Meaningful Use Requires
Meaningful Use Requires
Meaningful Laboratory Results
Meaningful Laboratory Results
™™ARRA and Stark Safe Harbor: Opportunities and challenges for you and your outreach business Kelly.Feist@sunquestinfo.com
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Laboratory Tests: The Best Bargain in Healthcare!
Laboratory Tests: The Best Bargain in Healthcare!
• All of this value only costs pennies
• Laboratory testing/pathology services typically cost only 3¢ to 4¢ of every healthcare dollar! • Significantly, sophisticated use of
information technology enhances the value of lab test data
Important Facts
Important Facts
• Laboratory test data—to some degree—plays a role in 60% to 70% of decisions to admit or discharge a hospital inpatient (Study by Michael Becich, M.D., UPMC)
• Laboratory test data consistently makes up 70%+ of the patient’s permanent health record
(Per Jay Schamburg, M.D., lab test data represents 82% of the data storage bytes in electronic patient health records at Aurora Health)
But wait…
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HITECH ACT
HITECH ACT
Health Information Technology for Economic and Clinical Health Act
• Incentivize the adoption of computerized health records: – Reduce medical errors
– Reduce healthcare costs
• Provide Grants to create standards for regional health information exchanges and support structures for EMR adoption
Meaningful Use
Meaningful Use
Focus on meaningful use is a recognition that better health care does not come solely from the adoption of technology itself, but through the exchange and use of health information to best inform clinical decisions at the point of care.
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Meaningful Use
Meaningful Use
The use of meaningful lab data is the largest single opportunity for an organization to control
healthcare spending in the community.
An effective community based lab strategy delivers cost effective and interoperable healthcare that results in improved patient care outcomes.
Laboratory Outreach Delivers
Laboratory Outreach Delivers
…
…
Service Line Value
Service Line Value
Del o it te , Hos p it al CE O S u rvey, 20 05
Most profitable and unprofitable service lines Items that can be transmitted electronically betweenphysician practices and your hospital
Quality Laboratory Information Services • Strengthens physician relations • Reinforces quality of care • Supports profitability
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…
…
and Regional Connectivity
and Regional Connectivity
Patient Patient Patient Patient Patient Patient Patient Patient Patient Patient Patient Patient H LARGE HOSPITAL LABS Academic & Research Centers Clinic Labs Small Hospitals Clinic Labs (Multiple) Physician Office Surgical Center “Minute Clinic” Physician Office Surgical Center “Minute Clinic” “Minute Clinic” Surgical Center Physician Office “Minute Clinic” Surgical Center Physician Office Reference Labs Physician Offices Tele Pathology Tele Pathology
The Regulation of Healthcare
The Regulation of Healthcare
Stark Law State Law Tax-Exempt Standards HIPAA Anti-kickback Statute Reimbursement Range of Acceptable Behavior
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Stark Law
Stark Law
Stark Exceptions and Anti
Stark Exceptions and Anti
-
-
Kickback Safe Harbor
Kickback Safe Harbor
• Purpose
– to increase momentum toward interoperability and EMR adoption within healthcare community
• What may be donated?
– General Rule: Items or services in the form of software or information technology and training
services necessary and used predominantly to create, maintain, transmit, or receive electronic health
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Examples of Covered Technology
Examples of Covered Technology
• EHR Software
• Interface and Translation Software
• Associated Training and Support Services
• Connectivity Services – Broadband and Wireless • Maintenance Services
• Patient Administration, Scheduling and Billing
Items
Items
NOT
NOT
Covered
Covered
• Most Software – Research or Marketing – Human Resources/Payroll – Operating Systems • Hardware • Storage Devices© 2010 Sunquest Information Systems, Inc.
Selection of Physician Recipients
Selection of Physician Recipients
• Recipients may not be selected in a manner that DIRECTLY takes into account the volume or value of referrals or other business generated between the parties
• Permissible criteria
– Total # of hours worked by Physicians – Size of practice
– Physician’s use of technology – Medical staff membership – Level of uncompensated care
Recipient
Recipient
’
’
s Contributions
s Contributions
• Co-payment of 15% of donor’s cost for technology must be paid by the recipient
– Can not be reimbursed
– Stand-alone ePrescribing system does not require a co-payment
• Good documentation of costs “may be a prudent business practice.”
