Stage 2 Meaningful Use, Interoperability of EMRs and ICD-10. What is CMS, ONC and HIPAA Impact on Accountable Care Organizations?

Last week we attended HIMSS12 the national conference of HIMSS in Las Vegas. The pace of adoption of electronic medical records is increasing, and Dr. Farzad Mostashari, Director of the Office of the National Coordinator (ONC) from Health and Human Services (HHS) made a breath taking statement in his key note that he expects more care to be delivered in 2013 by providers using an EMR than not.   Wow – did he just suggest over 50% adoption of Electronic Health Records?

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Dr. Farzad Mostashari photo
Dr. Mostashari, Director of ONC at his HIMSS Keynote

Current data suggests that we have achieved perhaps 15% of U.S. Medicare and Medicaid providers achieving meaningful use attestation via a regional extension center and CMS web portal, with perhaps 30% in some stage of development of implementing an EMR.

We also attended a session given by the primary author of Stage 2 meaningful use, Travis Broome from CMS.  There are revisions in the attestation process, timing of incentives and also a carrot and stick for industry adoption of standards for supporting quality measures (a key driver of payment reform and the shift away from fee for service medicine) in EMRs whereby CMS can either sweeten incentives or reduce them.

Although $27 billion has been put forth by HHS and CMS for EMR adoption, the real prize will be in determining who has access to the data of the EMR and how interoperability will be facilitated.  Vendors who are either providing EMRs or integrating with them are attempting to both embrace the Clinical Document Architecture (CDA) as well as differentiate from their competition.

One of the key questions will be how the EMR provides a foundation with the Health Information Exchanges (HIEs) for comparative effectiveness data over the life span of  a patient (sometimes called the continuum of care) and whether CDA standards currently proposed will accomplish that.   Informatics people call this “longitudinal clinical data.”  We’ll be speaking this spring on these topics and analyzing in future reports whether Accountable Care Organization enablement is on track.  While the $billions in meaningful use incentives are getting the spotlight today, the shift from Fee for Service (FFS) to evidence based medicine represents a tectonic shift in the $3 trillion health care economy.  When blended with ICD-10, we have a perfect storm for innovation and redistribution of wealth in healthcare.  Although ICD-10 has likely been delayed and some providers are relieved, the interaction between CMS, ONC, and HIPAA standards creates some interesting opportunities in the next five to ten years.  ICD-10 will provide the underlying content of diagnosis and procedure codes that will populate the EMRs and HIEs.

Keep watching the interchange between CMS, who sets the standards for Meaningful Use (i.e adoption of EMRs) and ONC that sets the standards for interoperability.  And, look for vendors with vision that can capitalize on the standards while achieving commercial adoption to enable Accountable Care Organizations.

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Michael F. Arrigo

Michael Arrigo, an expert witness, and healthcare executive, brings four decades of experience in the software, financial services, and healthcare industries. In 2000, Mr. Arrigo founded No World Borders, a healthcare data, regulations, and economics firm with clients in the pharmaceutical, medical device, hospital, surgical center, physician group, diagnostic imaging, genetic testing, health I.T., and health insurance markets. His expertise spans the federal health programs Medicare and Medicaid and private insurance. He advises Medicare Advantage Organizations that provide health insurance under Part C of the Medicare Act. Mr. Arrigo serves as an expert witness regarding medical coding and billing, fraud damages, and electronic health record software for the U.S. Department of Justice. He has valued well over $1 billion in medical billings in personal injury liens, malpractice, and insurance fraud cases. The U.S. Court of Appeals considered Mr. Arrigo's opinion regarding loss amounts, vacating, and remanding sentencing in a fraud case. Mr. Arrigo provides expertise in the Medicare Secondary Payer Act, Medicare LCDs, anti-trust litigation, medical intellectual property and trade secrets, HIPAA privacy, health care electronic claim data Standards, physician compensation, Anti-Kickback Statute, Stark law, the Affordable Care Act, False Claims Act, and the ARRA HITECH Act. Arrigo advises investors on merger and acquisition (M&A) diligence in the healthcare industry on transactions cumulatively valued at over $1 billion. Mr. Arrigo spent over ten years in Silicon Valley software firms in roles from Product Manager to CEO. He was product manager for a leading-edge database technology joint venture that became commercialized as Microsoft SQL Server, Vice President of Marketing for a software company when it grew from under $2 million in revenue to a $50 million acquisition by a company now merged into Cincom Systems, hired by private equity investors to serve as Vice President of Marketing for a secure email software company until its acquisition and multi $million investor exit by a company now merged into Axway Software S.A. (Euronext: AXW.PA), and CEO of one of the first cloud-based billing software companies, licensing its technology to Citrix Systems (NASDAQ: CTXS). Later, before entering the healthcare industry, he joined Fortune 500 company Fidelity National Financial (NYSE: FNF) as a Vice President, overseeing eCommerce solutions for the mortgage banking industry. While serving as a Vice President at Fortune 500 company First American Financial (NYSE: FAF), he oversaw eCommerce and regulatory compliance technology initiatives for the top ten mortgage banks and led the Sarbanes Oxley Act Section 302 internal controls I.T. audit for the company, supporting Section 404 of the Sarbanes Oxley Act. Mr. Arrigo earned his Bachelor of Science in Business Administration from the University of Southern California. Before that, he studied computer science, statistics, and economics at the University of California, Irvine. His post-graduate studies include biomedical ethics at Harvard Medical School, biomedical informatics at Stanford Medical School, blockchain and crypto-economics at the Massachusetts Institute of Technology, and training as a Certified Professional Medical Auditor (CPMA). Mr. Arrigo is qualified to serve as a director due to his experience in healthcare data, regulations, and economics, his leadership roles in software and financial services public companies, and his healthcare M&A diligence and public company regulatory experience. Mr. Arrigo is quoted in The Wall Street Journal, Fortune Magazine, Kaiser Health News, Consumer Affairs, National Public Radio (NPR), NBC News Houston, USA Today / Milwaukee Journal Sentinel, Medical Economics, Capitol ForumThe Daily Beast, the Lund Report, Inside Higher Ed, New England Psychologist, and other press and media outlets. He authored a peer-reviewed article regarding clinical documentation quality to support accurate medical coding, billing, and good patient care, published by Healthcare Financial Management Association (HFMA) and published in Healthcare I.T. News. Mr. Arrigo serves as a member of the board of directors of a publicly traded company in the healthcare and data analytics industry, where his duties include: member, audit committee; chair, compensation committee; member, special committee.

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