I recently received a question via a referral from a friend and want to share it with my readers.
The scenario and question are:
My husband is an ER doc, board certified in Family Practice. Under the ACA primary care physicians are eligible to receive the increased Medicaid reimbursement once they fill out the attestation indicating they meet the eligibility requirements. However, in reading the CMS final rule, it seems to indicate that Emergency Room services (as well as OB) are not considered primary care.
He works for two ER contacting groups who are all over him to log on and do the attestation so they can receive the increased reimbursement. A couple of things:
1. We are both positive that even though he meets the criteria (primary care certified & 60% of designated codes outlined by CMS) having him complete the attestation is really skirting the intent. He has never practiced outside of the ER and does not have a practice. CMS is not increasing the reimbursement for ACEP certified ER docs so this is really a technicality that the regulators didn't anticipate.
2. CMS indicates that a mechanism must be in place by the MCO to distribute the increased compensation back to the physician. An ER group isn't really an MCO. My husband gets paid an hourly wage and they have no intent of increasing his pay based on the attestation.
Basically the push back is sign it or else. We were thinking perhaps he would sign it if the group agreed in writing to release him of all liability and indemnify him, and reimburse CMS if they decide to do a claw back down the road. My fear is this all gets muddy and I can see CMS doing something crappy that nobody has thought of yet because nobody foresaw this little nuance.
I referred this individual to their local Regional Extension Center and encouraged her husband to obtain something in writing on whether he qualifies for attestitation. If you have any other suggestions, please include them here as a comment.
identifying partners who are efficient, but effective, and utilize resources wisely.
We have seen an increase in transparancy of outcomes as it relates to hospitals and SNFs and believe we will soon see efforts to also publish physician specific outcome metrics. Ultimately, outcomes will also be available on other long-term care facilities, home health, hospice and other providers.
Use of technology (EHRs, HIE, Telemedicine, Remote Monitoring, Social Media, Mobile, etc) will also play an important role in the efficieny and effectiveness of partners.
Let me know if you think there is something else that should rise to the top of an ACO-minded leaders list.
A recent interview appearing on SmartBlog on Social Media is drawing a great deal of traffic to my blog, so I'd like to first thank those visiting for the first time.
This is an excellent example of how social media can expand your reach and audience and a search engine optimization technique. First, there are the obvious new visitors who are following the link from SmartBlog and being introduced to my blog. There are also readers who liked the post and tweeted it to their followers; some of whom are also following the link to my blog. Lesson: Engage with other bloggers and social networking sites to reach new audiences.
Second, the search engines are picking up on all of this traffic and the site rankings for both SmartBlog on Social Media and Christina's Considerations (my blog) are going up. It's not enough to just have an online presence, you also need to be visible to the search engines. Lesson: Engage with other bloggers and social networking sites to increase your site's online visibility.
In this case, social media is good medicine for health care because it helps get your messages out to, and engage with, new and wider audiences.
There is a need to look at the impact of meaningful use on Critical Access Hospitals. Modern Healthcare has weighed in on a lack of clarity. Perhaps this is an indication that we need to explore the impact a little further.
Last week I was asked about the impact of meaningful use on CAHs and the answer I gave my friend was:
The impact will be the same as on any other provider. However, CAHs and rural providers may have more difficulty reaching meaningful use because of the challenges that we already know about. For example, if you don't have broadband in your area, it will be really hard to meaningfully use an EHR. There is a lot of work to do in this area and associated costs.
The doctors were truly the stars of the evening and their comments so important to this debate. I urge you to listen and consider their perspectives as you form your own opinion on the subject. I also invite you to leave your thoughts on this post, especially those of you with an interest in the role of health information technology and exchange.
"The analog in baseball would be for Major League Baseball -- the corporate entity that oversees the game -- to field a team that competed with other MLB teams. And that this MLB-owned team could play by a different set of rules (didn't need to support its expenses, could have losses subsidized by taxpayers, etc).
One can imagine that such a team could hire the best players, charge less for tickets and potentially win the most games while running huge deficits. Even if the MLB-owned team was forced to play by the same financial rules, it would nevertheless send a strong message to others that it doesn't believe that the other MLB teams were playing to their potential, and that it could do better."
To better understand the real risk and the slippery slope that we could be taken down, please read the entire article. Decide for yourself and critically analyze anyone's talking points!
"A group of community stakeholders in a suburban region will begin the conversation of establishing a RHIO for our region. The conversation had been dormant until the Healthcare Executive article appeared. Would you have any critical advice to provide the group in it's very beginning stages? Any advise as to areas to address in the early stages (monetary gains, politics, vendors)?"
