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Information Blocking–Gropper & Peel Weigh in

Deborah C. Peel
Adrian Gropper

Today is the last day for public comments on the proposed CMS regulations regarding Medicare hospital inpatient prospective payment systems (IPPS). While there are several changes proposed, the one that’s raised lots of attention has been the idea that access to Medicare may be denied to those providers guilty of information blocking. Here are the comments submitted by Gropper & Peel from Patients Privacy Rights— Matthew Holt

Executive Summary of PPR Comments on Information Blocking

Information blocking is a multi-faceted problem that has proved resistant to over a decade of regulatory and market-based intervention. As Dr. Rucker said on June 19, “Health care providers and technology developers may have powerful economic incentives not to share electronic health information and to slow progress towards greater data liquidity.” Because it involves technology standards controlled by industry incumbents, solving this problem cannot be done by regulation alone. It will require the coordinated application of the “power of the purse” held by CMS, VA, and NIH.

PPR believes that the 21st Century Cures Act and HIPAA provide sufficient authority to solve interoperability on a meaningful scale as long as we avoid framing the problem in ways that have already been shown to fail such as “patient matching” and “trust federations”. These wicked problems are an institutional framing of the interoperability issue. The new, patient-centered framing is now being championed by CMS Administrator Verma and ONC Coordinator Rucker is a welcome path forward and a foundation to build upon.

To help understand the detailed comments below, consider the Application Programming Interface (API) policy and technology options according to two dimensions:

API Content and Security Institution is Accountable Patient is Accountable
API Security and Privacy
  • Broad, prior consent
  • Patient matching
  • Institutional federation
  • Provider-directed interop
  • Compliance mindset
  • Directed authorization
  • Known to the practice
  • Individual credentials
  • Patient-directed interop
  • Privacy mindset
API Content / Data Model
  • Designated record set
  • FHIR
  • Patient-restricted data
  • De-identified data
  • Bulk (multi-patient) data
  • Designated record set
  • FHIR
  • Sensitive data
  • Social determinants
  • Wearables and monitors

This table highlights the features and benefits of interoperability based on institutional or individual accountability. This is not an either-or choice. The main point of our comments is that a patient-centered vision by HHS must put patient accountability on an equal footing with institutional accountability and ensure that Open APIs are accessible to patient-directed interoperability “without special effort” first, even as we continue to struggle with wicked problems of national-scale patient matching and national-scale trust federations.

Here are our detailed comments inline with the CMS questions in bold:Continue reading…

India’s Health Insurance Experiment. Who will be the winners?

By SAURABH JHA

Though the exact cost of Modicare, the government’s extension of health insurance for poor people, estimated at one lakh crore (a trillion U.S. dollars), is open for debate, what is not disputable is that the cost of insuring India’s poor won’t fall with time. A sure way of accelerating healthcare inflation, that is speeding the rate of increase of healthcare costs, is by subsidizing or paying for health insurance. Insurance is like Newton’s Second Law of Motion – the velocity keeps increasing as long as the force is applied.

Healthcare is a peculiar industry. Cars get cheaper but medical care doesn’t. The Maruti eventually became cheaper than the Ambassador, and more aesthetically pleasing than its Neanderthalic predecessor. Medical care doesn’t get cheaper because a life saved from cancer is a life waiting to be killed by another disease, which needs treating, too. Survivors of cancer get heart attacks and survivors of heart attacks get cancer, and survivors of both get dementia.

It’s like a restaurant where you can’t just pay for lunch – if you pay for lunch you have to pay for breakfast and dinner and may be a few samosas in between the meals. But unlike eating, consumption of medical care is not guarded by satiety. The insatiable medical sciences keep delivering even more expensive ways death can marginally be deferred. For example, the once dreaded stroke which leads to paralysis is now treatable. However, the treatment is not cheap and comprises clot busters, dangerous drugs with fatal side effects. Further, to treat stroke you need rapid diagnosis by modern imaging – that is you need CAT scans and radiologists. If penicillin for pneumonia is like eating at a roadside dhaba, treatment for acute stroke is fine dining at the Taj.

