The Impact Advisor 1Q21
The Impact Advisor is a digital newsletter focused on healthcare IT news topics, trends, and disruptors. We hope you find this quarterly publication valuable to the work at your own organization. Please engage with us (by subscribing), so we may continue to share our industry insights and thought leadership with you.
Delay in Information Blocking Enforcement Does Not Mean Providers Should Delay Taking Action
On 10/29/20, ONC released an interim final rule that extends certain compliance deadlines relating to “information blocking” that were established in the May 2020 ONC Cures Act Final Rule. Most notably, under the 10/29/20 interim final rule, healthcare providers, health IT developers, health information exchanges, and health information networks will now be “subject to” information blocking starting 4/5/21 – a five-month delay from the original deadline of 11/2/20. The date for when the scope of information blocking will be expanded to include all “electronic health information” has also been delayed five months to 10/6/22. See this “bulletin” from Impact Advisors for more details.
Complying with Information Blocking Requirements is NOT about the EHR
Why It Matters:
The biggest near-term change for providers is obviously the extension of the information blocking “applicability date” to 4/5/21. However, a five-month delay in enforcement from the government should not translate into a five-month delay from providers in terms of taking action. Complying with information blocking is not about just flipping a switch in the EHR. In fact, the EHR configuration required pales in comparison to the critical organizational decisions that need to be made (per the graphic above). Additionally, while much of the attention has been focused on 4/5/21, the 10/6/22 date should be top of mind for health delivery organizations, as well. To reiterate: As of 10/6/22, the scope of the requirements will be expanded, and information blocking will be prohibited for all electronic protected health information (PHI) defined by HIPAA. That is a significant difference from what will be required by 4/5/21 – and the time, effort, and resources needed to ensure compliance prior to October 2022 should not be underestimated.
Providers Need to Get Innovation Right
The Center for Connected Medicine’s “Top of Mind 2021” survey looks at the impact of COVID-19 on health delivery organizations’ innovation priorities. Per the report, prior to the pandemic, the top innovation priorities among surveyed health system leaders were “revenue cycle management” and “telehealth/virtual care” (both cited by 26% of respondents), followed by “business plans to improve operations/efficiency” (21%). When asked about the effects of COVID-19 on innovation priorities though, the top response was “shift to telehealth/virtual care” (49%), followed by “slowdown of non-COVID-19 priorities” (40%). The survey also includes a number of additional questions on three specific topics: telehealth, artificial intelligence, and revenue cycle management. (See the second and third charts below for two notable telehealth-related responses.)
Why It Matters:
We recommend reading the full report for more about approaches and plans cited by respondents for telehealth, AI, and revenue cycle management. A few thoughts on the charts above:
- We think the innovation priorities cited before the onset of the pandemic are important to note, particularly because the underlying pressures driving those innovation priorities at the time (e.g., financial constraints, evolving patient expectations, need to realize value, etc.) haven’t suddenly disappeared. In fact, many have been exacerbated further by the pandemic. This means it is more important than ever for hospitals and health systems to get innovation right – i.e., ensuring shared accountability, putting structure behind innovation, inviting industry partnerships, and investing in the right talent.
- In terms of the second and third charts above, there obviously has not been any shortage of stats and studies about virtual care since the pandemic began. However, we wanted to specifically call attention to these two because they underscore a key – but often overlooked – component of a true telehealth program: the use of analytics and reporting tools. Tracking volume and utilization are good starting points, but it is just as important to understand patient satisfaction with telehealth services (and expectations moving forward) – and be able to quantify the impact of the virtual care program on organizational revenue, clinical outcomes, and clinician workflow. Virtual and remote care models are becoming more fully embedded into the fabric of “traditional” health delivery – and the same level of rigor should be applied when measuring telehealth as when measuring any other clinical service line.
Update on EHR ‘Interoperability’ and Approaches to APIs
A new report from KLAS looks at progress among EHR vendors towards “deep interoperability” since 2017. For context, KLAS measures “interoperability” in four progressive stages, with “deep interoperability” existing when providers: “1) Have consistent access to outside data; 2) Can easily locate patient records; 3) Can view outside data inside their EMR workflow;” and “4) Experience frequent, positive impacts on patient care.” According to KLAS, “while all vendors have room to improve, some have proven more willing to work with other EMR vendors, have been more successful in enabling record exchange that impacts patient care, and have done better at providing and supporting meaningful API connections.”
Why It Matters:
We think KLAS’ framework for interoperability (i.e., the four progressive stages) is fantastic, as it drives home the critical point that “interoperability” isn’t just about the “exchange of information” – it is about getting actual value from outside data. Although it is still early on the API front, we definitely think that is an area worth keeping a close eye on – in particular, the readiness and willingness among leading health delivery organizations to assume more control and responsibility over the APIs from their enterprise EHR vendor(s).