The first thing I would suggest is for each of the stakeholder representatives read the HIMSS Guide for Establishing a RHIO because it is comprehensive and helps readers explore the considerations from the ground up. You may also be interested in a new Practice Brief on HIE from AHIMA.
The second thing I would do is communicate and ensure that all have a common vision of your HIE. Then communicate some more and ensure that there are shared goals and a commitment on the part of all involved to true collaboration.
Lastly, look at leadership. Who will be leading this effort? Is it an individual(s) that can truly put aside their own individual interests to focus on the HIE's needs. Is it an individual(s) who has passion for this community collaborative to improve the electronic exchange of health information? If either of these answers are "no", I suggest regrouping until you can say "yes".
From here, your HIE will be in the best position to address the multitude of other issues and questions that arise. Best wishes and give me an update on your progress from time-to-time!
In April, HIMSS released the results of their 18th Annual Leadership Survey and one of my RHIO friends (who doesn't work in healthcare) wrote to ask me what I thought about the results on page 22. He was surprised to ready that 53% have no plans to participate and 77% don't know, don't participate or have no plans to particiapte in a RHIO.
I told him not to worry, because overall the trend it headed in the right direction and that administrators are still learning about RHIOs. I know this because people find my weblog daily by typing in "What is a RHIO?" and other ask me "What is a RHIO?" when it comes up in conversation.
So, I'd like to know what you think about these statistics. Please leave your thoughts especially if you are one of those administrators finding my weblog because you are looking for the definition of a RHIO.
The September 2006 issue of Health Management Technology has a nice article titled Preparing for Interoperability: EHRs and the Law, which explans the changes to Stark and Anti-kickback laws. I believe it will all come down to how well the donating organization can document that the free or below market rate of the hardware or software will increase patient safety and quality by promoting the electronic exchange of health information in the community -- interoperability!
Do you know of any of the 600+ RHIOS now under development or even the few already operational that have standardized and clinically integrated the format (at the user interface) in order to efficiently display cumulative diagnostic test results for viewing and sharing?
Bob Coli, MD, Rhode Island
It sounds like you are interested in a physician portal! The SBCCDE (powered by Quovadx/Care Science) does have a portal for physicians, and a patient portal ready to bring on-line at the appropriate time. I am sure other operating RHIOs have some sort of portal, but I'd like to invite them to share a description of their own by responding (commenting) to your question directly.
MedSeek, a leader in portal development for hospitals, recently merged with AccessPt and now offer an enterprise wide portal strategy. I'd suggest exploring their offerings!
Background:Illumysis is the health information technology division of Lumetra and an independent healthcare consulting organization. Lumetra staff, who now form Illumysis, developed and implemented CMS' DOQ-IT program. In March I wrote an article on Illumysis for Health IT World and included aposton this weblog. The article resulted in a question that I would like to address here.
Question:The question is does Illumysis compete with the CMS DOQ-IT Program?
Answer:No. Illumysis provides consulting services to physician practices that do not meet the criteria for participation in the DOQ-IT program.
Those of you who follow my blog know that I presented on establishing a RHIO in Chicago last week at the American College of Healthcare Executives Annual Congress on Leadership. I've been a member of this organization for over 20 years and am board certified by them in healthcare management.
So, I already knew going in that many many of my peers would ask me "What is a RHIO?" and I was not let down! Since these are the people who ultimately "sign the check" I figured it was important to increase their knowledge on the topic.
Now, lets answer the question. My friendHolt Anderson doesn't fully agree with my definition, but he respects my perspective and perhaps one day he will come around to my point of view! :)
The term "RHIO" is only a descriptive of the "vehicle" being used to get us to the final destination -- a Nationwide Health Information Infrastructure. I take the more formal view of a regional health information organization to mean
a connected community with a formal independent organizational and governance structure with systems to ensure accountability and sustainability to support community-wide exchange of health information for the benefit of all stakeholders.
One of the newer terms to emerge is RHIN or regional health information network. I think this term might be a more appropriate description of newer organizations that don't yet have a formal organizational structure. However, you can call your RHIO or RHIN what every you want. In Santa Barbara we have a "Care Data Exchange", in California we have a CalRHIO, and if I search through my lists long enough I'm sure I can find a "network" in the list of RHIO names.
I received a question about why I did not include a sample set of bylaws in my recently released step-by-step guide for forming a RHIO. Instead of a sample set I have included an outline of typical sections.
