ocus Area Roundtable on Next-Generation Value-Based Payment Programs

Value-Based Payment Programs – Highlights from Recent Roundtable

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Like other systemic changes needed to ‘fix healthcare’ in the United States that have been proposed, discussed, and tried in various forms and fashions over the last 20 years, the widespread, meaningful adoption of value-based payment programs seems to always be just a few years away. And now, the coronavirus pandemic has forced all healthcare stakeholders to re-think what is needed to truly transform the healthcare delivery system in the United States. In our first Focus Area Roundtable on Next-Generation Value-Based Payment Programs, participants discussed obstacles to value-based payment programs, selecting and measuring quality measures and outcomes, and topics related to engaging stakeholders – particularly payers and providers – collaboratively and in a proactive vs. reactive manner.

HCEG’s Executive Director Ferris Taylor and Eileen Lee, VP of Product – Connected Solutions, at Zelis Healthcare, helped facilitate discussion among roundtable participants: leaders from health plans, health systems, care provider organizations, and two consultants serving the healthcare industry. This post presents highlights of the roundtable. Individuals involved with transforming their provider reimbursement and payment systems are welcome to join our Focus Area Roundtables including the 2nd roundtable on Next-Generation Value-Based Payment Programs.

Next-Generation Value-Based Payment Programs. Quality measures and outcomes. preventative health. Smaller, regional, commercial health plans. Fee-for-service payments (FFS). FHIR. EHR. CDS Hooks.Obstacles to Wider Adoption of Value-Based Payment Programs

Ferris kicked off the roundtable by asking participants to share their thoughts on what obstacles are hampering the increased adoption of value-based care and payment programs.

Eileen Lee shared her perspective that many smaller, regional, commercial health plans simply don’t have the infrastructure or the resources to change the framework for how they process payments. She noted that with current infrastructures built around making fee-for-service payments (FFS) and high costs associated with implementing and administrating both FFS and value-based payment programs, the opportunity for these types of organizations to evolve is simply not available to them.

Expanding Provider Networks and Accessing Data in EHR’s

Obstacles to Value-Based Payment

A chief technology officer of a health plan stated that their commercial plans still operate predominantly in a fee-for-service model and that they face two challenges in expanding their value-based payment footprint: developing their value-based provider networks and getting hospitals to participate and being able to connect into provider EHR systems to be able to send messages back and forth to support inpatient wellness and preventative health activities.

Eileen questioned whether engaging providers to participate in value-based programs was related to providers being unwilling to accept risk or whether they didn’t want the additional burden associated with collecting and reporting data.

One participant working with the front-line of care delivery shared that a big challenge for the front-line – from a value-based program’s perspective – is that collecting program metrics is ‘just another thing to do.’ She noted that if new data collection requirements can be better integrated into daily activities and workflow, value-based programs would be better accepted – particularly by physicians.

RELATED: Will Administrative Cost of Independent Dispute Resolution Force Providers to Join Networks?

Dealing with Different Requirements from Multiple Payers

In response to this comment on fitting into clinician workflow, Eileen reminded the roundtable that each payer has its own requirements and processes that clinicians must adhere to. The roundtable acknowledged the importance of recognizing and addressing payer-specific requirements, using standards and common definitions to the greatest extent possible, and selecting easily adaptable processes across multiple payers.

Capturing Meaningful Metrics as Part of Doing Business as Usual

One participant shared that, from his perspective, some Accountable Care Organization’s (ACO) are so concentrated on maximizing revenue by focusing on meeting quality measures and reporting end of year metrics, that innovations in care are not really welcomed. He noted that many metrics used for value-based programs should be captured and reported as a normal course of providing patient services – not just because they are required to receive specific payment program incentives.

The ability to incorporate data like laboratory values, medication lists, patient surveys, and other data that does not rely on inputs from clinicians or payers to support new payment models is one consideration noted in roundtable discussion.

Total Cost of Care Essential to Execute Value-Based Payment Programs

One participant associated with providing post-acute care in the home noted that the ability to accurately measure the total cost of care is key to being able to execute its value-based payment programs. She claimed that they don’t have access to all the data needed to be able to calculate the total cost of care.

