Given the opportunity to quickly prove its efficacy and customer appetite for connecting with care providers virtually, telehealth has more than proven the model works and works well. There is also consensus in the industry that the former regulatory and reimbursement barriers that were rapidly removed during COVID will not go back to the old normal. Evidence of this keeps emerging with CMS rulings and clarifications that signal this intent. The question for those in Senior and Long-Term Care who are now looking at their post-pandemic clinical, operational and business environment to make IT strategy decisions is: Where to go next in telehealth and virtual care?
By now, almost all providers have found a way to do virtual visits with the patients and residents they serve. A first step in evaluating your IT strategy for any purpose is to take a critical look at those solutions and workflows you are using with either a full or a targeted assessment. If done well, this assessment should provide you with the necessary insight to confidently map out your short and long term plans based on your current state and an inventory of your telehealth and virtual care capabilities.
This provides the opportunity to determine if you have the capabilities to meet the clinical, technical and operational objectives of your organization. You can examine if there are ways to optimize what you already have and be well positioned for the future.
For many organizations the near term objectives include improving access to care, decreasing the cost of providing care and maximizing reimbursement. Consider if your technology allows you to:
Meet the new and increased demands on your infrastructure. This includes internet, Wi-Fi, connectedness, and the ability to share the needed data through integrations and interoperability.
Optimize your processes and workflows. Consider the operations that can and should be automated. Explore any additional customization and training that would lead to better performance.
Enhance and improve the experience that patients, residents, families, staff and partner organizations have with your organization. Right now, the expectations are especially high and best practices for communication, feedback and recognition have significantly shifted to include having a strong digital presence. Many organizations have moved much of their interactions to a digital or even mobile first model and have rounded out their offerings with quality of life and hospitality elements like wellness programming and education, menus and meals, activities and content that adds value.
Maximize reimbursement for the clinical services you are providing and plan to provide. Changes to the way some clinical services can be billed could significantly increase the ROI for adding increased telehealth, RPM and CCM capabilities for appropriate use cases. Your IT strategy should help you maximize this revenue capture and enable the services that will be provided going forward.
Consider leveraging people with experience and expertise. Strategic Interests can help your organization with a Telehealth and Virtual Care assessment and strategy. Please contact Michalene Kinsler at mkinsler@strategicinterests.com to schedule an introductory call.
Let us help you put the right technology in place so your organization can focus on delivering care to the people you serve.
Strategic Interests’ Al Kinel and Brett Kinsler authored an article in Western New York Physician magazine discussing the ins and outs of remote cardiac rehab. See the reader below (skip to page 23) to read the article.
Continual Care Solutions and Strategic Interests announce a partnership to bring Digital Transformation to Human and Social Services Organizations
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imPowr, a software platform thoughtfully designed for human and social services organizations, and Strategic Interests, a healthcare IT consulting firm with a proven record of leading change, are announcing a partnership to bring Digital Transformation to human and social services organizations. This will help improve sustainability and resilience in 2021 and beyond.
Leveraging the comprehensive imPowr platform with Strategic Interests’ experience and expertise in successful digital planning, implementation and optimization, the partnership allows community based organizations and others to quickly adopt best practices, gain insights and make better decisions.
Often, the purchase of a software platform is only part of the complete solution needed for organizations to gain the full value of this effort. In order to be able to capture, manage and optimize data to drive better performance and increase revenue opportunities, an organization needs a digital strategy, an implementation plan, well-designed reports and dashboards and support to make it all “stick”. This deliberate approach helps organizations avoid costly mistakes, reduces delays and provides a sound basis for participation in valuable contracts and collaborations.
“We are excited to be collaborating with Strategic Interests since their innovative thinking and understanding of customer needs will complement the mission behind our imPowr platform. They are trusted leaders in the industry and together we will be able to serve more human services organizations with excellence.”
– Sean Ossont, President, Continual Care Solutions.
“The partnership between SI and imPowr will bring customers a highly coordinated process to plan, deploy, and apply best in class solutions to improve their performance based on their unique needs, objectives, and an understanding of how the organization functions.”
– Al Kinel, President, Strategic Interests.
This partnership brings not only a best in class platform but the strategy and support to quickly realize meaningful and measurable benefits.
