Archive for the ‘Meaningful Use’ Category

Guest Post: Are You Preparing to Fail Healthcare Compliance in 2018?

December 19th, 2017 by Tim Feldman and Darci L. Friedman

A 2018 roadmap to healthcare compliance should focus on cybersecurity, vendor management and telehealth.

As the year winds down, we see numerous lists of priorities healthcare organizations should focus on in the coming year. However, if you are looking to those end-of-year lists for guidance on what your organization should pay attention to in 2018, you are already behind. If you do find yourself playing catch-up, drafting your 2018 compliance work plan is the best place to start.

As the roadmap for your compliance efforts throughout the year, your annual work plan should indicate key high-risk areas. The Office of Inspector General (OIG) of the Department of Health & Human Services (HHS) has indicated that developing an annual compliance work plan is integral to the administration of an effective compliance program (Measuring Compliance Program Effectiveness – A Resource Guide).

The annual work plan and compliance program administration are but one portion of what is required for an organization to have a robust and effective compliance program. The required elements of a compliance program are the following:

  • Standards, Policies and Procedures;
  • Compliance Program Administration;
  • Screening and Evaluation of Employees, Physicians, Vendors and Other Agents;
  • Communication, Education and Training;
  • Monitoring, Auditing and Internal Reporting Systems;
  • Discipline for Non-Compliance; and
  • Investigations and Remedial Measures.

These elements provide a broad framework for your organization to identify risk, proactively remediate and provide a response mechanism to mitigate when there is an exposure. Working the plan and program throughout the year helps your organization achieve a state of ongoing readiness.

Cybersecurity

Cybersecurity is one item that will likely factor more heavily in your work plan, and appropriately so. Last June, the HHS Health Care Industry Cybersecurity Task Force released a report on improving cybersecurity in the industry. The Task Force concluded that cybersecurity, at its core, is a patient safety issue and a “public health concern that needs immediate and aggressive attention.”

Some of the areas to address in the broader realm of cybersecurity include:

  • Ransomware;
  • Email security, including phishing;
  • Internet of Things (IoT) and devices;
  • Bring your own device (BYOD); and
  • Medical identity theft.

As the Task Force report notes, cybersecurity must be thought about across the continuum of care in your organization. Work to shift the culture and thinking that cybersecurity is simply a technology issue, of concern only to the IT department.

Do this by implementing policies and procedures for key cybersecurity issues and then communicating them across the organization. Follow that with training, including everyone in your organization, from staff to board members. The training should: define cybersecurity; explain how it may manifest in the organization, and address your policies and procedures, making it evident to all what they can and cannot do and how to respond.

Third-Party Vendor Management

The outsourcing of services to third-party vendors is increasingly common and for good reason. Such relationships offer great benefits, but at the same time, these relationships also carry legal, financial, reputational and compliance-related risks. Here are seven questions to evaluate your third-party vendor relationships:

  • Does your organization, as a covered entity (CE) under HIPAA, have a vendor compliance program to help you identify, manage and report on these risks?
  • Do you review and assess your vendors’ risk profile?
  • Are you familiar with each vendor’s hiring practices?
  • Do you know which vendors’ products connect to other IT systems that contain critical data, including protected health information (PHI)?
  • Do you have insight into each vendor’s information security and data privacy capabilities?
  • Do you know with which vendors you have a business associate agreement (BAA)?

For many healthcare organizations, the answer to several of these questions is likely “no,” which creates risk for those organizations. The OIG’s position is clear: healthcare entities have a responsibility to proactively identify, assess and manage the risks associated with their vendor relationships.

All vendors are NOT created equal. A good starting point in managing an effective and efficient third-party compliance program is to perform a risk-ranking of vendors based on their access to critical assets or information. By segmenting your vendor population into “risk tiers” you can focus limited resources on the most serious exposures.

Components of third-party compliance assessment should include, among other things:

  • Due diligence (background, reputation, strategy);
  • Knowledge of, and compliance with, security and privacy requirements;
  • Operations and internal controls (policies and procedures);
  • Workforce controls, background and exclusion checks; and
  • Training and education.

