Health systems and EHR vendors have been working for months to comply with the ONC’s final rule on interoperability and information blocking that goes into effect in April and is expected to grant patients unprecedented access to their health information. Here is a look at some of the issues they contended with.
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As a quick recap, there are three categories of “actors” to whom the law applies: health care providers, health IT developers of certified health IT, and health information networks (HINs)/health information exchanges (HIEs). Based on the information blocking law, in general, if these three types of actors engage in practices that interfere with the access,
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When 2020 began, no one anticipated that complying with the Merit-based Incentive Payment System (MIPS)—the flagship payment model of the Centers for Medicare & Medicaid Services (CMS) Quality Payment Program (QPP)—would look so different halfway through the year. Like many other things, the COVID-19 crisis has delayed, diverted, or derailed many organizations’ reporting efforts and capabilities. Lower procedure volumes, new remote work scenarios, and shifting priorities have taken attention away from MIPS work.
Despite the disruptions and uncertainties associated with the pandemic, healthcare organizations should not lose track of MIPS compliance and the program’s intent to improve care quality, reduce costs, and facilitate interoperability. Here are a few strategies for keeping a MIPS program top of mind.
Understand the immediate effects of the pandemic on MIPS reporting
Due to COVID-19, CMS granted several 2019 data reporting exceptions and extensions to clinicians and providers participating in Medicare quality reporting programs. These concessions were enacted to let providers focus 100% of their resources on caring for and ensuring the health and safety of patients and staff during the early weeks of the crisis. For the 2020 MIPS performance period, CMS has also chosen to use the Extreme and Uncontrollable Circumstances policy to allow requests to reweight any or all of the MIPS performance categories to 0%.
Clinicians and groups can complete the application any time before the end of this performance year. If practices are granted reweighting one or more categories but submit data during the attestation period, the reweighting will be void and the practice will receive the score earned in the categories for which they submit data
Seize the opportunity to improve interoperability
Interoperability is a key area that organizations were focused on before the crisis, and this work still warrants attention. If an organization is not on the front lines of the COVID-19 response, it should use this time to shore up communications with other entities so, once things return to “normal,” it will be well prepared to seamlessly exchange information with peer organizations.
Establishing processes for sending and receiving care summaries via direct messaging is important for practices to earn a high score in the Promoting Interoperability category. Direct messaging is a HIPAA-compliant method for securely exchanging health information between providers, which functions as an email but is much more secure due to encryption. A regular pain point organizations face is being unable to obtain direct messaging addresses from peer organizations, including referral partners.
To assist providers in this area, the Office of the National Coordinator for Health Information Technology (ONC) and CMS has created a mandatory centralized directory of provider electronic data exchange addresses published by the National Plan & Provider Enumeration System (NPPES). The NPPES directory is searchable through a public API and allows providers to look up the direct messaging addresses for other providers. To meet current interoperability requirements, providers must have entered their direct messaging address into the system by June 30, 2020. If they haven’t done so, the provider could be publicly reported for failure to comply with the requirement, which could constitute information blocking.
Take time now to ensure direct messaging addresses have been entered correctly for all members of your practice. This is also a good time to begin reaching out to top referral sources to make sure they are also prepared to send and receive information.
Look for ways to streamline quality reporting
Over the next few months, the focus will return to quality measure reporting. As such, it’s wise to take advantage of this time to ensure solid documentation and reporting methods. Electronic medical records (EMRs) can be helpful in streamlining these efforts.
For example, dropdown menus with frequently used descriptions and automated coding can enable greater accuracy and specificity while easing the documentation process for providers. Customizable screens that can be configured to include specialty-specific choices based on patient history and problem list can also smooth documentation and coding, especially if screen layouts mirror favored workflow.
Regarding MIPS compliance in particular, it can be helpful to use tools that offer predictive charting. This feature determines whether a patient qualifies for preselected MIPS measures in real-time and presents the provider with data fields related to those items during the patient encounter—allowing the physician to collect the appropriate information without adding additional charting time later on.