• Transition
– EHR donations must cease December 31, 2013 – Must be assignable
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Patient Protection and Affordable Care Act
Patient Protection and Affordable Care Act
• Department of Health and Human Services(HHS)
– Required to implement new Stark self-disclosure protocol.
• Prevents future ownership of hospitals by physicians or increasing percentage of ownership by physicians
• Referring physicians must inform patients of alternate local suppliers of designated health services prior to providing in-office services
Challenges
Challenges
• Fear – Lack of understanding – Potential costs of inadvertent noncompliance • $$$– Up front and Continued
• Time
– HITECH incentives
• Adoption
– Physicians want to be Independent – Access to data
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Opportunities
Opportunities
• Leverage volume in subsidy programs • Negotiate with vendors to control costs • Explore other options with EHR vendors • Hosted Solutions
• Financing 15% via 3rd party
• HITECH Incentives and Momentum
Physician Connectivity Pre
Physician Connectivity Pre
-
-
ARRA
ARRA
Most Laboratories provide Web based connectivity to their affiliated physicians
– 36% of Laboratories provide both Results reporting and Order Entry – 37% of connected Ambulatory offices submit Laboratory Orders Electronically[1] – 20% of Ambulatory physicians order Medications Electronically
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EMR Adoption Pre
EMR Adoption Pre
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-
ARRA
ARRA
At the current pace full adoption will be reached in 2030.
In order to reach the ARRA goal of 80% adoption by 2014 a 6% increase in EMR adoption is required. However, this is based on an EMR penetration rate of 25% in 2007 which is fairly high even for the assumptions made by AHRQ.
Yes: 14 (78%) No: 4 (22%)
Let
Let
’
’
s Look at the Market Today
s Look at the Market Today
• Does your hospital offer EHR subsidies for affiliated or employed community-based physicians?
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Yes: 7 (37%) No: 12 (63%)
• Does your hospital offer EHR subsidies for non-affiliated or non-employed community-based physicians? 1 (5%) 2 (10%) 7 (37%) 6 (32%) 3 (16%) 0 to 100 101 to 200 201 to 500 501 to 1000 Over 1000 5 (28%) 5 (28%) 2 (11%) 2 (11%) 4 (22%) 0 to 100 101 to 500 501 to 1000 1001 to 2000 Over 2000
• How many beds does your hospital have?
• How many community-based physicians are in your region?
© 2010 Sunquest Information Systems, Inc. 10 (55%) 3 (17%) 3 (17%) 0 (0%) 2 (11%) 0 to 2 3 to 5 6 to 10 11 to 20 Over 20 12 (67%) 4 (22%) 2 (11%) 0 to 5 6 to 10 Over 10
• What is the average number of physicians per practice?
• How many other entities do you
compete with for that community referral base? 3 (16%) 12 (63%) 4 (21%) Greater adoption from smaller practices (1 to 4 doctors) Greater adoption from larger practices (5 or more doctors) Other, please specify 6 (43%) 8 (57%) Yes No
• Have you seen
greater adoption from larger/smaller
practices?
• Have you seen an increase of referrals from doctors that receive EHR subsidies?
Other Comments:
Unknown at this time. Program just started Too early to tell
Very little adoption
© 2010 Sunquest Information Systems, Inc. 12 (63%) 7 (37%) Yes No 6 (31%) 7 (37%) 6 (32%) Hospital Doctors Other, please specify
• Has there been a recent surge in
doctors implementing EHR systems?
• Who pays the maintenance and upkeep costs?
Other Comments: Management group Shared costs
It is built into a subscription model with the hospital subsidizing They pay their ½, we pay our ½
Don’t know 80/20
Case Studies
Case Studies
• North Shore Long Island Jewish Health System
– 50% subsidy
– 85% if share de-identified clinical data
• St. Francis Care – ASP model • Hoag Memorial – 3-4 choices of EHR • Partners Healthcare – 1-2 choices of EHR
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The purpose of this presentation is to inform and comment on recent developments in health law. It is not intended, nor should it be used, as a substitute for specific legal advice.