Eileen asked if she thought that some of the transparency and coverage rule mandates will make calculating the total cost of care easier. The participant noted that they may if they were able to get eligibility data feeds to understand benefit coverage but obtaining that data is still up to the health plans to decide whether or not to share that data.

Measuring Quality, Outcomes, and Cost for Value-Based Payment Programs

Ferris asked the roundtable to share their thoughts on measuring quality, outcomes, and cost for value-based payment programs.Next-Generation Value-Based Payment Programs. Quality measures. Cost of Care. Outcomes.

One participant noted their plan’s success with a value-based contract on heart failure using pharmaceuticals. He explained that what makes that agreement work is that it can be measured. They know when people take their medication whether it works for them or does not work for them based on claims data and information easily reported by the physician. And they have a very measurable outcome. He went on to say that costs savings can be measured using claims data.

Another participant, a manager of clinical integration at a regional, integrated healthcare provider/payer system, asked participants if it was possible for value-based care program outcomes to be measured with claims volume alone. And could a program be deemed ‘better’ due to the ability to measure its outcomes based on claims data alone without other patient artifacts in order to determine the quality of outcomes?

A health plan CIO stated that claims data alone is not enough in almost all cases and that clinical data is needed as well. Another person added that benchmarks are also needed to know how you’re performing relative to some baseline.

How the Pandemic has Impacted Value-Based Payment Programs

Eileen from Zelis questioned the group on how the pandemic has impacted value-based care. She noted that at the beginning of the pandemic, providers that were participating in value-based care and payment plans had a little bit less of an impact from the drop in service volumes. But now that patients have spent a year delaying care, Eileen wonders if providers are or will be seeing more negative outcomes even while they (physicians) are still providing the same historical level of care.

Providers Anticipating Increased Risk Due to Pandemic-Induced Delays to Care

Eileen went on to share observations on two trends emerging since the pandemic started in Q1 of 2020. She stated that there has been an increase in interest among providers in value-based care and value-based payments as a way to ward off the negative impacts of fee-for-service when patients stopped coming; noting providers see value-based payment programs as a leveling – a way to help manage their risk and keep their cash flow moving.

She added that she expects data to reveal the same trend about preventive care and about the severity of illness coming into ER’s that others are seeing. And wonders what that may mean for long-term outcomes and the measurement of those outcomes for purposes of value-based care payment. Eileen noted that it may be more difficult for physicians to get incentive payments and show high-quality metrics if their patients simply don’t participate in the care gap closing activities that they need to participate in order for there to be quality care outcomes. Listen here for pandemic’s impact on adoption of value-based payment programs [00:38:34 – 00:40:01]

Managing Patient Migration Outside the Network – Incentivizing Collaboration

One participant shared that supporting the ability of their network physicians to collaborate and communicate with other network physicians – and incentivizing them to do so – has had a large positive effect on both total cost of care point and outcomes relative to patient’s risk profile and chronic conditions: fewer ED visits and readmissions to inpatient care.

In line with comments made by Eileen Lee about the decrease in preventative services since the pandemic began, this participant noted that managing this so-called ‘migration outside the network’ has been hampered by the decrease in preventive care services utilized by many plan members and patients since the start of the pandemic in Q1 of 2020.

Other Considerations on Capturing Metrics and Improving Outcomes under Value-based Payment Programs

Participants shared insights and observations on other ways to capture metrics and improve outcomes under value-based payment programs – particularly as more and more services are moving from traditional acute care settings to community and home-based settings:

Delivering Care in the Home and Use of Remote Monitoring Technologies

One person noted seeing opportunities created for digital startups, especially remote patient monitoring startups where organizations can outsource some of the patient monitoring part and then receive great insights from these new companies only when it is needed. Listen here for more on new opportunities for supporting value-based payment programs [00:31:25 – 00:32:56]Delivering Care in the Home and Use of Remote Monitoring Technologies Challenge in Accessing and Capturing Outcomes Data in the Home – Alleviated by OASIS Data

Challenge in Accessing and Capturing Outcomes Data in the Home – Alleviated by OASIS Data?

Building on the idea of diagnosing, monitoring, and providing care in the home, Ferris asked one participant, a provider of post-acute services in the home, how they are capturing measures and outcomes data in the home care environment and whether that data is captured in an EHR.