With respect to reporting, providers may benefit from using their certified EMR in addition to reporting through a registry. At the beginning of the MIPS program, providers could report through both a registry and EMR directly and would be scored separately for their quality category through each method. They would then be awarded the higher score of the two. This method had the potential to leave some high-scoring measures on the table.
Beginning in 2019, providers reporting through both registry and EMR direct are scored across the two methods. CMS uses the six highest scoring measures between the two reporting sets to calculate the provider’s or group’s quality score, potentially resulting in a higher score than the provider would earn by reporting through either method alone.
A knowledgeable partner can pave the way to better performance
COVID-19 has impacted healthcare like no other event in recent history, and it’s not surprising that MIPS compliance has taken a back seat to more pressing concerns. However, providers still have the opportunity to make meaningful progress in this area. By working with a technology partner that keeps up with the current requirements and offers strategies and solutions for optimizing data collection and reporting, a provider can realize solid MIPS performance during and beyond this unprecedented time.
About Courtney Tesvich, VP of Regulatory at Nextech
Courtney is a Registered Nurse with more than 20 years in the healthcare field, 15 of which have been focused on quality improvements and regulatory compliance. As VP of Regulatory at Nextech, Courtney is responsible for ensuring that Nextech’s products meet government certification requirements and client needs related to the regulatory environment.
As if 2020 couldn’t be
any more challenging for healthcare providers, new federal rules on
interoperability and patient access, granting patients direct access to their healthcare
data, begin taking effect this November and continue into 2022. These rules,
while ultimately beneficial to patients, bring an additional level of
operational complexity to many revenue-stressed healthcare organizations.
If anything, the 2020 pandemic has illustrated the vast potential of interoperability. For example, consider the huge increase in 2020 in virtual care visits, projected to be more than 1 billion by year’s end, and with an estimated 90% related to Covid-19. Many of these new virtual health patients will move through different care networks, using different health plans, and seeking remote access to their health records. These are precisely the type of patients’ interoperability is meant to help.
What should healthcare providers be doing now to ensure they’re not only compliant with new interoperability rules, but also applying them as optimally as possible to benefit their patients and organizations? In this article, we review the upcoming rules and suggest five key steps providers can take to ensure their interoperability implementations proceed as smoothly as possible.
What’s Ahead with
After several years of discussion on interoperability standards, the Office of the National Coordinator (ONC) for Healthcare IT and the Centers for Medicare & Medicaid Services (CMS) issued their final rules on interoperability in the spring of 2020. The new rules, covering both health systems and health plans, are intended to ensure that patients can electronically access their healthcare information regardless of health system or type of electronic health records (EHR) and covering all CMS-regulated plan types, including Medicare Advantage, CHIP, and the Federally Facilitated Exchanges.
Starting Nov. 2, 2020, healthcare systems must begin complying with interoperability rules preventing information blocking, which means not interfering with patients’ access to or use of their electronic health information. Providers must also attest they are acting “in good faith” regarding preventing information blocking, with any non-compliance flagged on the National Plan and Provider Enumeration System. By May 1, 2021, hospitals, psychiatric hospitals, and critical access hospitals with an EHR must send notification of their patients’ admission, discharge, and transfer (ADT) events to providers.
Interoperability will replace the current fragmented and error-prone ways of exchanging vital healthcare information. Near-term benefits of interoperability include improved care coordination and patient experience, greater patient safety, and stronger patient privacy and security. Longer-term benefits include higher provider productivity, reduced healthcare costs, and more accurate public health data.
For providers, the good
news about interoperability is that they’ve had years to think about and
implement many of its fundamental tenets, based on their work meeting
meaningful use requirements. That’s borne out in a 2019 HIMSS survey of
healthcare organizations which found nearly 75% of respondents past the
“foundational” level of interoperability – “foundational” defined as allowing
data exchange from one IT
system to another, but without data interpretation.