Continue reading…

Health in 2 Point 00, Episode 34

I’m back. After the takeover editions, I’m answering Jessica DaMassa about Atul Gawande as the CEO of the ABC new venture, the demise of Caresync, Ooda Health and its demand for a female VC, and whole bunch more blather! — Matthew Holt

Adjusting for Risk Adjustment

Risk adjustment in health insurance is at first glance, and second, among the driest and most arcane of subjects. And yet, like the fine print on a variable-rate mortgage, it can matter enormously. It may make the difference between a healthy market and a sick one.

The market for individual health insurance has had major challenges both before and after the Affordable Care Act’s (ACA’s) risk adjustment program came along. Given recent changes from Washington, like the removal of the individual mandate, the market now needs all the help it can get. Unfortunately, risk adjustment under the ACA has been an example of a well-meaning regulation that has had destructive impacts directly contrary to its intent. It has caused insurer collapses and market exits that reduced competition. It has also led to upstarts, small plans and unprofitable ones paying billions of dollars to larger, more established and profitable insurers.

Many of these transfers since the ACA rules took effect in 2014 have gone from locally-based non-profit health plans to multi-state for-profit organizations. The payments have hampered competition not just in the individual market, which has never worked very well in the U.S., but in the small group market, which arguably didn’t need “help” from risk adjustment in many states.

The sense of urgency to fix these problems may be dissipating now that the initial rush for market share under the ACA is over and plans have enough actuarial data to predict costs better. There has been an overall shift to profitability. But it would be a serious mistake to think that just because fewer plans are under water, the current approach to risk adjustment isn’t distorting markets and harming competition.

Continue reading…

Defining Engagement in an Age of Patient Monitoring and Data Collection

SPONSORED POST

If you have an innovative solution that addresses Patient Engagement and Remote Monitoring, Bayer’s Dealmaker Challenge wants to hear from you! Apply here for a shot at collaborating with the Bayer G4A Digital Health Team and participating in Dealmaker Day, an exclusive matchmaking event, October 9th in Berlin.

What is healthcare without patients? For decades physicians have been a one-stop shop for diagnosis and treatment, a trusted source. And yet it’s only been in recent years that the entire healthcare industry has woken up to the notion that patients can and should have an active role in their healthcare and the decision making process. Patients may not have a medical education or clinical experience, but they do have a strong asset going for them: intimate knowledge of their bodies and access to information only they can provide. The rise of wearable technologies over the past decade has only increased patients ability to quantify their experiences, health and otherwise. Diet, exercise, daily habits, stress levels, family life, physical environment all contribute to an overall picture of health. Yet too often, clinicians only see a slice of their patients health picture – the picture that is presented during office visits. The increased importance of tracking lifestyle data has clinicians and technologists asking themselves, How do we unlock more information in order to make better decisions and deliver better care?

The field is called Patient Engagement. And while the industry has mutually agreed upon it’s critical importance, the question remains as to what it looks like.Continue reading…

Can Medicaid Expansion Survive?

Amid fresh political rancor and legal machinations in the ongoing war over the Affordable Care Act (ACA), there’s a bright spot: Medicaid. At least for now.

This matters. True to predictions made by Obama and supporters when the ACA became law (2010), it has taken years and a lot of blood, sweat and tears to get to this moment.

As a reminder, the U.S. Supreme Court in 2012 ruled that states could opt out of the ACA’s Medicaid expansion—leaving each state’s decision to participate in the hands of governors and state lawmakers.

On June 7, after a 4-year pitched political battle, Virginia became the 33rd state (plus DC) to expand Medicaid under the ACA. The Virginia expansion is projected to encompass 400,000 low-income Virginians.

The state swung in favor of expansion after Democrats gained the governorship and more seats in the legislature in 2016. But, importantly, key moderate Republicans relented.

Four other non-expansion states could join Virginia over the next year or two. They are Maine, Idaho, Utah, and Nebraska.Continue reading…

WTF Health | Self-Reported Patient Monitoring Startup from Finland, Kaiku Health

WTF Health – ‘What’s the Future’ Health? is a new interview series about the future of the health industry and how we love to hate WTF is wrong with it right now. Can’t get enough? Check out more interviews at www.wtf.health

Central to the ‘WTF Health’ ethos is the idea that around the world, there is a shared passion for creating a new future for healthcare — and that the less-positive ‘WTF moment’ is a shared experience, regardless of which country’s health system one is standing in.

