Top Down Meets Bottom-Up
By Rod Baird
This is the 3rd year I’ve attended the LTPAC HIT Summit and this year the event celebrated its 10th anniversary. To my knowledge this is the single annual meeting that is useful for everyone engaged with the LTC continuum. That means not just Nursing Facilities and Home Health Agencies, but the vast array of providers that serve this very costly population – hospitals, ACOs, Multispecialty Physician groups, and the vendors who support them. The overriding goal – connect these entities so patients actually experience a continuum of care, not just a series of episodes.
If you didn’t attend, you should look at the agenda to see the range of issues people grapple with. It is really the place to meet colleagues who you only know via email or conference calls.
The 1st year I attended the event was at the at the recommendation of Liz Palena-Hall, RN the ONC’s Policy Analyst for Long Term Care. For these three years running, presenters described the projects they’ve undertaken to connect LTPAC programs with hospitals, community physicians, beneficiaries, and other entities.
At the end of each presentation, all I can do is shake my head at the low level of progress being made compared to the immense level of effort.
Today’s blog reflects on my personal analysis of why it is so hard to connect LTPAC with the greater community. I’m also offering our strategy for minimizing some of the barriers.
The major hurdles we experience are:
- Money – LTPAC Providers have no funding (e.g. HiTech Act $s for Meaningful Use) to prime their data capture/exchange efforts. Medicare & Medicaid payments for patient care are dropping, while other regulatory burdens are growing. There is simply no resource available for infrastructure development – so even the most committed providers have to go slow.
- Untimely/Unavailable Information – Consider both sides of SNF/Hospital transition. It’s only with 2014, that a decent standard (CCDA) exists to support interoperability and robust message content. Only a few LTPAC vendors are certified for this standard, and hospitals have so many challenges getting 2014 CEHRT operational that a LTPAC transfer document is a lower priority.
- Moving Target for Content – A mix of the same disciplines (MD, Nursing, PT/ST/OT, MSW, CNA, etc.) work across the spectrum of LTPAC settings. Each location has a unique payment/regulatory scheme – which require documenting different actions/elements that aren’t synchronized. Those differences, and lack of objective standards, make any shared care, or transition of care documentation a challenge. It is clear that CMS, via legislation, is trying to move to standardized assessments (IMPACT Act of 2014). This makes it problematic for any software vendor to design ToC documents, knowing the content will be changing.
- Hospital > SNF: The single most useful document (from the LTPAC Physician’s POV) is the Discharge Summary by the Hospitalist. Unfortunately, only a few very well organized Hospital systems have this available at the time of discharge – it is usually a few days late. Without that critical information, the effort to be fully electronic seems less urgent.
- SNF > Hospital: LTPAC software is largely designed to record data associated with Medicare & Medicaid rules (payments & survey). Most of those data elements are not of significant interest to Hospitals or community based physicians (e.g. MDS data). Transforming the MDS into a CCD is only a partial solution. The data is often out of date, and doesn’t include medications or physician notes.
- Current Efforts Put the Cart Before the Horse – The Summit’s presentations focused on exchanging LTPAC data using an HIE or analogous strategy. As a general statement, (there are always exceptions) HIEs are a long way from delivering on their promise of sharing usable clinical information across the continuum. For LTPAC providers, again my personal opinion, the effort is only warranted when they gain some type of Preferred Provider Status. I know from our own large LTC Physician Group (ECP in NC/SC) that we are regularly asked to enroll in various HIEs and submit our data into a pool. In return the physician is offered a view-only window into a variety of patient reports (text), much of which is interesting, but not pertinent to issues at hand. We do collaborate, but only superficially – today’s ROI for the LTPAC Physician is limited in the markets we cover.
I’m also responsible for gEHRiMed, a cloud based EHR for LTPAC physicians. We work with many large LTC groups across multiple states; some are ACO enrollees. We support (and have successfully tested interoperability) for standard data exchange – CCDs in the past, now CCDAs. Many groups want to verify that we can create files, but then nothing happens. Outside of the pilot projects featured at AHIMA LTPAC, the infrastructure to consume these documents doesn’t really exist.
Because of my past involvement with CMS’s Innovation Center, we do know many of the leading figures in AHIMA’s LTPAC thought leadership. I was able to identify specific locations where we support physicians that overlap facilities in some of the demonstration project sites. I’ll look forward to seeing how many of them are able to actually exchange data.
My next blog post will cover the bottom-up side of LTPAC Data exchange – including an update on the evolution of ePrescribing in the face of CMS’s deadline for use of the NCPCP 10.6 standard. This will feature comments on a presentation I had the privilege of giving with Chris Laxton, AMDA’s Executive Director, and Shelly Spiro, the Pharmacy HIT Collaborative’s Executive Director.
About the Author: Rod Baird is founder and president of Geriatric Practice Management (GPM) and gEHRiMed. Since 1977, he’s led provider and management organizations that deliver care to Medicare/Medicaid beneficiaries. He also was chosen to be a part of the Centers for Medicare and Medicaid Services’ (CMS) Innovation Advisors Program. Originally posted on LTC Management with permission to syndicate.