Five Steps for
While healthcare systems
will achieve significant interoperability gains through technology investments,
they should not consider technology as the ultimate sole key to
interoperability success. If anything, financial and political considerations
may be far more important to your organization’s interoperability success. Here
are five critical non-technology factors to consider:
1. Determine your “master”
All pertinent stakeholders in your organization should be on the same page about your interoperability strategy, resources, and timing. Know up-front that those implementing interoperability may not have previously worked with patient-centric analytics, partners, or departments in your organization. Plan your resources and timing accordingly. Your strategy should focus on the value-add of interoperability internally, such as access to additional data points on your patients, and externally, such as how you describe the upcoming benefits of interoperability to your patients.
2. Convey your vision, expectations
and expected return
An interoperability implementation is
a massive change management initiative, which requires continuous, top-down
leadership and championship, and proper expectation-setting. Communicate where
your organization currently stands regarding its interoperability capabilities,
and where you wish to have it go. Convey how the organization plans to get to
its future desired state. And perhaps most importantly, share the likely return
on investment in this effort. Be as specific as possible. For example, if you
believe interoperability gains will ultimately enable a 5% decrease in your
hospital readmissions, state that.
3. Examine workflows and identify
specific use cases
Every type of ADT event in your
organization, and its corresponding workflows and system interactions, should
be under review. Consider all types of clinical use cases, the types of data to
be exchanged, and those involved in providing patient care. This will help
determine your optimal approach to data-sharing and how your organization can
strategically use the additional data you receive from other health
4. Rigorously prep your data
Standardized data collection and reporting
which produces quality data is the heart and soul of successful
interoperability. Be sure your organization’s data is clean and meaningful, and
will ultimately be understandable and useful to your patients.
5. Think big-picture differentiation
There’s nothing in the ONC and CMS
interoperability rules that says you need to stop at mere rules compliance.
Consider your pursuit of interoperability as a singular opportunity to be a
patient-centric leader in your market. Let everyone relevant know of the
success you’ve achieved.
offers a chance for healthcare systems to achieve multiple operational gains,
when handled well, it is ultimately a patient-centric endeavor. Always keep the
needs and interests of your patients at the core when facilitating access to
their personal health data. It’s the ultimate smart long-term interoperability
The COVID-19 pandemic has forever changed patient expectations for healthcare delivery, including offered services and health office operations. Although health systems have remained dynamic in adopting telehealth capabilities, their long-term capital, like real estate and supply chain management (SCM) protocols, have not adapted to match these expectations. Health systems must be aware of current trends in both areas to inform their future decisions.
Divesting in healthcare real estate is also key to reducing unnecessary costs to a health system, especially if optimal use of these spaces is already lacking. The overwhelming costs of ownership and management lock money away in underutilized and obsolete real estate spaces. Divesting provides more capital liquidity, and frees capital to go towards investment in telehealth, diagnostic technology, and emerging specialties, assets that go towards increasing patient and workforce engagement and satisfaction. In addition, eliminating unused real estate assets allows freedom from liabilities and human capital investments, like facility maintenance and upkeep, not to mention the increased frequency of deep cleaning necessary in the post-COVID-19 bi-lateral operations era.
Further, years of mergers and acquisitions in the healthcare industry have left many health systems with the unwanted result of increases in real estate assets. This has led to increased consolidation of these assets, a trend that has been exacerbated by the pandemic pressure on health system funds. Future consolidation and reevaluation of assets should be informed by trends in patient expectations as well as trends in the market.
Here are five emerging trends driving the future of healthcare real estate and assets. Each encourages divestment out of health system real estate ventures or restructuring of existing spaces in order to better cater to forever changed patient expectations.
1. Rise of Telehealth
According to the Department of Health & Human Services, telehealth use is up around 50% in primary care settings since the beginning of the public health emergency and is projected to remain high in the time following. Most recently, in-person visits have increased and as a result, telehealth visits have declined due to the state’s reopening, and thereby some critics posit that this trend may not continue. However, that could not be further from the truth.
Moving forward, despite health system fear regarding long-term reimbursement may be lacking from federal, state, and commercial health plan payers for virtual care delivery, leveraging telehealth to augment traditional healthcare delivery will become a necessity because consumers will demand it and physicians in some studies have shown satisfaction with their video visit platforms. This will no doubt have an impact on office layout and services.