And, of course, with every vendor that meets the criteria of a Business Associate, ensure that a written BAA is in place. BAAs can be complex and are often daunting, but they must be carefully negotiated and acknowledged by both parties.

By ensuring your vendors have strong compliance programs in place and that they are following through on the BAA requirements, your organization is meeting its compliance obligations and doing its best to minimize its risks.

Telehealth

The compliance concerns related to the delivery of care via telehealth are numerous and include the following:

  • Licensing;
  • Credentialing;
  • Security;
  • Regulatory requirements for billing; and
  • Fraud and abuse.

An area to focus some attention on is payment under federal healthcare programs. The OIG currently has two active work items on telehealth, one for Medicaid and one for Medicare. Both of the items relate to the propriety of payment for telehealth services.

If your organization provides telehealth services, consider conducting a risk assessment to determine if you have any exposure in the area. Risk assessments are not strictly one of the 7 required elements of a compliance program, but they are often referred to as the “8th Element” given the focus on them in the Federal Sentencing Guidelines and OIG documents.
Risk assessments, along with the other elements of a compliance program, provide your organization the means to identify, prioritize, remediate and/or mitigate the myriad on-going risks it will encounter. If you are not working your compliance program and specific risk areas throughout the year, you are failing to adequately prepare for an event. By failing to prepare, as one wise man said, you are preparing to fail.

About the Authors: Tim Feldman is Vice President and General Manager of Healthcare Compliance & Reimbursement at Wolters Kluwer Legal & Regulatory U.S. He oversees product development across a vast suite of practice tools and workflow solutions to help professionals stay ahead of regulatory developments and effectively manage compliance activities. Darci L. Friedman, JD, CHPC, CSPO, PMC-III, is the Director of Content Strategy & Author Acquisitions for Healthcare Compliance, Coding & Reimbursement at Wolters Kluwer Legal & Regulatory U.S. She is responsible for supporting the overall strategy for developing new content and features, innovating new product models, and recruiting top content contributors.

HIN Disclaimer: The opinions, representations and statements made within this guest article are those of the author and not of the Healthcare Intelligence Network as a whole. Any copyright remains with the author and any liability with regard to infringement of intellectual property rights remain with them. The company accepts no liability for any errors, omissions or representations.

Infographic: ROI from Data-Driven Clinical Optimization

August 18th, 2017 by Melanie Matthews

Although the 2009 American Recovery and Reinvestment Act gave health systems a financial incentive to achieve Meaningful Use of EMRs, many healthcare organizations have struggled to capture value. As the capabilities and sophistication of EMRs continue to grow, there is a widening divide between healthcare organizations that harness the capabilities for a competitive advantage and those that are crippled by poor usability, workflows and adoption, according to a new infographic by Galen Healthcare Solutions.

The infographic looks at the impact of clinical EMR optimization on quality improvement and return on investment.

Health Analytics in Accountable Care: Leveraging Data to Transform ACO Performance and Results Between Medicare’s aggressive migration to value-based payment models and MACRA’s 2017 Quality Payment Program rollout, healthcare providers must accept the inevitability of participation in fee-for-quality reimbursement design—as well as cultivating a grounding in health data analytics to enhance success.

As an early adopter of the Medicare Shared Savings Program (MSSP) and the largest sponsor of MSSP accountable care organizations (ACOs), Collaborative Health Systems (CHS) is uniquely positioned to advise providers on the benefits of data analytics and technology, which CHS views as a major driver in its achievements in the MSSP arena. In performance year 2014, nine of CHS’s 24 MSSP ACOs generated savings and received payments of almost $27 million.

Health Analytics in Accountable Care: Leveraging Data to Transform ACO Performance and Results examines program goals, platforms, components, development strategies, target populations and health conditions, patient engagement metrics, results and challenges reported by more than 100 healthcare organizations responding to the February 2016 Digital Health survey by the Healthcare Intelligence Network.

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Infographic: Technology and the 21st-Century Medicine Bag

March 6th, 2017 by Melanie Matthews

The traditional clinician’s medicine bag is now a thing of the past, but its replacement promises to be even more useful as a means of facilitating better patient care, according to a new infographic by Transcend Insight. Now, a doctor’s visit is facilitated via laptop or with a smartphone — technologies and products of healthcare innovation.

