On The Issues

March 13th, 2015

5 Significant Healthcare Public Policy Trends for 2015 & 2016

HHS, CMS & ONC increasing regulatory incentives and pressures

While we will see tweaks to important legislation and regulation, the major public policy impacts that I envision for 2015 and even 2016 will revolve around EHR meaningful use, interoperability and most importantly in my book and strategy, alternative payment and care delivery models. Yes, ICD-10 is in there too but literally for how many years can we talk about that? J


EHR Meaningful Use

EHR meaningful use will almost certainly grab the biggest headlines throughout the year as we just saw with the popular CMS announcement of the delay in the Medicare EHR meaningful use attestation for the 2014 reporting year whereas eligible professionals now have until March 20th, 2015.  

There is also a new EHR meaningful use rule expected this spring that is intended to be responsive to provider concerns about software implementation, information exchange readiness as well as be reflective of developments in the industry and progress toward program goals achieved since the program began in 2011.

Here are a few highlights:

  • Shorten the EHR reporting period in 2015 to 90 days to accommodate these changes
  • Realign hospital EHR reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other CMS quality programs
  • Modify other aspects of the program to match long-term goals, reduce complexity, and lessen providers’ reporting burdens 


Interoperability and Data Exchange

 The ONC Released its Shared Interoperability Roadmap on January 30


HHS’s Office of the National Coordinator for Health Information Technology (ONC) sees health IT as an important contributor to improving health outcomes, improving health care quality and lowering health care costs. They further state that health IT should facilitate the secure, efficient and effective sharing and use of electronic health information when and where it is needed.

Here are a few highlights: 

·         ONC suggests that the community must expand its focus beyond institutional care delivery and health care providers, to a broad view of person-centered health 

·         Healthcare is being transformed to deliver care and services in a person-centered manner and is increasingly provided through community and home-based services that are less costly and more convenient for individuals and caregivers 

·         The Roadmap Identifies Four Critical Near-Term Actions for Enabling Interoperability

o   Establish a coordinated governance framework and process for nationwide health IT interoperability

o   Improve technical standards and implementation guidance for sharing and using a common clinical data set

o   Enhance incentives for sharing electronic health information according to common technical standards, starting with a common clinical data set

o   Clarify privacy and security requirements that enable interoperability

A personal favorite inside the Roadmap is the call for alignment of private payer efforts with CMS policies and programs, including incentives for health information exchange and e-clinical quality measures that will enable the three- and six-year goals in the Roadmap. This is a key component that will garner a lot of broad stakeholder support including the critical support of caregivers and IT professionals who struggle to participate in quality and incentive programs due to their lack of coordination and ability to report on measures.


The ONC did create a terrific infographic that details this journey as well. Public comments on the ONC Interoperability Roadmap are open until April 3rd, 2015. 


Alternative Payment and Care Delivery Models

In addition, a newly proposed CMS Shared Savings Program Rule focuses on more ACO flexibility, greater performance-based risk and reward as well as the use of innovative care coordination & telehealth tools. While I am still holding out for passage of bipartisan, bicameral SGR/ FFS reform legislation there has been real progress out of HHS as they have proposed phasing in an alternative payment models that leverage outcomes & quality-based payments with a smaller fee-for-service reimbursement. Basically, paying providers for value, not volume. 

Through this January announcement: 

·         HHS has set a goal of tying 30% of traditional, or fee-for-service, Medicare payments to quality or value through alternative payment models, such as ACO, PCMH or bundled payment arrangements by the end of 2016, and tying 50% of payments to these models by the end of 2018 

·         HHS also set a goal of tying 85% of all traditional Medicare payments to quality or value by 2016 and 90% by 2018 through programs such as the Hospital Value Based Purchasing and the Hospital Readmissions Reduction Programs 

Note - In 2011, Medicare made almost no payments to providers through alternative payment models, but today such payments represent approximately 20% of Medicare payments. The goals announced in January represent a 50% increase by 2016. 

·         To put this in perspective, in 2014, Medicare fee-for-service payments were $362 billion so a significant amount of payments will be shifting quickly into alternative payment models and this trend will not be tied to just Medicare but rather all insurers including Medicaid will be briskly moving in this direction




HHS has adopted a framework that categorizes health care payment according to how providers receive payment to provide care: 

·         Category 1—fee-for-service with no link of payment to quality

·         Category 2—fee-for-service with a link of payment to quality

·         Category 3—alternative payment models built on fee-for-service architecture

·         Category 4—population-based payment 




While there certainly is a lot already to digest regarding key public policy trends for 2015 and beyond, I would be remiss if I did not highlight one of the new regulations near and dear to my heart…


Medicare telehealth expansion includes use of health IT for chronic care

Medicare has expanded its covered telehealth services to include wellness (HCPCS code G0438) as well as several behavioral health visits. Beginning in January 2015, Medicare will reimburse physicians $40-$42/patient/month for chronic care management services for patients with more than one chronic condition

  • Physicians must use EHR systems that meet 2011 or 2014 certification criteria for meaningful use and a scope of service
  • Chronic care management is expected be provided by clinical staff directed by a physician or other qualified health professional. The level of service is expected to be 20 minutes per patient per month


Oh, and let’s not forget about our decade-long transition to ICD-10 on October 1, 2015. 

So as you can see and are probably well aware, 2015 has already started off with seismic shifts in public policy in an attempt to stabilize the rate of growth of our annual healthcare costs. I don’t believe anyone can kid themselves and think that we will ever reduce our nation’s healthcare expenses but what many of us are passionately working towards is creating a smarter and sustainable healthcare system that will at least reduce the rate in which our costs are increasing and truly create a healthcare system where we see intrinsic value and the patient becomes an informed and accountable consumer. We can all dream can’t we? J