So, I’m going around the world this year — to 17 different health innovation conferences in 11 different countries — to find out what innovators abroad are doing to tackle the problems in their health systems and what we can learn from one another.

Driving down the cost of care, managing chronic conditions, helping people achieve better health, improving care delivery and patient experience — these goals know no borders. What’s different is the framework around them. So, what if the payment model were different? What if there was a single electronic patient record? What if certain laws and regulations didn’t exist?

Different constraints breed different solutions. What a hopeful and inspiring idea. And, with any luck, food for your thoughts and innovative thinking.

So here is the first interview I’d like to share from abroad! Everyone meet Finnish startup Kaiku Health, fresh off closing a €4.4M Euro series A. Their patient monitoring monitoring platform lets cancer patients (and others with chronic diseases) self-report on how they’re doing, using their hospital’s existing patient portal. Stick around until the end: Bonus insight on the strengths of the health tech startup scene in the Nordics for those who want to go explore.

Filmed at Upgraded Life Festival in Helsinki, early June.  

Misdiagnosis: Obamacare Tried to Fix the Wrong Things and Prescribed the Wrong Treatments

David A. Hyman
Charles Silver

 

Today THCB is happy to publish a piece reflecting the learnings from Charles Silver and David Hyman’s forthcoming book Overcharged: Why Americans Pay Too Much For Health Care, shortly to be published by the libertarian leaning Cato Institute. In subsequent weeks we’ll feature commentary from the right radical libertarian zone on the political game board (Michael Cannon) and from the left (Andy Slavitt) about the book and its proposals. For now please give your views in the comments–Matthew Holt

There are many reasons why the United States is “the most expensive place in the world to get sick.” In Part 1 of Overcharged: Why Americans Pay Too Much For Health Care, we show that the main reason is that we pay for medical treatments the wrong way. Instead of having consumers purchase these treatments directly, we route trillions of dollars through third-parties payers – both government and private insurers.

Relying on third party payers has many consequences — few of them good. To start with, this arrangement removes the budgetary constraint that would otherwise cap the amount consumers are willing to spend. By minimizing the direct cost of treatments at the point of sale, third party payment arrangements alter everyone’s incentives fundamentally. Consumers no longer need worry about balancing marginal costs against marginal benefits; instead, they have an incentive to use all treatments that have any potential to help, regardless of their prices. When millions of consumers act on these incentives, total spending skyrockets and consumers collectively wind up worse off, because their fixed costs spiral upward too. Heavy reliance on third party payers creates a classic failure of collective action.

It isn’t just consumers. Providers love third party payment as well. And why not? Once providers have access to the enormous bank accounts of third party payers, the sky is the limit, at least until third party payers start setting limits on the amounts they will pay and saying no to unproven and/or cost-ineffective treatments that doctors want to provide and patients want to receive.

Not surprisingly, it has turned out to be extraordinarily difficult and politically unpopular for third party payers to set such limits. Obamacare’s appeal derives largely from two requirements: health insurance plans must accept all comers, including applicants with preexisting conditions that require expensive medical treatments; and health plans must provide unlimited benefits (i.e., no annual or lifetime spending caps). From an individual consumer’s perspective, what could be better than having access to unlimited amounts of money to spend on medical needs? From society’s point of view, though, this combination is a recipe for disaster.Continue reading…

WTF Health | Oscar’s Schlosser on Consumerizing Health Plans, post-ACA & pre-Amazon/JPM/BH

WTF Health – ‘What’s the Future’ Health? is a new interview series about the future of the health industry and how we love to hate WTF is wrong with it right now. Can’t get enough? Check out more interviews at www.wtf.health

Having formerly worked for a health plan, I geek out over health plan innovation as IMO it’s the underpinning of the true disruption of health care. When the incentives change, everything else will change too…

So when I met Mario Schlosser, co-founder & CEO of Oscar Health at Health Datapalooza, I may or may not have asked him to sign my Oscar insurance card. (Yep, I’m a member.)

Our chat focused his push to continue driving health plan innovation amid the deterioration of the ACA and his plans for Oscar’s latest $165M round. His goal: make the payer “an interface and enabler of new kinds of technologies.” Is that even possible?!

Around 4:15 minute mark we find out if he’s been tapped for advice from the Berkshire Hathaway/Amazon/JP Morgan health alliance as they take on their own challenges disrupting health insurance.

assetto corsa mods