Healthcare innovation, in fact, is transforming everything from how physicians diagnose and treat their patients to how healthcare systems are reimbursed for their services. Here’s a quick look at how that transformation is unfolding, and how four key technologies in particular have become critical components of modern-day medicine.

Technology and the 21st-Century Medicine Bag

Remote Patient Monitoring for Chronic Condition Management: Leveraging Technology in a Value-Based System Encouraged by early success in coaching 23 patients to wellness at home via remote monitoring, CHRISTUS Health expanded its remote patient monitoring (RPM) enrollment to 170 high-risk, high-cost patients. At that scaling-up juncture, the challenge for CHRISTUS shifted to balancing its mission of keeping patients healthy and in their homes with maintaining revenue streams sufficient to keep its doors open in a largely fee-for-service environment.

Remote Patient Monitoring for Chronic Condition Management: Leveraging Technology in a Value-Based System chronicles the evolution of the CHRISTUS RPM pilot, which is framed around a Bluetooth®-enabled monitoring kit sent home with patients at hospital discharge.

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Infographic: Countdown to the Merit-Based Incentive Payment System

April 18th, 2016 by Melanie Matthews

The Merit-Based Incentive Payment System (MIPS) was created by the Medicare Access and CHIP Reauthorization Act of 2015 to streamline several of CMS’s value-based programs including Meaningful Use, Physician Quality Reporting and Value-Based Modifier.

An infographic by SA Ignite highlights the basics on MIPS including eligibility, scoring, financial impact, qualifications, and exemptions.

One year after the Centers for Medicare and Medicaid Services began reimbursing physician practices for chronic care management services, Bon Secours Medical Group is now comfortable with the CCM reimbursement requirements and is reporting that it’s unique approach to this revenue opportunity is ramping up nicely. And, the organization’s approach to chronic care management reimbursement is helping to position itself for advance care planning as a new billable CMS event in the upcoming year.

During Physician Reimbursement in 2016: Workflow Optimization for Chronic Care Management and Advance Care Planning, a January 26th webinar, now available for replay, Robert Fortini, PNP, chief clinical officer for Bon Secours Medical Group, will provide an inside look at his organization’s experience with CMS’ chronic care management reimbursement this year and how they are leveraging this experience for CMS’ newest billable event in 2016—advance care planning.

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Infographic: 7 Steps To Boost Patient Engagement

September 9th, 2015 by Melanie Matthews

Patient engagement is more than just a requirement under Meaningful Use – it’s a long-term strategy for improving healthcare, according to a new infographic by eVisits.

The infographic lists seven key steps to boosting patient engagement.

How To Boost Patient Engagement

2015 Healthcare Benchmarks: Patient EngagementTransformational patient-centered models emerging post-ACA are designed to succeed with a core of engaged, activated patients, yet enlistment of individuals in chronic care management, telehealth and other health enhancement interventions continues to challenge the healthcare industry.

2015 Healthcare Benchmarks: Patient Engagement documents strategies, program components, successes and challenges of engaging patients and health plan members in self-care from more than 125 organizations responding to the 2015 Patient Engagement survey by the Healthcare Intelligence Network.

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Infographic: Patient Engagement Through Online Portals

August 7th, 2015 by Melanie Matthews

As physician practices gear up for Meaningful Use Stage 2, which requires physicians to promote and measure patient engagement, the role of the patient portal will become more important.

A new infographic by Nextech examines how practices can ensure their patient portal is set up for successful patient engagement.

Population Health Framework: 27 Strategies to Drive Engagement, Access & Risk StratificationFaith-based integrated delivery system Adventist Health is on a mission to improve population health status with a wellness-based approach it estimates will eventually net $49 million in savings.

Population Health Framework: 27 Strategies to Drive Engagement, Access & Risk Stratification walks through the elements of Adventist’s population health management program that engages individuals to modify behaviors and prevent illness in the future.

