Meaningful Use Requires Meaningful Laboratory Results · 2017-04-02 · EMR adoption within healthcare community • What may be donated? – General Rule: Items or services in the

Meaningful Use Requires Meaningful Use Requires Meaningful Laboratory ResultsMeaningful Laboratory Results™™

ARRA and Stark Safe Harbor: Opportunities and challenges for you and your outreach business

[email protected]@sunquestinfo.com

© 2010 Sunquest Information Systems, Inc.

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 FactsImportant 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…There’s more!


HITECH ACTHITECH 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 UseMeaningful 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.


Meaningful UseMeaningful 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 DeliversLaboratory Outreach Delivers……Service Line ValueService Line Value

Del

oitte

, Hos

pita

l CE

O S

urve

y, 2

005

Most profitable and unprofitable service linesItems that can be transmitted electronically betweenphysician practices and your hospital

Quality LaboratoryInformation Services• Strengthens physician

relations• Reinforces quality

of care• Supports profitability


……and Regional Connectivityand Regional Connectivity

Patient

Patient

Patient

Patient

Patient

Patient

PatientPatient

Patient

Patient

Patient

Patient

H

LARGE HOSPITALLABS

Academic &Research Centers

Clinic LabsSmall

Hospitals

Clinic Labs(Multiple)

PhysicianOffice

SurgicalCenter

“MinuteClinic”

PhysicianOffice

SurgicalCenter “Minute

Clinic”“MinuteClinic”

SurgicalCenter

PhysicianOffice

“MinuteClinic”

SurgicalCenter

PhysicianOffice

ReferenceLabs

PhysicianOffices

Tele Pathology

Tele Pathology


The Regulation of HealthcareThe Regulation of Healthcare

Stark Law

State Law

Tax-Exempt Standards

HIPAA

Anti-kickback StatuteReimbursement

Range of AcceptableBehavior


Stark LawStark Law


Stark Exceptions and AntiStark Exceptions and Anti--Kickback Safe HarborKickback 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 records (EHR)…


Examples of Covered TechnologyExamples 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 NOTNOT CoveredCovered

• Most Software– Research or Marketing– Human Resources/Payroll– Operating Systems

• Hardware• Storage Devices


Selection of Physician RecipientsSelection 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


RecipientRecipient’’s Contributionss 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


Patient Protection and Affordable Care ActPatient 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


ChallengesChallenges

• Fear– Lack of understanding– Potential costs of inadvertent noncompliance

• $$$– Up front and Continued

• Time– HITECH incentives

• Adoption– Physicians want to beIndependent – Access to data


OpportunitiesOpportunities

• 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 PrePhysician Connectivity Pre--ARRAARRA

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

Source: Laboratory Economics, The Laboratory Economics Web-Connectivity & EMR Report 2008


EMR Adoption PreEMR Adoption Pre--ARRAARRA

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%)

LetLet’’s Look at the Market Todays Look at the Market Today

• Does your hospital offer EHR subsidies for affiliated or employed community-based physicians?


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?


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 startedToo early to tellVery little adoptionMore are asking to be owned by our healthcare system


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 groupShared costsIt is built into a subscription model with the hospital subsidizingThey pay their ½, we pay our ½Don’t know80/20


Case StudiesCase 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


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.

Documents

Meaningful Use Requires Meaningful Laboratory Results · 2017-04-02 · EMR adoption within healthcare community • What may be donated? – General Rule: Items or services in the