About imPowr
imPowr by Continual Care Solutions is a comprehensive software solution designed specifically for non-profit human services organizations, bringing together data into a single integrated database. The imPowr solution provides organizations with financial growth, improved efficiencies, and risk mitigation so that they can focus on advancing their mission and serving the community with excellence.
Strategic Interests, (SI), is a Global HIT consulting firm with a personal touch.Our trusted transformation consultants focus on our clients’ best strategic interests and success. Vision, innovative thinking and collaborative relationships drive the SI philosophy. SI consultants have expertise, capabilities and deep networks that can be deployed in flexible, blended teams to help reduce costs and target client needs.
Leaders from Point of Care Partners and Strategic Interests founder Al Kinel will join forces to discuss the relationship between healthcare payers and health information exchanges. What’s working, what could be better?
Join your friends from Strategic Interests, Excel Partners and TechRochester at the R2I (Rochester to Israel) Virtual Exchange where you will learn about exciting healthcare technology from Israeli startup companies.
November 18th, 2020 11:00am – 1:00pm EST No cost to register
By Brett Kinsler, Strategic Interests, Partner, Clinical Services & Informatics
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By Ken Kleinberg, Point-of-Care Partners, Practice Lead, Innovative Technologies
In our previous post, we discussed the importance and some of the challenges of a consent management program. Now, let’s look at some other areas that require examination and decisions in the consent management process:
Major Consent Considerations
Here are some of the most important issues that organizations need to consider for robust implementation in support of meaningful patient consent management:
Authorization Models: range from opt-in or opt-out (may be at the organization or the state level, and may have huge implications for adoption/success with opt-out being the preferred approach), and hybrids that require opt-in for sensitive information, such as HIV or controlled substances or other specific PHI (personal health information) or demographics related to age or guardianship.
Initiating Party: consent initiation may be performed by the provider, the patient, or either, in addition to a parent/guardian or healthcare proxy (how this consent is verified and passed from stakeholder to stakeholder is a key challenge in consent management).
Initiation Domain: may be at the point of care, online, or a mixture of options. COVID-19 has led to waiver programs that temporarily change these policies. Such changes may become permanent. Areas subject to natural disasters (e.g., hurricanes, tornados, flooding, wildfires) may want to specifically plan for such occurrences.
Data Sharing: basic choice to share all data or can be more granular to select certain types of data by sensitivity level (a key challenge here is that omission of data, such as a diagnosis for mental illness, may still be discerned if other information that is shared, such a medication used to treat mental illness, is included for medication reconciliation safety purposes).
Provider Data Access: may be granted to a particular provider, organization, or multiple providers (community consent) based on the model deployed. Some models permit emergency access or may blanket restrict all access regardless of an emergency event occurrence. Use of audit trails can be key here to track unwarranted access.
Patient Data Access: models may provide ability to access and/or suggest changes – this access can be more complex based on age (restrictions for teenagers, for example, which can differ by state or organization), family member access (divorced/separated, step-parent), etc. As there can by high complexity here and no easy answers, this can be a major impediment to more sophisticated consent implementation.
Alteration and Revocation: patient changes to consent may be retrospective, prospective, or contain options of either. For example, revoking consent may or may not remove access to some or all historic data. Changes to consent may be entered by the patient, provider, or either and may occur at the local or statewide level – timing may also be an issue (e.g., batch vs. real-time).
Alignment with Federal Policies: HIPAA, TEFCA, Part II regulations, etc., does not necessarily reconcile fundamental policy differences across regions or states.
Data Types: Can include both HIPAA-covered and non-HIPAA-covered data such as advance directives, MOLST (Medical Orders for Life-Sustaining Treatment) data, genetic information, patient generated health data from wearables and home devices, AI/ML generated data, etc.
Additional Technical and Organization Considerations
Among the technical issues of implementing consent management are:
Integration Technologies – leveraging FHIR APIs when feasible and including approaches to integrate with other consent requirements, EHRs, advanced directives, etc.