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Infographic: HIEs Supporting Meaningful Use Stage 2

February 16th, 2015 by Melanie Matthews

An increasing number of HIEs are supporting meaningful use stage 2 requirements, according to a new infographic by HIMSS.

The infographic looks at the percentage of HIEs able to support CPOE, patient reminders, secure messaging and data protection.

Health Care System Transformation for Nursing and Health Care Leaders: Implementing a Culture of CaringHealth Care System Transformation for Nursing and Health Care Leaders: Implementing a Culture of Caring features successful examples of how various units of the healthcare system can apply specific strategies to their inter- and intra-professional work, and how to engage and sustain authentic dialogue among and between stakeholders.

Health Care System Transformation for Nursing and Health Care Leaders: Implementing a Culture of Caring reflects the interests of such major stakeholders as patients and families, nurses, physicians and other primary and adjunctive care providers, ancillary service providers, administrators and managers, and all other individuals involved in the many aspects of organizational models and delivery of healthcare and human resource functions and outcomes.

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Infographic: CMS’ Quality Improvement Programs

December 31st, 2014 by Melanie Matthews

Ninety-two percent of eligible hospitals and 75 percent of eligible healthcare professionals have received an incentive payment for meaningful use, according to an infographic by CMS.

The infographic also examines the progress on other CMS’ quality improvement programs, including: ACOs; physician quality reporting system; ICD-10; and electronic funds transfer.

Physician Quality Rewards for Population Health ManagementHumana recently distributed $76.8 million in quality awards to approximately 4,700 physician practices through Humana’s Provider Quality Reward programs. The program is designed to support providers where they are in their practices as they move through the continuum of care programs focused on the Triple Aim.

Physician Quality Rewards for Population Health Management a 45-minute webinar on December 16th, now available for replay, Chip Howard, Humana’s vice president of payment innovation in the provider development center of excellence, shares how Humana’s program supports physicians’ transition from volume to value and helps them become successful population health managers.

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Infographic: Meaningful Use Audits

December 5th, 2014 by Melanie Matthews

Meaningful use audits could recover $33M in EHR incentives, according to data from the HHS published in a recent Health Security Solutions infographic. Although the precise reason for failure is not included in the dataset, there is reason to believe from strong anecdotal evidence that failure to conduct an adequate risk analysis is the most common reason entities fail their MU audits.

The infographic looks at both pre- and post-payment audits and which states have the highest audit failure rates.

Keys to EMR/EHR Success, Second EditionIn this revised second edition, nationally recognized expert Ron Sterling, president, Sterling Solutions, Ltd., has included up-to-date information on this daily-changing topic of Health IT. A new chapter on EHR and malpractice risk has been added, as well as detailed coverage of conversion issues for practices that have an old EMR. Also, new additions on ARRA and meaningful use will help many medical practices evaluate whether an EHR investment makes sense.

Keys to EMR / EHR Success, Second Edition starts with an overview of preparing the practice for technology. From there, Sterling helps the reader define requirements, choose the right system, get physician and staff buy-in, and take the system “live” as smoothly as possible. Sterling translates his experience into a step-by-step process any medical practice can follow with ease, from first considering an EHR, all the way through post-implementation training and updates.

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Infographic: Physician Adoption of Health IT

September 29th, 2014 by Melanie Matthews

Physician interest in mhealth is strong, according to Deloitte’s 2014 Survey of U.S. Physicians. Access to clinical information is the most cited benefit of health IT by physicians, the survey also found.

A new Deloitte infographic looks at the difference between physician users and non-users of health IT, patient support of health IT and analysis of meaningful use.

Physician Adoption of Health IT

Transforming Health Care: The Financial Impact of Technology, Electronic Tools and Data Mining The healthcare technology revolution is just around the corner. And when it arrives, it will change and enrich our lives in ways we can only begin to imagine. Doctors will perform blood pressure readings via video chat and nutritionists will analyze diet based on photos taken with cell phone cameras.

Transforming Health Care: The Financial Impact of Technology, Electronic Tools and Data Mining combines healthcare, technology, and finance in an innovative new way that explains the future of healthcare and its effects on patient care, exploring the emergence of electronic tools that will transform the medical industry.

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