The participant shared that, ideally, the delivery of home-based services would be integrated with EHRs but to do that they must obtain provider by provider approval to get access to providers’ EMR’s. She shared that another way they are looking at getting data is to try to get access to the Outcome and Assessment Information Set (OASIS) data because that is standard across all home health providers. She noted that using the OASIS data requires a technology solution to receive the data, integrate it into their technical architecture, and be able to manipulate and trend the data.

Impact of FHIR-Based Use Cases on Value-Based Payment Programs

Next-Generation Value-Based Payment Programs. Quality measures. Cost of Care. Outcomes. Technologies. FHIR. CDS Hooks. MessagingOne participant asked whether use cases based on the FHIR – the foundational standard to support data exchange via secure application programming interfaces (API) – would have a positive impact on value-based care programs. The CTO mentioned previously noted that integration of Smart on FHIR-based apps running on a provider’s EHR would be a positive step toward obtaining data needed for value-based payment programs.

He also mentioned the use of new standard messaging and data exchange tools between payers and providers that utilize ‘CDS Hooks.’  Unfortunately, while the standards exist, leveraging them is still a one-on-one approach necessitating working with a FHIR vendor and integrating the back-and-forth integration.

While Ferris noted CMS’s Interoperability and Patient Access Final Rule now in effect as an example of a positive data exchange development between healthcare stakeholders, Eileen clarified that 67% of Americans are covered by self-funded or TPA plans that are not subject to the rule.

RELATED: Balancing Amount of Data Shared with Providers – Increasing Impact of Value-based Arrangements

Closing Thoughts on Next-Generation Value-Based Payment Programs

Ferris asked Eileen Lee of Zelis to wrap up the roundtable by offering a closing comment. Eileen shared that the adoption of value-based payment programs is one of those scenarios where the problem is easy to see and the solution seems even easier to decide but implementing it is complicated due to the diverse and diffuse environment of healthcare in the United States.

Listen here to Eileen Lee comment on the movement to Next-Generation Value-based Payment Programs [00:44:40 – 00:45:40]

Share Insight & Opinion on Value-Based Payment Programs and Join Our Next Roundtable

To assess payment-related challenges payers and providers are experiencing, identify gaps in the current payer-provider payment system, and help determine what’s holding back the adoption of new payer-provider payment solutions, the HealthCare Executive Group has created a mini-survey on Payer-Provider Payment Solutions. Healthcare stakeholders are urged to complete this three-minute survey. All survey respondents can receive survey results and be entered into a drawing for one of four $25 Amazon gift cards.HCEG Focus Area Roundtable. HealthCare Executive Group. Next-Generation Value-Based Payment Programs. Zelis Healthcare. Quality measures and outcomes.

Join our next roundtable on Next-Generation Value-Based Payment Programs on Tuesday, October 26, 2021, at 2:00 PM ET where additional insight, real-world experiences, and the latest developments on value-based payment programs will be discussed.

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Payment Integrity’s Role in Building a Fair & Equitable, Structurally Sound Payment System

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Each year over the last decade, ‘Healthcare Payment’ and ‘Data & Analytics’ have been on the HCEG Top 10 list of challenges, issues, and opportunities facing healthcare leaders; whether payment reform, big data and advanced analytics, payment integrity, or as in the case of the most current 2021 HCEG Top 10+ list: ‘Data & Analytics with respect to Costs.’ And now, the pandemic’s impact on healthcare provider revenue, the increasing financial responsibility of individuals for high and widely priced healthcare services, and multiple price transparency regulations such as the No Surprises Act and Transparency in Coverage are forcing stakeholders across the industry to address fundamental structural issues surrounding healthcare payments and provider reimbursement.

On Thursday, September 9th, the first in a series of Focus Area Roundtables on Payment Integrity and ‘Data & Analytics with respect to Costs’ took place with HCEG’s executive director Ferris Taylor joined by Kurt Fullmer and Andrew Cone, two healthcare industry leaders with MultiPlan – HCEG’s Focus Area Partner for ‘Data & Analytics with respect to Costs’. Seventeen other leaders from health plans, health systems, provider organizations including IPA’s, and industry consultants joined the roundtable discussion focused on the following topics:

1-How providers and payors – and plan members and patients – can find common ground in terms of payment and reimbursement
2-The ways the No Surprises Act may change the future of provider networks and reimbursement
3-How payment integrity must evolve to be considered by providers as fair and equitable

RELATED: Trends that are re-shaping payment integrity strategies

Finding Common Ground Among Payers, Providers, Plan Members, & Patients

Ferris kicked off the roundtable by asking how healthcare stakeholders could find common ground in terms of reimbursement. MultiPlan’s Andrew Cone noted the importance of keeping in mind the wide degree of variance that exists in the healthcare market across product types such as Medicare, Medicaid, Commercial, Group, Individual, etc. There’s a clear benefit to payers and providers to adopt consistent patient attribution approaches, quality measurement, and risk adjustment practices across all product types.

