2013 was a good year for health IT and has laid the foundation for 2014 to be the biggest year ever for the industry.
The current deadline to implement ICD-10 is very unlikely to change. The federal government already allowed a one-year delay in the compliance deadline for the nationwide conversion to the ICD-10 code sets. That delay moved the compliance deadline to Oct. 1, 2014, and I don’t see much chance it will be pushed out further (most of the rest of the developed world has been using ICD-10 for years).
“These new standards are a part of our efforts to help providers and health plans spend less time filling out paperwork and more time seeing their patients,” HHS Secretary Kathleen Sebelius said in a news release announcing the deadline. This is a revolutionary change to ICD coding from the current 17,000 codes under ICD-9 to more than 155,000 codes under ICD-10, including about 68,000 diagnostic codes.
There will be some significant challenges in converting from ICD-9 to ICD-10 and there are some serious concerns around the readiness of healthcare organizations and providers to achieve a successful implementation. A Workgroup for Electronic Data Interchange (WEDI) study showed about 80 percent of participants have not begun testing, and only about half have undergone the initial step of conducting an impact assessment. WEDI sent a letter early in this year to HHS spelling out some of the concerns with regards to testing.
WEDI has partnered with CMS to create the ICD-10 Implementation Success Initiative. Hopefully this will help provide the necessary resources for the health system to deal with this massive change. ICD-10 could be the Y2K of healthcare this year, and it may just go off as smoothly. HIMSS has a very good ICD-10 Playbook that has some valuable tools to help.
Privacy and Security
The HIPAA Omnibus rule that came into effect last year will see enforcement rolling out in 2014. Federal regulators are planning for a permanent HIPAA audit program that will begin this year, said Leon Rodriguez, director of the HHS Office for Civil Rights (OCR). However, with Rodriguez set to leave his position to fill a new role as director of the United States Citizenship and Immigration Services (USCIS), we will have to see who is eventually named to lead the OCR and how the enforcement plan will play out under this year’s restricted budget. Regardless, I expect that we will see some strong enforcement, in particular for inappropriate disclosure of data and the denial of access to patient records to patients. HIPAA has strong protections for a patient having the right to access their own health information—this will be a key focus of enforcement in 2014.
There are likely to continue to be breaches reported throughout the industry, and some would use this as a way to argue against the digitization of our healthcare system. I think this is a serious mistake. Having electronic health information can be very secure and has incredible benefits.
One reason that we see more reported breaches is that we now know about them. With strong privacy and security controls and the ability to audit for inappropriate access, we are aware of who has viewed information, unlike in the past when someone may have perused a patient’s chart and there was no way to to know if the data was compromised.
Increased reporting of breaches can actually be a good thing and we are able to hold accountable those responsible.
Stage 2 of meaningful use is upon us, and while the beginning of stage 3 is pushed out a year, there will be a lot of discussion on what the regulatory framework is to become. So far there have been no changes to the timelines for stage 2 meaningful use in 2014, although CMS and ONC have made changes to extend stage 2 and push out the beginning of stage 3.
I expect that some form of regulatory relief for 2014 may come this year. This year we will see the stage 3 rules take shape, and the HIT Policy and Standards Committees will have a sharp focus on future requirements. There will also continue to be political pressure from Congress (this is an election year after all) with an emphasis on interoperability. And we will see the number of certified products decreased as the reality of the 2014 Edition certification criteria sets in for vendors and their customers.
I expect that there will be quite a few healthcare providers, especially in rural and underserved areas, that will find it difficult to meet the stage 2 requirements this year. We may see the beginning of a digital divide as large health systems continue to gobble up smaller ones as well as physician practices.
As one rural hospital CEO put it, “A small community hospital can not make it alone in this environment and acquisition or very strong affiliation is necessary to survive.” This is true not only from a financial standpoint in the era of health reform, but from an IT standpoint. Community and critical access hospitals may not have the resources to meet the new requirements, and vendors will focus efforts at supporting their bigger customers. I still believe that in order to look out for the little guy, greater flexibility is needed in the timeline for meaningful use in 2014.
Providers will also be facing the possibility that their current product is not yet certified, or no longer complete certified, meaning they are not able to attest for all of the criteria. There is nothing wrong with a modular approach to achieving meaningful use, but it will be important to think through what is needed.
A search on the Certified Health IT Product List (affectionately known as “The Chapel”) shows that for the 2011 Edition there were more than 3,700 products for ambulatory and almost 1,200 for inpatient. In contrast: so far for the 2014 Edition there are only 664 products for both combined, and only 112 have achieved complete certification (these numbers will of course go higher throughout the year). There are many that were complete certified to the 2011 Edition that will only attain modular certification for 2014. The customers using those systems may need to either switch vendors completely or purchase additional software to fill the gaps they face in functionality.
