Policy

Blog – March Madness in Radiology: the Push for ACOs

dondennison Radiology ,

March Madness in Radiology: the Push for ACOs

This excerpt…

Prompt, consistent report delivery must be available and employ current technologic standards that streamline this, including tablet and smartphone delivery to providers. Rigorous quality reviews, peer evaluation and communication between radiologist and technical centers must be used to improve quality. Electronic methods of tracing and evaluating incidents should be employed.

…is on the money, but this technology platform should be part of the EMR (probably sourced as an add-on) and managed by the same group that manages the EMR, not Radiology. Radiology should indeed provide the guidance to configure the platform to meet Radiology’s needs, but they aren’t the only specialty that needs these tools, so a shared service is the best approach.

Article – Get set: New HIPAA has teeth

dondennison Policy

In this article, the new HIPAA Privacy and Security final rule—also known as the HIPAA Omnibus Rule—which became effective on March 26, 2013, is discussed.

Some thoughts…

  • Access to protected health information by 3rd parties, such as vendor support staff, is mentioned. In the related article referenced at the bottom (note: link is broken; corrected link here), it mentions that “Third parties account for 40 percent of the breaches reported and 75 percent of the records exposed”. It will be interesting to see how effective a vendor’s support staff will be when they are unable to analyze data referenced in a reported problem; invalid or corrupt data is a common enough problem that analyzing the original data to eliminate this as a root cause of the problem is a routine task. Also, wide scale analysis of databases to detect frequency of missing or invalid data elements is also a common method. If this data is not made available, or is stored in an encrypted form (at rest), it will be interesting to see how effective current support methods and tools will be (may need to be updated).
  • Same question as above for Business Intelligence (BI) applications that often mine databases (and sometimes files) containing patient record information.
  • Encryption of data on disk (by the storage subsystem or the application) is relatively common (often as an option), but encryption of the database files is less common (though technically feasible with many database management systems). It seems to me that most of the detected and reported breaches are of laptops and portable media (e.g. USB drives).
  • I wonder, if this rule is heavily enforced, if the fines will become enough of a revenue source to be viewed as a way of offsetting the costs of enforcement, or even funding—much like speeding and parking tickets subsidize police operations.

Article – mHIMSS executives say FDA regulation won’t hold back app innovation

dondennison Healthcare IT , ,

This short Q&A article discusses the role and impact of FDA regulation, as well as the new medical device excise tax.

Some thoughts…

  • Someone explain to me how applications accessed on a tablet or smartphone are so much different than a desktop app being accessed on a netbook on Wifi. A tablet is a computer, typically without a keyboard and mouse. The user input method varies slightly and we have a whole new class of device? I don’t get it. If an application is collecting clinical data (e.g. dermatology photo), it should be subjected to appropriate regulations regardless if the user is using a mobile computer or a full desktop to run the application. This seems to me like a lack of understanding of computing by policy makers.
  • I believe the driving issue are mobile app developers getting into healthcare rather than registered medical device manufacturers getting into building mobile apps. Those familiar FDA regulations (and similar ones in other jurisdictions) generally know the rules. It is the mobile app developers unaware of the FDA regulations that are likely facing the greater challenge (mostly learning the requirements of being a medical device manufacturer). Providing the right guidance to the app developer community could be a growing opportunity for experienced regulatory affairs contractors/consultants.

Article – The Obamacare Revolt: Physicians Fight Back Against the Bureaucratization of Health Care

dondennison Policy

Politics aside, this article provides some numbers on the actual costs of some healthcare procedures in the U.S., comparisons to the reimbursement amounts for these, and the “horse trading” to make some procedures more affordable (performed at a loss), while others are allowed to be more expensive (higher margin to subsidize the other procedures).

Medical imaging (MRI) is mentioned on the second page.

Article: Global pioneer James Thrall reflects on 30 years in radiology

dondennison Radiology , ,

Worth a read (note: you may have to have an account on the site, but I believe it is free). Covers a lot of history and provides a sobering perspective of state of Radiology today…

Economically, radiology experienced a classic bubble in my 30 years as a department chairman. Tailwinds from new technology increased both the demand for imaging services and reimbursement per average case. These were coupled with increased efficiency from PACS, and led to remarkable increases in departmental income and compensation for individual radiologists.

While the economic vectors were all pointing up, we were lulled into thinking this was the way things were always going to be — and should be. Wrong. As soon as imaging became the fastest-growing cost segment in healthcare, the knives came out and reimbursement cuts began, however flawed their logic. The bubble burst.

WSJ.com: The Coming Failure of Accountable Care

dondennison Policy ,

The Coming Failure of Accountable Care

Interesting (and perhaps correct) predictions.

While a change to the financial motivations–from reimbursement for procedures (which leads to volume) to funding based on clinical outcomes, quality of care and savings achieved–is admirable, the issue of change management looms. If the systems changes, but those in the system do not, what is accomplished?

Also, one thing I still have to figure out (more reading needed) is how an ACO serving a statistically high elderly or obese or otherwise higher health risk population is compared to one that serves a relatively young and healthy population. Is there some form of “base line” measurement done and the ACO is measured based on improvement from there?