He also called out the way in which healthcare services are priced relative to other major products like buying an automobile and acknowledged that some controversial issues, gamesmanship, and outright bad behavior by some stakeholders have driven regulations like the No Surprises Act and that the next few years will be “very interesting” in terms of establishing common ground between healthcare’s stakeholders.

Listen here to Andrew Cone share context for establishing common ground among stakeholders. [11:32 – 13:31]Finding Common Ground Among Payers, Providers, Plan Members, & Patients

Value-based Care Programs Support Common Ground

One participant, a leader of a physician organization, shared her perspective that reducing or eliminating ongoing and often arbitrary changes to provider payments by payers and moving to more fixed, regular payments found in value-based payment programs would go a long way toward establishing common ground among healthcare stakeholders and reduce or eliminate the gamesmanship sometimes played.

It was noted the larger impact and ongoing challenge related to regional differences in care patterns and related reimbursement rates. And the challenges associated with defining levels of care at expected levels and consistently delivering those care at agreed-upon levels.

Listen here for additional impacts on establishing common ground. [19:25- 20:11]

New and Increasing Administrative Burdens Impact Costs and Payment Integrity

One participant shared their experience with increased costs associated with providing preventative care to patient populations vs. reactive care to a subset of a patient population. Others in the roundtable noted increased – and new costs – associated with identifying individuals in need of preventative services, capturing and reporting value-based measures, and identifying and accessing correct plan and community-based resources on behalf of their patients.

RELATED: Surprise Billing and the Impact for Payors

The Right Information at the Right TimeThe Right Information at the Right Time

Increased levels of provider interaction with plans on behalf of their patient population were identified as a recurring cost driver. One health system leader both praised and bemoaned the challenge of identifying and complying with different clinical care guidelines in markets served by multiple plans. She shared how each plan dictated different clinical guidelines and procedures and the fact that coverage for many services – particularly those associated with certain specialties like cardiology – was hard to ascertain, often not a covered benefit, and ended up being a patient responsibility frequently borne by the provider.

The ability to accurately identify benefits and reimbursement amounts on a timely basis – combined with clear clinical guidelines – was identified as a key means to control overall costs while at the same time doing the best for the health and well-being of the patient/member.

Length of Time a Person Remains with a Single Payer/Plan

One individual associated with a health plan noted the hesitance of funding preventative care for plan members who may not remain with the plan for more than a short period of time. For payers and care providers in risk-sharing arrangements, the cost of preventative care interventions is not typically recouped in a plan year.  They noted the likelihood of benefits associated with proactive care accruing to subsequent plans and the need to compensate clinicians and payers for delivering preventive care whose benefits are derived over multi-year periods. A topic for future discussion would be to explore the policy levers that could help to address this issue.

Impact of No Surprises Act on Provider Networks and Payment Integrity

The roundtable transitioned the discussion to the No Surprises Act where participants discussed what impact the No Surprises Act might have on the future of provider networks and reimbursement. MultiPlan’s Kurt Fullmer shared a quick overview of the Qualified Payment Amount component of the No Surprises Act and participants continued discussing the following related considerations:

Qualifying Payment Amounts as Regional Values Subject to Negotiation

QPA’s are regional values set by both providers and payers in a particular area that will be subject to a ‘baseball-style arbitration process if not mutually accepted by providers and payers.

RELATED: What is a Qualifying Payment Amount?

