drs. Kate Goodrich[i] (CMS) and Don Rucker[ii] (ONC) delivered the mornings’ keynote addresses. Each painted a more solid vision for the future that anyone from those two DHHS arms has in past years; but the guidance was aspirational as opposed to operational.
Regardless of progress towards a functioning model for interoperability, our Public Sector appears to remain clueless about the role they’ve assigned LTC Medical Professionals in their script – Population Management.
Here is short list of impressions from the complete meeting:
- CMS is trying to align Quality Initiatives across the continuum – I recall Dr. Goodrich commenting on one of her slides that IMPACT Act measures could be aligned with MACRA/MIPS.
- There are MIPS regulations, designed for Hospital Based Practitioners that allow the EP to use a hospital’s performance measures to calculate a MIPS Score. AMDA’s Alex Bardakh asked how that strategy would work when the majority of LTPAC medical care is delivered by EPs across multiple institutional settings. Unfortunately, her comments demonstrated a continuing misunderstanding about LTPAC Medical Group operations. Only the smallest Medical Practices could manage their quality reporting through the paradigm of a facility’s record. Everyone would appreciate alignment, but the complexity of CMS’s myriad systems defeats any quest for simplicity.
- ONC’s Dr. Rucker was a forceful, and knowledgeable champion for Interoperability. However, with questioning from the audience, it was apparent that the rulemaking which will operationalize Interoperability legislated by the 21st Century Cures Act[iii] is not a reality until FY/CY 2020, at the earliest. What he did say with certainty, that conveyed support at the highest levels of government (i.e. the Administration) – there would be no new funding to develop interoperability for LTPAC, or other settings. If your setting was overlooked in the Meaningful Use incentives for Hospitals and Physicians, just get over it! BTW – for Medicine, the term Meaningful Use is two generations out of date – it was replaced in MACRA/MIPS for 2017-18 by ACI (Advancing Care Information), and that’s being replaced in 2019 by Promoting Interoperability (likely to be known as PI).
- Again, listening between the lines of his guidance – any entity that receives Medicare or Medicaid Payments for a service will have to provide Interoperability[iv] without additional fees.
- If that becomes the regulatory mandate, LTPAC facilities, and their IT vendors will face difficult discussions. How do you pay for the software development that supports this vision of interoperability without funding? If you simply ignore the cost of transitioning clinical terminology from text to structured date – you are faced with enormous costs creating and maintaining a robust IT security environment. Security is a huge challenge in a tightly controlled (closed) system. The Cures Act presupposes the existence of connectivity between Clinical Databases using APIs that are both Open and Secure (a technical possibility, but at a significant development/maintenance cost).
- A keynote presentation that did recognize the key role played by LTPAC Medical Professionals came from Dr. David Gruber[v]. His program titled Provider Survival Strategies in an at-risk Environment: Role of Technology; was the first instance where a HIT Summit keynote speaker articulated the role physicians should play in a risk-based As facility operators face mounting financial headwinds from Medicare /Medicaid payment ‘reform’, nearly their entire LTC population (NF/ALF/ILF) has a primary care physician/Advanced-Practitioner. All the Nursing Facility residents have on-site care, and many ALF/ILF settings are inviting medical groups to be the default on-site care provider.
- Gruber did an excellent job of tying the social/demographic/economic changes created by aging Baby Boomers into the LTPAC space. His comments on Risk Adjustment, and the role of technology/data, were particularly insightful. He did focus on the importance of identifying and managing high cost/risk individuals and effectively managing their care.
- A final keynote speaker worth mentioning was Dr. David Kendrick; he’s a physician leader at My Health Access Network – an Oklahoma based HIE (Health Information Exchange). The LTPAC Summit has always had speakers extolling the benefits of HIEs, but this was the first time one was described which had easy to identify benefits to its subscribers. Its ingenious design combines the best aspects of many existing programs – in a way that creates new value for everyone. His talk didn’t explain the back story, but the network interfaces with Medical Groups, Hospitals, Payors, and the national HIE network. They also provide QCDR (quality clinical data registry) services to their members. This registry has divined how to manage quality data reporting, across multiple providers, at a patient level – with that quality measure data being shared only with the corresponding payor for the patient/service. While that sounds trivial, it is a huge innovation for both the payor and provider community.
The 2018 conference was organized by LeadingAge CAST. Previous conferences were good, but suffered from a disconnection with the business aspects of LTPAC care delivery. Many individuals contributed to making this year’s conference a success, but a special shout-out for the organization’s leader, Majd Alwan. His commitment to fostering appropriate technology for use with the frail elderly population helped focus the conference and expand its utility.
[i] Kate Goodrich, MD, MHS. Director of the CMS Center for Clinical Standards and Quality (CCSQ).
[ii] Don Rucker, MD. ONC/DHHS National Coordinator for Health Information Technology.
[iv] Interoperability Definition (excerpted from the AHIMA summary): Defines interoperability as HIT technology that: (a) enables the secure exchange of electronic health information with, and use of electronic health information from, other health information technology without special effort on the part of the user,
(b) allows for the complete access, exchange, and use of all electronically accessible health information for authorized use under applicable state and federal laws and
(c) does not constitute information blocking.