Transition from ‘Volume to Value’ (Still!) Stuck in Neutral
A survey of provider organizations published in the January 2021 issue of NEJM Catalyst Innovations in Care Delivery suggests that “COVID-19 hasn’t been a tipping point for value-based care.” Respondents estimated that 74% of their organization’s revenue in 2020 came from fee-for-service (FFS), compared to only 26% from “value-based reimbursement” – a virtually identical breakdown to two years earlier. When asked directly whether COVID-19 will “be the tipping point for adoption of value-based care,” three-quarters of respondents said “no.” In fact, a majority of respondents (55%) said that the pandemic will result in “no change” to the proportion of their organization’s revenue from value-based reimbursement.
Why It Matters:
The results are yet another reminder that the transition “from volume to value” continues to move far more slowly than anyone could have originally anticipated, with limited progress even in the last two years. Given the long uphill climb, it is hard to fault respondents for doubting that even the unprecedented COVID-19 crisis could be the catalyst for change. Of course, that doesn’t mean this pandemic won’t be one of the key factors that soon sparks a genuine shift away from FFS; in our opinion, the survey responses merely highlight the level of skepticism among providers about “value-based reimbursement” after so many years of hype. While that skepticism is certainly justified, it doesn’t mean that health delivery organizations can afford to be idle. There obviously won’t be a sudden shift to a fully value-based reimbursement model overnight, but the reality remains that at some point in the near future providers will need to take on significantly more financial risk for the cost and quality of care. For many hospitals and health systems, that means developing (and optimizing) new processes and workflows, as well as investing in more robust analytics tools and risk management capabilities than what is in use today. There is no substitute for “real world” experience, and we continue to believe that the organizations who embrace payment models that involve taking on tangible financial risk (whether through voluntary federal programs or partnerships with commercial payers) will be far better positioned than those who do not.
Challenges with the Patient Financial Experience Compared to Other Industries
According to CHIME’s annual “Most Wired” report, although 87% of health delivery organizations offer patients a “list of procedures with associated prices” (either via the patient portal, app, provider’s website, etc.), patient-specific price comparisons are far less common. Additionally, when it comes to price transparency, almost two-thirds of respondents still do not provide patients with a “definition of key terms” while close to another two-thirds do not offer “education regarding capabilities.” (See first chart below.) Another notable – but unrelated – finding from the report pertains to information from patient monitoring equipment that is sent to the EHR. Per CHIME: “41% of both acute and ambulatory care organizations have integrated data – either fully or partially – from 10 or more of the equipment types [listed in the second chart below].” Overall, the full report includes trends on a number of different topics, such as value-based payment, population health, patient engagement, and information security.
Why It Matters:
The survey covers many different topics, so we definitely recommend taking a look at the full report. A few thoughts on the results above:
- We think the first chart speaks volumes about the patient financial experience right now compared to other industries. Granted, health delivery is inherently different (and more complicated) in many ways than other consumer-facing service industries when it comes to pricing – and some of the factors involved in providing accurate, patient-specific price comparisons in advance are not always fully under the control of the hospital or health system. Two things that are largely under the control of most health delivery organizations though are providing patients with “definitions of key terms” and “education regarding capabilities.” The fact that neither functionality is offered on a widespread basis underscores the opportunity in the market that still exists for hospitals and health systems to differentiate themselves by providing patients with more context to accompany any pricing information.
- The second chart serves as a good reminder that while there is a lot of (justified) attention about the flood of information from patient-owned devices and wearables, there also is an increasing amount of data that needs to be integrated into the EHR from monitoring equipment and other medical devices in the hospital and/or physician practice.
Q: I’ve heard a lot about ADT Event Notification – what is it, what are the deadlines, and what do I need to do right now to comply?
A: ADT Event Notification stems from the CMS Interoperability and Patient Access Final Rule and now requires hospitals to make a “reasonable effort” to provide ADT (Admission, Discharge and Transfer) notifications as a requirement to maintain their “Conditions of Participation” (CoP).
In order to comply, qualifying hospitals, Critical Access Hospitals (CAHs) and Psychiatric Hospitals must send a minimum of:
- Patient Name
- Treating Practitioner Name
- Sending Institution Name
- Patient Diagnosis (if not prohibited by other applicable law) – optional but strongly encouraged
The ADT notification requirement would “trigger” upon the following events:
- Admission to Inpatient services (including Observation admissions) or Emergency Room registration (ED Arrival/ED Roomed)
- Transfer from Inpatient Services or Emergency Room
- Discharge from Inpatient Services or the Emergency Room
Recipients of the ADT Event Notification include:
- All applicable post‐acute care services providers and suppliers
- Primary care practitioners and groups
- Other practitioners and groups identified by the patient as primarily responsible for his or her care
- Practitioners and groups which need to receive notification of the patient’s status for treatment, care coordination, or quality improvement purposes
Notifications can be sent directly from an EHR or through an intermediary that facilitates exchange of health information (such as an HIE or third-party notification service).
In addition to completing any technical requirements needed to send the ADT message, success will also be dependent upon robust workflows that support having accurate Care Team members identified for each patient, along with up-to-date Provider Directories, Direct Address and Digital Contact information for all recipient types listed above.
The current deadline for compliance is May 1, 2021.
Response provided by Dan Golder, Principal at Impact Advisors