Compliance with State vs. Federal Regulations & PolicyQualifying Payment Amounts as Regional Values Subject to Negotiation

The need to understand and reconcile the federal No Surprises Act with state-level regulations was also discussed. One participant, a finance leader for a health system in southern California where out-of-network billing and payment law AB 72 has been in effect since 2017, noted ‘little to no non-compliance’ and expected the same with the No Surprises Act. Another participant, a leader at a PPO & IPA in the state of Washington, noted a similar experience with that state’s Balance Billing Protection Act that went into effect in January of 2020.

Removing the Patient from the Middle of Payer-Provider Payment Disputes

Kurt offered that in the interest of goodwill and patient experience, payers and providers may want to remove the patient from any payment dispute process as soon as possible.

Will Administrative Cost of Independent Dispute Resolution Force Providers to Join Networks?

While two participants noted that disputes are rare in their states which have already implemented surprise billing regulations, they and other participants agreed that direct costs associated with the dispute resolution process – and indirect costs associated with patient experience – are not insignificant and would be a consideration by any stakeholder entering dispute resolution.

One participant proposed that costs associated with dispute resolution – both direct and possibly more so with indirect patient experience costs and pressure from health systems – may force many currently non-contracted providers to join plan networks. Another participant disagreed and noted the ongoing physician shortage exacerbated by the pandemic supports non-contracted providers’ reluctance to join networks.

What Enablers Must Be Achieved to Realize Fair & Equitable Payment

The final topic Ferris presented to the roundtable was to solicit perspectives and feedback on what enablers need to be in place to achieve the overall goal of a fair price for a fair service in the most frictionless way possible. Participants agreed that while regulations cannot be ignored, that establishing common definitions, increasing meaningful collaboration and understanding between payers and providers, and working together to build transparent provider networks are primary enablers to achieve fair and equitable payments that address patient needs.

Listen here to Andrew Cone on the need for standard definitions as enablers of fair and equitable payment. [40:40 – 42:28]

Building a Fair and Equitable, Structurally Sound Payment System

If nothing else, this first roundtable on payment integrity and provider reimbursement clarified that the healthcare payment system remains broken with several long-standing structural issues that must be addressed. HCEG’s Ferris Taylor proposed that healthcare needs a solid, ‘concrete’ payment system foundation capable of withstanding the ongoing ‘huffs and puffs’ of various Big Bad Wolves involved with the current payment system: cost-shifting between stakeholders, misaligned incentives, unfair market pricing leverage, complex subsidies, and an increasing number of often ill-defined and conflicting government regulations and mandates – among other things.payment integrity value-based-care

More on Payment Integrity & Provider Reimbursement

payment integrity data and analytics costs and payment hcegWe appreciate Andrew Cone and Kurt Fullmer as thought leaders from our Focus Area Partner MultiPlan and look forward to our next roundtable on Payment Integrity: Data & Analytics for Costs & Payment. In this second roundtable on October 20th at 3:00 Pm ET / 12:00 PM PT, we’ll discuss more specific considerations and practical approaches to building a fair and equitable, structurally sound healthcare payment system.  Leaders of health plans, health systems, and care provider organizations are invited to join.  Request an invite here

Learn more about other Focus Area Roundtables here and consider joining our upcoming webinar series where information and thought leader insight and opinion of healthcare executive priorities will be presented.

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RELATED: Payment Integrity: Supporting Frictionless Services & Outcomes at Fair Prices

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Practical Interoperability Part 2: Trust, Workflow, Value-Based Care Models, & More

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‘Practical Interoperability’ means different things to different healthcare stakeholders. In the HealthCare Executive Group’s first Focus Area Roundtable on Interoperability, leaders associated with health plans, care providers, and organizations supporting the healthcare system discussed what practical interoperability means to them. Addressing barriers to interoperability and use cases with the most potential to increase interoperability was a primary focus of the roundtable with highlights shared in the first post recapping the roundtable titled ‘Discussing Barriers to Healthcare Interoperability, Use-Cases, and More.’ This second post shares additional highlights including increasing adoption of use cases, the importance of trust among stakeholders, interoperability’s increasing impact on value-based arrangements, and workflow considerations – particularly in terms of balancing the amount of information exchanged by payers and providers.

Read Part 1 of the recap of this first Focus Area Roundtable on Interoperability here.