2014 begins a new stage of meaningful use and also should usher in a new way of measuring success of the EHR Incentive Program. Up until now we have primarily been judging success by the number of hospitals and physicians participating, the amount of taxpayer dollars paid, and general EHR adoption metrics.
This year we will likely see a shift under a new National Coordinator and increased congressional scrutiny to measuring improvements to the health system as a result of health IT. I would look at indicators such as better population health, lowered costs, and higher patient satisfaction as some of the possible areas of focus.
Interoperability and Health Data Exchange
Health Information Exchange (HIE) is going to take off in 2014! I have said that analytics provides the ROI for our health IT investments — and HIE is a key enabler for analytics to succeed. The need to aggregate data at a community level for improved population health management is a driving force in adoption of HIE.
The increased consolidation in the industry is also creating a need to not only gather health data from outside an organization’s walls but – with the patchwork of systems sometimes in place due to mergers and acquisitions – HIE will allow data to be shared between disparate systems internally as well. The foundation is now laid with the infrastructure in place for HIE to be broadly available and used this year.
The Transitions of Care requirements for meaningful use, and the Standards and Certification criteria including Direct protocols in certified EHR technology, are making capabilities for exchange ubiquitous. The success of organizations like Healtheway and DirectTrust (I am on the Board of Directors for DirectTrust) have created a framework for scalable trust and broad-based exchange.
As the State Health Information Exchange Cooperative Agreement Program winds down, this year will be the year that HIE moves to market-based approaches that provide value and have sustainable business models. Some organizations will go bust, some will merge and others will wildly succeed.
The patient engagement requirements for meaningful use, and the need to empower patients to succeed in new payment and care delivery models, make this a very important strategic priority. 2014 will be a very big year for patient engagement, and has been vying in my mind for the title “2014 will be the year of…” (which I gave to health data analytics).
I will be writing quite a bit in the next few months on this topic and following the issue closely. Information is power, and empowered patients need to have real time, ubiquitous access to their own health data if they are to be informed partners in their care. For a taste of how important this topic is, watch the video below of Lygeia Ricciardi, Director, Office of Consumer eHealth at the ONC, during the Health Affairs briefing “New Era Of Patient Engagement,” February 6, 2013: Lygeia Ricciardi at Health Affairs Briefing.
It is interesting to realize that seven years ago almost no one had a smart phone, now almost everyone does. This puts the power of computing in the palm of our hands makes for some fantastic opportunities to leverage mobile devices in healthcare. Mobile health will be a great topic of discussion this year, although I think that it will really have a huge impact in the next two to three years.
Last year the FDA issued some final guidance on mobile medical apps, spelling out the FDA’s approach to mHealth regulation.
“Some mobile apps carry minimal risks to consumer or patients, but others can carry significant risks if they do not operate correctly. The FDA’s tailored policy protects patients while encouraging innovation,” said Jeffrey Shuren, M.D., J.D., director of the FDA’s Center for Devices and Radiological Health. The FDA is focusing its oversight on mobile medical apps that:
- are intended to be used as an accessory to a regulated medical device – for example, an application that allows a health care professional to make a specific diagnosis by viewing a medical image from a picture archiving and communication system (PACS) on a smartphone or a mobile tablet; or
- transform a mobile platform into a regulated medical device – for example, an application that turns a smartphone into an electrocardiography (ECG) machine to detect abnormal heart rhythms or determine if a patient is experiencing a heart attack.
Digital health technologies also played an increasing role at CES where the Digital Health Summit is co-located as part of the event. CEA, which runs the event, announced “a 40 percent growth of the digital health footprint” at the event, and there has certainly been an increase in the consumer digital health market. 2014 will continue to build on this trend and I expect to see quite a bit of start-up activity.
2014 will be the year of health data analytics. With new payment and care delivery models being widely implemented with a sharp focus on improved population health, it is now time to build on the success we have had with data capture and data sharing and move towards data analytics that will allow us to finally realize the value of health IT. 2014 is going to be a very, very busy year for health IT. We may have finally reached the tipping point where technology has a strong and obvious impact on lowering costs and improving care.
Latest posts by Brian Ahier (see all)
- New ONC Leader Karen DeSalvo Discusses Priorities, Current Health IT Landscape at HIMSS14 - March 4, 2014
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- What’s in Store for Health IT in 2014? - January 23, 2014