This is not my standard “news and advice” product as too much is happening at alarming speeds.

While I see many challenges and opportunities I also see a lot of misinformation and uncertainty.  Granted, I don’t have all the answers, yet I’m in a position where I can see more markets and experiences than the traditional healthcare professional.  I’m also exposed in both my personal and professional life to the healthcare business environment so whether I like it or not I cannot escape it.  So let me briefly tell you of my experiences of last week alone.

1.      Meaningful Use.  There is a drop of 21% of family physicians who attested to meaningful use in 2011 which failed to do so in 2012.  No one knows for sure why but there are some suspicions about the following possibilities:

a.       Change in reporting period, which was only 90 days for the first year of participation, but a full 365 days for the second year.

b.      Missing the two-month attestation window from Jan. 1 through Feb. 28, 2013.

c.       Reduced support from the regional extension centers.

d.      Lack of ongoing monitoring.

e.       Extra burden/overhead of meeting meaningful use in their offices.

http://www.aafp.org/news-now/practice-professional-issues/20130703mudropoutrate.html

2.      HIPAA Privacy and Security.  On a daily basis I receive informaiton about the latest settlement and fines.  Today I read about the U.S. Department of Health and Human Services (HHS) and the penalties they imposed to WellPoint.  The actual penalty was $1.7 million for potentially violating the Health Insurance Portability and Accountability Act of 1996 (HIPAA) privacy and security rules.

The findings may be slightly different but in most of the cases I read a common trend regarding the organization’s failure to: “adequately implement policies and procedures …….”.    

“HHS expects organizations to have in place reasonable and appropriate technical, administrative and physical safeguards to protect the confidentiality, integrity and availability of electronic protected health information–especially information that is accessible over the Internet,” the agency said in a statement.

http://www.hhs.gov/news/press/2013pres/07/20130711b.html

3.      Accountable Care Organizations (ACOs).  Today July 15, 2013 is an important day as this date marks the deadline for Pioneer ACOs to pull out.  Last week there were rumors that as many as 9 of the 32 ACOs may opt out.

The running of a successful ACO is challenging by itself and CMS quality and pay for performance measures don’t make them any easier. 

http://www.medscape.com/viewarticle/761870_5

http://www.modernhealthcare.com/article/20130712/NEWS/307129966/reform-update-pioneer-acos-face-july-15-decision-deadline?

 I also had the chance to talk with someone else in private about their organization’s performance and the effect of sequestration (2% reduction on Medicare fees).  In this case the organization is big enough to control and meet CMS quality measures, yet the 2% reduction was significant enough to result in a staff reduction and streamline in order to remain in the black.  And in case you had any doubts this reduction did include physicians.

Beginning Sept. 23, 2013, HIPAA Omnibus rule enforcement rules will come into effect.  The Omnibus rule establishes liability for many of HIPAA’s requirements and extends the same directly to business associates that receive or store protected health information, such as contractors and subcontractors.  However I have not seen too many healthcare professionals and business associates trying to meet the requirements of the Omnibus Rule.

My own experience is that last week alone, and considering only HIPAA Security, I had to create three new forms and five policies.  Luckily for some of my clients that are using my Compliance Software they won’t have to worry about anything as they are covered by my efforts and we will be telling them when to use the forms.  I also had the chance to work on some new production lines and marketing for some of them so we spread out the risk and the income potential among different markets and services/products.

So my advice to you is the following:

1.  Stay tuned.  Pay attention to what is going on in the USA and your particular market.  Understand the rules and your implementation requirements.  Remember that if you are going to play and win you must know the rules.
2. Be proactive.  Don’t wait until is too late to act.  For example, there are changes regarding payment that are coming.  These changes will reduce your cash flow so it will be wise to ensure you have access to liquid funds so talk to your bank to look into the possibilities.
3. Know your numbers.  You need to know your overhead, costs per service, patient demographics, Payor sources, etc.  Consider the return on investment (ROI) of all your actions and keep and eye on your overhead and payment per service/product.
4. Seek advice before taking actions.  There are too many rules and too many deadlines.  I personally have a team that among all of us we share information and analyze the situation.  I even have a social network and marketing consultant that assists me with decisions and promotions.  And of course, I couldn’t ask for a better team to help me with the Compliance Software.  So what about you?

 At the end of the day remember that the Taino Consultants Inc. team is here to help.