Authentication and Tracking – Identity management, OAuth/UMA, audit capabilities
Promulgating Consent to Other Entities– Differences in terminology and lack of adequate mapping may contribute to lowest common denominator filtering where granularity of consent is lost
Workflow – including the ability to support authorized queries, and allow patients the ability to view and manage consent preferences online
Organizational considerations include:
Consent Strategy – who in the organization decides what approach the organization should take to consent management – should it be based on what others have done (e.g., identification of best practices) – how should it mesh with state or federal policy – could the organization’s consent approach be a competitive differentiator?
Governance – who has the authority to change, interpret or enforce policies
Changing Landscapes – Keeping up with potential legislative changes, such as concerning the management of sensitive substance use, mental health, and HIV data as well as overall consent models.
Advocacy – what approaches and levers do organizations have to influence policy
Outreach approaches – including provider and patient communication, education, training and activation/engagement.
Conclusion
Effective and meaningful consent that supports information sharing and action requires a balance between a patient’s willingness to provide access to their private information, the need for providers and other stakeholders to access patient data to impact clinical outcomes, population health, the patient experience, and the patient’s willingness and ability to play a larger role in their own health and health information. Better use of technology and processes for consent can enhance the effectiveness and efficiency for stakeholders across regions, states, and the nation. Leveraging the expertise of a team who understands stakeholder alignment, consent management strategy, and is skilled in development and deployment will ensure the success of your organization’s consent program.
By Brett Kinsler, Strategic Interests, Partner, Clinical Services & Informatics
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By Ken Kleinberg, Point-of-Care Partners, Practice Lead, Innovative Technologies
Sign here. On the surface, patient consent is such a simple principle. Patients communicate their desire to share their health information or accept (or deny) a treatment. The most common broad consent is often the only option given to patients, and generally includes the concept of informed consent, emphasizing the patient’s role in the decision-making process and a section to address common patient questions. More granular approaches to consent offer a myriad of options that may specifically assess patient desires and choices to protect privacy and security.
All (Regulated) Stakeholders Take Note
Stakeholders that need to manage consent effectively include health systems, providers, EHR (Enterprise Health Record) vendors, health information exchanges (HIEs), health information networks (HINS), labs, pharmacies, and payers/health plans. Organizations do not necessarily have to have direct patient interaction to be concerned with consent, as is the case with many HIEs that are not patient facing. Patient portals and the newer world of consumer apps are clearly access vehicles where consent may come also into play. The recently finalized rules from CMS and ONC have a lot to say about information exchange and patient access – and while they have yet to be tested, they clearly put a greater responsibility on the patient for managing consent in the permissions they agree to. In many cases, these decisions have implications outside the protections of HIPAA (consumer beware).
The Office of the National Coordinator for health IT (ONC) feels patients need to understand their role and options so that they make meaningful and informed consent decisions – they refer to this as meaningful consent. If patients fail to participate in the process, they risk having too much or too little information shared, leading to potentially dire consequences to their health and private lives. But even once consent is granted, accounting for the responsibility organizations undertake in caring for patients (and their data), leaves much to consider and balance.
Pitfalls of Getting it Wrong
Organizations implementing an effective consent process, including appropriate sharing among multiple stakeholders and regions, face an incredibly complex task. Those who do not have the needed policy/regulatory knowledge, systems, technology, processes, and workflow to properly enable meaningful patient consent may suffer serious repercussions including lawsuits, fines, loss of accreditation, reduction in public trust, or worse. They may also experience loss of revenue, patients, value-based care payments and other incentives.
Poor consent management by industry players may influence the establishment of even greater future barriers and regulations to the exchange of information that truly needs to be shared. We will face the implications of our failure to act responsibly and strategically. Patient advocacy and privacy groups already have a great deal of ammunition regarding lack of patient protections either through mistakes or more purposeful intent, such as sharing information for commercial gain or other purposes beyond what is legal or ethical.
Consent at the State Level
Variations in regulation, approach and methodology to consent within and across states pose challenges to the interoperable exchange of health information. This influences the approaches taken by HIEs that operate in those states or a region that spans states (in addition, cross-state HIE partnerships are not uncommon). Some areas use an opt-in model, requiring patients to consent to the sharing of their data. These systems provide much less information than areas with an opt-out model, whereby default participation and sharing is assumed unless specifically revoked. Certain approaches have been shown to actually increase barriers to health information exchange, placing a greater administrative burden on less technologically advanced organizations. Some providers within and across states may find themselves having to interact with multiple entities to share and access clinical information and, thus, require multiple complex interfaces and workflows to serve their geography well.