I thought about this very issue when putting the guide together but decided against including a set of bylaws because of the fact that there are 50 states with different laws, regulations and policies. Instead I suggest that each incorporating organization obtain a sample set (boiler plate) in their state to use as their template. If you have access to a set from a recently incorporated nonprofit organization or an attorney who can provide a set, start there. Otherwise, you can check the appropriate office in your state (Secretary of State) or with organizations supporting small businesses.
My greatest fear was that all of the RHIOs would adopt a sample from, lets say California, and include a bunch of stuff that isn't applicable in your state and could potentially lead to unnecessary risk. If you still can't find anything leave a comment and either I or someone in my growing readership will help!
If you still want to see a sample (from California) try CalRHIO.
I keep getting people visiting my weblog because they are performing a search for a list of RHIOs. So, I thought I would try to at least point them in the right direction. First, the HIT Dashboard recently released by the HIMSS RHIO Federation seems to have the most comprehensive list of regional health information networks and other RHIO-like efforts. Second, the eHealth Initiative Connecting Communities website also has a list with a description of the project, but there isn't always much contact information.
Now, I've been at this long enough that I too have a couple of lists. The first is of all the California regional health information network projects or organizations. This list includes a description of the project and contact information, but I'll only release it if those on the list give me their permission.
I've also amassed quite a significant list of RHIO emails, but I don't have any plans at the moment to release this list unless it is for a really good reason. Again, I would try to have those on the list participate in the decision to release the list, or not.
My advice is to try the two links above and contact me about my lists only if you think you have a mighty fine argument! (We'll talk!)
I've been asked by Dr. Gary Levin, Inland Empire RHIO what I think about the January 8 article in Health Data Management and Dr. Brailer's comments. (He will post his comments later this week.)
I don't think the "mission" of RHIOs will change dramatically over the next few years, however, their role will likely change as the realities of the future come into focus. I agree with Dr. Brailer that a RHIO is a journey, especially if you are like me and see it as a community wide quality improvement effort.
At this point, we don't know how, or if, the DHHS contracts for prototype NHINs will change the role of RHIOs. Perhaps it will be hard for some to justify their IT plans, however, others may have the resources to proceed with their implementation plans. I believe it will all come down to the strength of the community collaboration and the resources they can commit to move their plans forward.
I agree with Dr. Brailer that the most important role for RHIOs is their ability to organize the governance and collaboration aspects. I think there will come a time when the technology is "plug and play" and RHIOs will no longer be expected to "innovate and develop technology". Instead, they will be responsible to the community for ensuring that the technology is implemented in a manner consistent with stakeholder needs. These RHIOs will also provide the ongoing oversight and authority structure which will be vital to the success of a national health information infrastructure.
As I mentioned in my post on the Forecast for 2006 I think that size does matter and at some point, RHIOs will begin to find shared visions and realize the benefits of combining their resources with other communities. For example, Santa Barbara County "collaborates" with Ventura and San Luis Obispo Counties in many different ways and forms a "natural" region. At some point it may make sense for these three "communities" to combine their resources and form one RHIO to represent the interests of their combined stakeholders.
In summary, if you are a RHIO leader, this article only means that you need to keep an eye on the horizon and be ready for change!
A question referenced the recent Robert Wood Johnson Foundation Information Links Grants and inquired about future opportunities for public health funding. I asked Tim Crowley at RWJF whether there were plans for another round next year and this is his response:
At this time, there are no plans to issue a second round of grants but RWJF does plan to continue to invest in the area of information exchange between public health agencies and health care providers. We welcome you to visit the Foundation Web site at www.rwjf.org to sign-up for email alerts by interest area.
While I'm not aware of any specific opportunities at the moment, my recommendation is that the organization review Monday's post and be prepared to apply for any grants as they arise. I anticipate more opportunities going forward, especially for rural areas and to bring behavioral health to the table.
More and more I'm meeting people forming RHIOs and they have a multitude of questions. As I have answered the questions posed to me, I have felt that others in similiar positions might also benefit from the answers. So, I've written the guide (to be released in January 2006) and today start a new category on this blog -- Ask Christina...
My readers can pose a question via email firstname.lastname@example.org and I will provide the answer on this weblog. Readers can click on the Ask Christina... link on the bottom right hand side to see all of the questions and answers(Q&A), as well as, comments posted by other readers. The most exciting benefit of our efforts over time will be a rich resource for those just starting to build a regional health information network.
I'd like to focus on questions related to moving RHIO projects forward. I also want to extend a special invitation to consumers of healthcare to ask questions for the purpose of increasing their knowledge and understanding of health information technology and regional health information networks.
What question would you like to Ask Christina today?