2. Convenience of Outpatient Services
Motivated in part by telehealth utilization, patients seek convenience and accessibility in their healthcare now more than ever. Health system expansion may therefore mean satellite offices in high traffic areas to cater to the patient’s need for accessibility, marking a movement away from the traditional, centralized hospital campuses.
3. Value-Based Care Transitions
As legislation and CMS regulation moves more towards a value-based care system, trends show a natural move towards lower-cost facilities that provide preventive care. These could also contribute to continued trends to more off-campus real estate and planning for alternative care delivery options, for example, mobile vans reaching more vulnerable, at-risk populations for care such as life-saving vaccinations.
4. Pandemic Precautions
Bilateral operations are likely to be maintained for some time even after more normal operations return, and healthcare real estate, especially with consolidation, will need to accommodate this precaution, and others like it in all locations.
New diagnostic and testing tools are constantly being released, forcing health systems to reevaluate their current assets and make room for new ones which contributes to wasted space. Furthermore, remote monitoring apps will continue to proliferate in the market and become more affordable and accessible to consumers while advancing interoperability standards and federal information blocking requirements will allow information to flow more freely.
Strategies to Optimize Healthcare Real Estate & Strategy
In order to unlock money trapped in assets, health systems should look to make their assets work better in response to current trends and patient expectations. To accommodate patient demands and changes to health industry regulation and reimbursement, it makes sense to ensure efficient use of all facilities and optimize real estate and assets using the following strategies:
– Divest underutilized assets of any kind: Begin with real estate and move smaller to reduce unneeded capital investment.
– Remove or reduce administrative spaces: Transition non-clinical workforces to partial or complete work from home status, including finance, legal, marketing, revenue cycle, and other back-office functions. Shared space or “hotel” workspaces are popular.
– Reconfigure medical office or temporary care buildings: As these are often empty several days a week, they must be consolidated.
– Get out of expensive leases for care that can be given remotely or in lower-cost options or by strategic partners: Take full advantage of telehealth capabilities and eliminate offices that have become obsolete.
– Integrate telehealth into real estate only where it makes sense: Telehealth is more applicable to some services and care modalities than others. Offices should reconfigure to meet these novel needs where necessary, even if it means forgoing leases for the near term.
– Assess other expensive assets: Appraise assets like storage and diagnostic tools. Those not supportive of the new post-COVID-19 care model or prioritized service lines and are otherwise not producing revenues should be sold or outsourced to strategic partners.
– Diversify with off-campus offices: Provide convenient access to outpatient care and new outpatient procedures by investing in outpatient medical offices in high foot traffic locations.
– Create space for services in high demand: Services like preventive care and behavioral health should be given physical or virtual space in the system to cater to patient needs.
About Moha Desai
Moha Desai is a Principal of Healthcare Strategy and Transformation where she focuses on driving forward strategic, planning, financial, revenue cycle, operational improvement, and patient engagement healthcare projects for providers, federal government health agencies, and various firms requiring growth, business development, and project implementation and management. She has previously served in leadership roles at Partners HealthCare, Deloitte Consulting, Bearing Point, etc. Moha received her B.A. in Economics and her M.B.A. at Yale University.
Telehealth has quickly transformed the healthcare industry. Rather than scheduling an appointment, waiting up to a few weeks, and going to a doctor’s office or another healthcare facility, we can now access many types of care from the convenience of our smartphones.
However, telehealth has also brought in its own set of new challenges that must be overcome for it to be successful in the long term. Below, we explore five of the biggest issues telemedicine faces and offer insights on how they can be solved.
Clearing Legislative Hurdles
The Centers for Medicare and Medicaid Services greatly lowered the bar for provisioning telehealth in the wake of COVID-19. Since then, providers have been allowed to deliver care through a larger range of platforms as long as they are not public-facing.
However, this doesn’t address the widely varying state requirements for licensing and credentialing. In general, telehealth providers must be licensed in the state where patients receive care. Only nine states currently offer special telehealth licenses that allow providers to deliver telemedicine outside their state limiting their potential scope.