Several states have taken a statewide approach to consent, which, while challenging to implement and maintain, provides marked benefits to patients and users. To successfully define and deploy statewide consent capability, a state needs to evaluate and incorporate stakeholder requirements, design solutions (which may include a consent registry) and create an approach to address these requirements that meets the needs of everyone. To ensure successful deployment and sustainability, states need to embrace a funding and program management approach that allows stakeholders to migrate from their current approaches, and solve workflow issues related to the collection and management of consent. This is a complex undertaking that benefits from outside experts to manage the alignment of stakeholders and develop effective and efficient approaches.
In our next post, we will look more closely at the most important issues for stakeholders to consider, especially regional and state HIEs, regarding the implementation of consent including organizational and technical considerations.
First published in New York Medical Group Management Association New York Beat e-newsletter August 2020
In a recent webinar, a colleague showed a slide with a multiple choice question: Who led the digital transformation of your company? A. CEO B. CTO C. COVID-19 Of course, choice C was circled in red. From schools to retail, the coronavirus pandemic has forced us to change how we perform everyday tasks we hardly paid a thought to last autumn. Necessity may be the mother of invention, but COVID is triple espresso she is drinking to fuel her innovation.
Medical practices have been, for quite some time, flirting with the idea of telehealth and more recently with remote patient monitoring. Largely left to large or hospital-owned practices, the idea of treating patients virtually has been seen as more of a Jetsons age novelty than an indispensable resource. But the pandemic has forced many to think differently and act in ways that best serve patients and support the sustainability of the practice. Healthcare has been pushed to elevate the use of technology in order to stay safe, effective, relevant, and viable.
Chances are your practice is now doing some form of telehealth and you were not doing much prior to COVID. It’s likely the implementation of this technology was a disruption for which you weren’t fully prepared. This begs a few questions: What else is on the horizon in healthcare innovation that we may not be expecting? Are there better ways to do what we quickly implemented? Do we need to modify our workflows? Can we better impact outcomes, satisfaction, revenues, or profits by enhancing what we’ve done?
Let’s examine a few of the upcoming transformations you can prepare for to ensure the next major disruption is more of a tremor than a quake to your everyday operations:
Telehealth Expansion
The vast majority of healthcare practitioners who have only recently moved into the telehealth space have no intention of reverting. As insurance reimbursement scales to meet the demand, the benefits of using remote communication to treat patients will continue to grow. Wider adoption, increased usage among vulnerable populations, and higher acuity use cases will continue to be evident. Telehealth will be increasingly used to care for patients who are traveling or snowbirds as well as provide more consistent tracking of patients with chronic or complex conditions. The impact of avoiding unnecessary hospital and ED visits will further increase its cost-effectiveness. Patients have come to trust telehealth as a viable alternative and will come to expect the option when making healthcare decisions. Being prepared for this will position your practice as one that is patient centered, and as an employer who can provide flexibility for clinicians who are unable or unwilling to attend in-person visits. Look at the telehealth program you may have implemented as a result of COVID. Are there ways to strengthen the system to shift into a more permanent and integrated one?
Advances in Wearables and Remote Patient Monitoring
Once only sported by early adopters and elite athletes, the age of Apple Watches and Fitbits is now is full swing. The technology is improving, easier to clinically incorporate and capture into EHRs in a meaningful and actionable way. Advantages of getting accurate readings for, say, blood pressure or blood glucose between clinical encounters provides more frequent touchpoints, faster feedback about interventions, and earlier warning for trends and impending events. This new stream of data can help increase revenues, enhance patient outcomes, reduce operations costs, and enhance patient experiences. Technology improvements in cardiac monitoring and other metrics are advancing rapidly and this evolution means you will not be bombarded with a flood of data but only values that will help in making decisions. If you’re not currently thinking about how to incorporate wearable data into your daily workflow, you should be.
