The primary focus of CHIME’s Public Policy Program is to advance the role of CIOs and other senior healthcare IT leaders by providing educational, collaborative, and advocacy programs to improve the quality of care. Through our CHIME Policy Chats, we hope to inform CIOs about advocacy efforts and learning opportunities; provide updates on legislative and regulatory issues; and educate them on what CHIME is doing to help shape the implementation of federal and state policies. The discussions feature Sharon Canner, senior director of advocacy, and Jeff Smith, assistant director of advocacy for CHIME.
Chapter 1
- A cybersecurity framework
- Seeking “a balance between flexibility and being prescriptive.”
- Patient data matching in Stage 3
- SGR & payment reform
- Staying the course with ICD-10
- Clearing up the MU confusion — “None of the deadlines have changed for 2014.”
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Bold Statements
When we looked at the proposed framework, our understanding was that it’s an approach to encourage organizations to consider cybersecurity risk just as they would consider risks such as financial, safety, or operational.
Our thinking on this is to look at patient matching in the context of Stage 3. What can you recommend or put into certified technology that will get us to where we want to be?
A lot of good work has been done by CIOs and their staff in getting ready, getting their systems ready, and doing the training such that any delay would really be, we think, a major mistake.
When CMS and ONC announced that they were going to ‘extend Stage 2 and delay Stage 3 to 2017,’ that actually caused a lot of confusion. Because all of the sudden CIOs were getting emails from their CFO and from colleagues saying, ‘Look at this — this is great. We’ve got flexibility.’
There is still time to make changes that are needed, but the window of opportunity is closing quickly and the flexibility on timing for Meaningful Use can go a long way toward making the transition to ICD-10 a more palatable process.
Gamble: Hi Jeff and Sharon, Happy New Year to both of you.
Canner: Happy New Year to you as well.
Smith: Happy New Year.
Gamble: Thank you. So obviously, this is 2014, the year that’s been on everybody’s radar for a while. Why don’t we just jump right in, and you guys can talk about the big things that are on your list — your main focuses for the coming year.
Canner: Certainly. We’re going to go through a number of issues, not necessarily putting them in order of importance, but just sort of rolling through as we start looking at where we’re putting our attention this year. I want to kick off with an issue that actually is a holdover from last year, and that is cybersecurity, which has certainly been in the news — not necessarily for healthcare, but it has been a big issue. What I’m referring to specifically on our radar is that there was request for comment on a preliminary cybersecurity framework that was developed by NIST (National Institute of Standards and Technology). This was released back in October with a due date of December of last year. And so CHIME put together a group of our members, and some of our CIOs reached into their staff to tap into some of the expertise in this area.
When we looked at the proposed framework, our understanding was that it’s an approach to encourage organizations to consider cybersecurity risk just as they would consider risks such as financial, safety, or operational. In that framework, we then identified several unique distinctions about the healthcare sector when you’re talking about cybersecurity. And that gets into such things as the fact that healthcare is a highly regulated industry — we already have many, many rules related to security and privacy, and that needs to be taken that into consideration.
Also, there are multiple settings in the healthcare industry; you have individual physicians and large versus small practices, you’ve got larger systems with more resources and you have small and rural critical access hospitals. There are financial models to consider, there’s data exchange — which is just getting off the dime in a lot of instances, and there are mobile devices. There are all of these factors to consider, and so in putting together our response, we pointed to a number of factors to avoid additional cost and administrative burden on the industry; to seek a balance between flexibility and being very prescriptive; to look at ways to help under-resourced providers; to look at the risk of inaction; and finally, to provide a tool kit for implementation that can help the many players to reach these goals by really giving them a lot of practical applications that could be used.
Gamble: The one thing I wanted to ask was are still finding that with the proliferation of mobile devices, there are enhanced security concerns, just as far as making sure all of the devices — whether they’re owned by organizations or not — have the proper security measures in place?
Canner: It just adds a whole other level. I think we’re really in the very early stages of how all of this is managed. You have environments where it used to be that you could not bring your cell phone into a hospital, for example, and now it’s bring your own device, bring your own system. So it’s certainly a major turnaround. It just sort of adds to the challenges for cybersecurity so I think that’s an excellent question.
Another issue I would talk about is patient matching. As you will recall, in December, the administration, the Office of the National Coordinator in particular, held a stakeholder meeting on patient data matching. This is an issue that CHIME has been promoting and pushing for the last three to four years to make sure that the right patient is identified with his or her data. Certainly there are a lot of false positives and false negatives, and when you’re doing health information exchange, clearly the risk increase. As we all know, it’s been in the political third rail that you cannot use an identifier, but what else can we do? The administration at this stakeholder meeting released a proposal or a set of recommendations — although I think they were careful to say that these are not firm recommendations and that we really want to hear the feedback from the industry.
