Impact Insights

Week in Review 11/14/14

The FY 2015 Work Plan from HHS’ Office of Inspector General (OIG) suggests even more oversight around HIPAA compliance and EHR incentive payments is coming:

  • For the first time, OIG will “determine the extent to which hospitals comply” with HIPAA’s EHR contingency planning requirement. (For context, HIPAA requires covered entities to have a contingency plan that, “establishes policies and procedures for responding to an emergency or other occurrence that damages systems that contain protected health information.”)
  • OIG will also “review” Meaningful Use payments to identify incentives that erroneously went to providers who did not meet MU requirements. Additionally, to determine if certified EHRs are adequately protecting patient information, OIG will perform security audits of covered entities participating in MU and their business associates (such as cloud services providers). Note that the OIG “review” of incentive payments and the planned security audits are separate from the well-publicized MU audits currently being conducted by CMS.

Impact Advisors’ Thoughts are two:

1)      The first bullet is yet another good reminder of the need to fully understand – and be compliant with – all requirements under HIPAA.

2)      The second bullet underscores the fact that with more than $25 Billion (!) in MU incentives now paid to providers, federal oversight and review of those payments isn’t going away anytime soon. We cannot stress enough the importance of maintaining thorough and accurate documentation when attesting.


KLAS has published a summary graphic from their recent report on EHR interoperability. The chart rates EHR vendors on “overall interoperability success” (i.e. percentage of customers who reported feeling “very” or “moderately” successful with interoperability) vs. “depth of interoperability” (i.e. percentage of customers who mentioned “advanced” interoperability options or “complex connections”). KLAS said it was releasing the chart publicly “to provide clarity into a market that is cluttered with competing claims.” 

 KLAS Chart_111414


Impact Advisors’ Thoughts: The graphic is certainly interesting and has been getting a fair amount of news coverage, but we cautions not to read too much into it. KLAS studies, while excellent, are almost always based purely on customer feedback. In this case, given the vast differences in interoperability needs among providers today, opinions of what constitutes interoperability “success” (or “advanced” vendor options) will likely be largely a product of each organization’s unique goals and approach to exchanging data.


Becker’s Hospital Review publishes a great list of “100 Healthcare Statistics to Know.” Many of the studies about IT have been covered previously in the Week in Review blog, but here are some of the non IT-related ones we thought were interesting (largely because they highlight a problem that IT could help solve):

Impact Advisors’ Thoughts: We admittedly have a special place in our heart when it comes to studies and data points, but it is hard to find a good compilation all in one place. Highly recommended for the bookmarks folder or for anyone looking to impress their co-workers at a holiday party.