Enhancing the Patient Experience with Digital Health Apps
In addition to adopting telehealth and remote monitoring to engage patients between encounters, innovative practices are also adopting a myriad of other tools and capabilities to enhance the patient experience. Enabling patients to find a doctor, schedule an appointment, message their provider, pay their bill, get directions, rate their experience, report how they feel, confirm compliance, get educational content, and access their clinical record from their smartphone can significantly enhance their perception of providers. While many of these functions can be addressed individually, providers will find more patient satisfaction and retention if they deploy comprehensive, integrated apps that provide a single point of access for all of these functions.
Virtual Reality
Senior living facilities have been using VR in the treatment of memory care. Experiences from the past can feel fully immersive and trigger memories, conversations and new mental connections. VR is increasingly being used by surgeons to visualize complex surgery and improve interventions by superimposing virtual images over the actual patient. We are only beginning to scratch the surface of what is possible in this arena. Stay tuned for the near future of VR applications that will be useful in your everyday workflow.
Advances in technology are but one piece of the puzzle you need to stay ahead of an ever-evolving healthcare landscape. To survive and thrive, it is necessary to stay flexible and informed. Don’t wait for the next pandemic to embrace the inevitable, assess your situation and create a roadmap for your future. In the end, we all want to provide the highest quality care for our patients and adopting useful and meaningful technology can help to do exactly that.
Telehealth and Virtual Care continues to be a focus of delivering safe, effective care during COVID and a cornerstone of addressing issues of access for rural and underserved populations.
As part of the CARES Act, $200 million was designated for telehealth programs and was quickly awarded to both large and small providers in an effort to rapidly increase the availability of virtual visits, remote monitoring and other types of connected care.
Continuing with that focus, the FCC will make funding available through the Universal Service Fund (USF) as the Connected Care Pilot Program (Pilot Program) to help defray the costs of providing connected care services. The emphasis on supporting these services will be for low-income Americans and Veterans. The Pilot Program will make available up to $100 million available over a three-year funding period and will be separate from the budgets of the existing Universal Service Fund (USF) programs.
For those projects that are selected, the Pilot Program will cover 85% of the eligible costs of
(1) patient broadband internet access services (2) health care provider broadband data connections (3) other connected care information services, and (4) certain network equipment (e.g., equipment necessary to make a supported broadband service function such as routers)
Unlike the FCC Covid Telehealth Program, this will not fund end-user devices or medical equipment and will require a competitive bidding process. The intention is to address a wide variety of health challenges such as diabetes management, opioid dependency, high-risk pregnancies, pediatric heart disease, mental health conditions, and cancer. Information on eligibility and guidelines is available and the timeline is expected to be released soon. Organizations can submit an eligibility determination ahead of the full announcement – see links at end of this post.
Also in the interest of expanding coverage to rural areas, the Department of Health and Human Services (HHS) released a report on existing and upcoming efforts to improve rural healthcare. This report, the Rural Action Plan, is the first HHS-wide assessment of rural healthcare efforts in more than 18 years and the product of HHS’s Rural Task Force, a group of experts and leaders across the department first put together by Secretary Alex Azar in 2019.
This action plan provides a roadmap for HHS to strengthen departmental coordination to better serve the millions of Americans who live in rural communities across the United States. Eighteen HHS agencies and offices took part in developing the plan, which includes 71 new or expanded activities for FY 2020 and beyond. Efforts that will be undertaken in FY 2020 include nine new rural-focused administrative or regulatory actions, three new rural-focused technical assistance efforts, 14 new rural research efforts, and five new rural program efforts. These efforts build on 94 new rural-focused projects the HHS Rural Task Force identified as having launched over the past three years.
This report outlines the key challenges facing rural communities related to issues such as emerging health disparities, chronic disease burden, high rates of maternal mortality and limited access to mental health services. The plan lays out a four-point strategy to transform rural health and human services, with a number of actions that can be launched within weeks or months. The four points of the strategy are:
Building a sustainable health and human services model for rural communities
Leveraging technology and innovation
Focusing on preventing disease and mortality
Increasing rural access to care
More funding through programs like these and improved coordination across agencies and providers could provide the foundation for truly addressing how to deliver care when and where it is needed – especially for those most in need.
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