CHIME was there as well as host of other stakeholders. There were a lot of discussions about privacy and about different algorithms and risk frameworks. Our thinking on this — and I think a lot of others agree — is to look at patient matching in the context of Stage 3. What can you recommend or put into certified technology that will get us to where we want to be? We were really pleased to see that ONC stepped up and is focusing on this issue. We’re going to be looking for a lot more to come out this year certainly as the proposed rules are developed for Stage 3. We will certainly be very much involved in that.
Gamble: Are you still finding that this is a hot button issue and that people have really strong opinions about it?
Canner: Absolutely. And particularly at that stakeholder meeting, there was some pushback from some who actually believed that the electronic health record creates more problems than it solves. I think these are old discussions, but the general tenor of what we heard at this meeting and from ONC was really the impetus to go forward and to really get into trying to finally solve this major challenge. We’re very excited that CHIME has had a big role in continuing to push on this issue to present information. A number of our CIOs have appeared at not only this forum but also others to try to make some very practical points about what is it like when you are the CIO and you really have to be sure that you’ve got the right patient with the right data. Again, we’re really pleased going forward on that.
The other thing I will mention real quickly is SGR reform. As you know, both sides of congress have now marked up legislation, but this is a major change in SGR that obviously is not going to be taken up just yet. Right now we currently have a short‑term patch, but I think what we like, and what we saw, in the major reform package is to provide more resources for clinical quality measures; to look at that issue to be included with the Meaningful Use program and incentives for payment reform, taking into consideration advance payment models and just trying to bring these pieces together, rather than to isolate SGR reform.
So we’ll be watching this one closely. I would say this is not a top issue for us in terms of matching it up with others, but certainly something that is very, very important. And we’ll be looking to see where this goes.
Gamble: It is certainly going to become more of a big issue as we see more Accountable Care organizations come together, that there is a need to change from the whole fee for service model. This is something that I’m sure we’ll start to pick up some momentum in the next year or so.
Canner: Absolutely. And this has been under discussion for such a long time, just major SGR reform. I want to move to an additional issue before we segue over to Jeff, and that is ICD-10. The October 1 date is looming, and CHIME is very firm in believing we need to go forward on compliance for ICD-10 on October 1. A lot of good work has been done by CIOs and their staff in getting ready, getting their systems ready, and doing the training — and I would emphasize the word ‘training’ — such that any delay would really be, we think, a major mistake because of having to retrain staff and redo systems. We really need to move to ICD-10.
That being said, there is a real concern on the part of a convergence of things happening in 2014. Of course you have Meaningful Use Stage 2, the date which remains firm, and Jeff will talk more about that. We recently queried a number of our CIOs, and one of the concerns we found with the hospital systems is that with their affiliated and independent physicians, the convergence factor is going to make it very, very difficult. And when push comes to shove, they’re going to do ICD-10 over Meaningful Use if it really becomes a choice and they are just unable to comply with both. We’ve been trying to work with them and trying to work with CMS in really trying to educate on what the issues are around this. So let me now move over to Jeff to talk a little bit more about ICD‑10 as well as Meaningful Use and other issues that are at our forefront.
Smith: Thanks, Sharon. Talking about ICD-10 becoming a compounding factor in 2014 to other things associated with Accountable Care and Meaningful Use — I really do think that’s going to be the story of 2014 in terms of the issues that are directly in front of the faces of CIOs. I think that we’ve got a lot of ground to cover. As you know, we’ve been pretty vocal on the need to provide flexibility in 2014. I’m not sure if you saw the headlines that we saw toward the end of last year when CMS and ONC announced that they were going to ‘extend Stage 2 and delay Stage 3 to 2017,’ but that actually caused a lot of confusion out in the industry. Because all of the sudden CIOs were getting emails from their CFO and from colleagues saying, ‘Look at this — this is great. We’ve got flexibility. We can take up to three years to meet Stage 2. This is perfect. This is exactly what we need to make sure that we have a safe and orderly transition.’
Unfortunately, that announcement was badly misconstrued, and we have to reiterate all the time that none of the deadlines have changed for 2014. If you’re a hospital and you’ve gone through at least one year of Meaningful Use, then you have to be up and running no later than July 1to start collecting data for three months. And if you’re a physician past your first year you’ve got to be up and running by October 1using 2014 edition technology. Insofar as we continue to hear from members that this is a challenge, we continue to communicate that to CMS and ONC and the White House, because we do think that there is still time to make changes that are needed, but the window of opportunity is closing quickly and the flexibility on timing for Meaningful Use can go a long way toward making the transition to ICD-10 a more palatable process.
Gamble: Right.
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