Although we can expect deregulation to occur over the next few years, the timeline and the path it will take is very much up in the air. This means providers must develop platforms that are flexible enough to adapt to changing legal environments.
Overcoming reimbursement issues
Prior to COVID-19, reimbursement had been a key barrier to the widespread implementation of telehealth. Even now, reimbursement for conditions not related to the coronavirus can still be difficult.
Each state has different regulations guiding the type of services and providers eligible for Medicaid reimbursement. For example, reimbursement policies often only applied to rural areas or those within certain geographic restrictions.
Once the public health crisis has ended, many of the current flexibilities will end, putting a particular strain on smaller facilities. Overall, there must be comprehensive and holistic reform that ensures all providers get reimbursed, whether providing care in person or via telehealth.
Addressing inequality in access to care
One of the greatest benefits of telehealth is that it can facilitate care well beyond the walls of physical healthcare facilities. No longer limited by geography, mobility, or other factors, patients can receive care as long as they have an internet connection.
However, many individuals around the country do not have access to high-speed internet and/or smartphones. For example, only 69.3% of rural areas and 64.6% of tribal areas have adequate access to high-speed broadband. This directly affects patients’ ability to participate in telehealth modalities, including consultation and remote monitoring.
Likewise, many telehealth services are based on smartphone apps. Rural populations are also less likely to own smartphones compared to urban and suburban residents—71% of rural residents compared to 83%.
While 71% may sound like a good number, we’re talking about tens of millions of people, and disproportionately elderly individuals with greater needs, who can’t use telehealth for these reasons.
Providers must develop platforms that can support audio-only, offline, and alternative channels to compensate for these connectivity and device-access obstacles.
Interoperability is fundamental for the long term success of telehealth services. While the large scale adoption of electronic health records (EHR) has been one of the greatest achievements of the past decade, even that has not been with its hurdles—particularly in rural settings.
Taking this electronic health data and ensuring interoperability among disparate apps will require secure data exchange without special user effort. Second, interoperability needs complete access, modification, and use of all patient electronic health information. Finally, it must restrict information blocking or any “knowingly and unreasonably” interfering with the exchange of EHR data.
To do all of this requires the development of core standards and practices, cross-training, and significant investment in data security for all telehealth platforms across the industry.
Since the foundation of medicine, healthcare has relied on in-person interactions. COVID-19 taught everyone just how important remote care is, especially during times of infectious disease transmission.
However, even with its clear advantages, some patients remain unconvinced. How do you still deliver effective and safe care to these individuals?
As telehealth continues to expand and patients grow more familiar with it, some of this will disappear on its own. But, telehealth providers must take steps to educate patients about the specific benefits of telemedicine, explain to them how to use platforms and services, and ensure their PHI is secure.
Of all the challenges to telehealth, this is both the most difficult, yet attainable. It’s entirely in the hands of telehealth providers how well and how quickly they’ll be able to overcome this barrier.
Telehealth: Driving the Future of Healthcare
Now is the watershed moment for telehealth. As the world slowly returns to normal and some of the regulatory and reimbursements policy restrictions come to an end, whether the healthcare industry can maintain the gains that have been made the last few months remains to be seen. There is no guarantee that healthcare won’t return the way it was before the pandemic.
Now’s the time for telehealth providers and those interested in joining the market to create solutions for the issues described above that will capitalize on all of telehealth’s benefits and ensure the long term viability of this effective and absolutely vital care modality.
You can dive further into the world of telehealth in our Shine podcast. In our latest episode, four industry experts discuss the world of telehealth, the tests it’s facing, and where it’s headed in the near future.
About Ed Adamson
Ed Adamson is a Director of Strategy & Insight at Star, a global consultancy that connects insights, strategy, design, engineering, and marketing services into a seamless workflow. Adamson has 19 years of experience of brand-led innovation for some of the world’s greatest CPG brands from companies including P&G, Kimberly-Clark, Coty, GSK, Bayer, Danone, Mondelez and McCormick Foods.