Importance of Establishing & Maintaining Trust to Overcome Barriers to Practical Interoperability

Building on discussion of the importance of health plan-provider collaboration and which stakeholders are best positioned, qualified, and equipped to own specific interoperability use cases, HCEG’s Ferris Taylor noted the abundance of EMR’s, robust data sets that increasingly include structured clinical data, and analytical capabilities that weren’t available 12-15 years ago. These data and analytics, along with mandates on transparency and interoperability – particularly electronic prior authorization and pricing data – are forcing stakeholders to increase trust among themselves and other 3rd parties.

Ferris asked Tim Capstick, Regional Vice President of Health Plans at Surescripts, to frame the discussion of developing trust to unlock the value of increasing practical interoperability.

Developing a Trust Framework to Unlock the Value of Existing Healthcare Data AssetsTransparency in Coverage Mandate. No Surprises Act. health plans, health systems, healthcare providers. compliance-related activities. Data Standards, Data Collection & Operational Considerations

Tim set the context for roundtable comments by sharing how well-defined standards, clearly understood use cases, and trustworthy partners serve as the essential foundation to maximize business model benefits of increased interoperability. Tim emphasized: “We have to be able to trust whoever’s going to sit in the middle – or bring these entities together. We’ll have to be able to trust each other and make sure that we know and trust what each other are going to be doing with this information.

Listen here for more on establishing trust to unlock the value of healthcare data

RELATED: Building Trust is Essential to Transforming the Healthcare System

Establish Trust by Consistently Providing Quality Information That Returns Value

One participant representing a research organization shared that standards – particularly FHIR – will help with advancing practical interoperability once the data content, elements and formats of these standards are better understood.

Participant Denny Brennan, Executive Director and Chief Executive Officer of HCEG partner Massachusetts Health Data Consortium (MHDC), weighed in on the importance of by sharing that MHDC is creating an implementation guide combining DaVinci-compatible payer data and clinical data exchange standards related to prior authorization.

Denny noted that payers and providers have a great deal of work getting their digital house in order and making the necessary data available to accelerate instantaneous or close to instantaneous prior authorizations for services that today are difficult, arduous, and don’t require a huge amount of clinical intervention, if anything, to make the decision.Healthcare Price Transparency Price Transparency Regulations & Compliance, Policies, Programs, & Tools, Data Standards & Operational Considerations

Listen here for more on the importance of providing quality data to healthcare providers

See Price Transparency Data Standards & Operational Considerations from a recent roundtable in Price Transparency facilitated by our Focus Area Partner HealthSparq.

Balancing Amount of Data Shared with Providers – Increasing Impact of Value-based Arrangements

Other discussions involved challenges, issues, and opportunities regarding interoperability’s impact on the day-to-day workflow of healthcare stakeholders – particularly in terms of how care providers are accessing information and what information is being presented. The balance between providing too much information that can overwhelm care providers, administratively burdens them, and inhibits their ability to do what they need to do and responding to provider requests for more information to make care decisions were discussed. Participants noted value-based arrangements and risk-based reimbursement models are clearly an impetus for increased interoperability and drive desire from the provider community for more information. Being mindful of the process workflow of care providers, what information is inserted into the workflow, and how that information is inserted and accessed was identified as key considerations.

RELATED: How Health Plans Can Best Support Provider Organizations Address Barriers to Practical Interoperability

The Importance of Breaking Workflow to Include Business Partners

Roundtable participants made clear that accommodating care provider information demands – whether under traditional FFS or new value-based payment models – requires a thoughtful change to provider workflows. In addition, compliance with interoperability mandates and realizing practical interoperability’s greater benefits means all stakeholders will need to break their routines and [modify] their workflows to include partners.

“Stakeholders don’t have to do this themselves if they can get out of the adversarial zero-sum game that, if we share data with providers, or we share data with health plans, they are going to use those data against us or whatever scenario comes to mind. There’s a lot of money that’s being swept off the table by IT vendors who are offering niche services that ultimately never get used.” – Roundtable Participant

As shared in the Part 1 recap of the roundtable on interoperability, if providers invested in better collaboration with their payers, they might reduce their investment in the technologies to support processes they thought they were going to do entirely by themselves.

Listen here for more on breaking business partner workflow to reduce overall IT investments

Interoperability Vendors Serving the Healthcare Market – a Darwinian ExperimentDarwinian experiment interoperability-related initiatives, programs, and applications.

Participants shared various comments about increasing the adoption and evolution of interoperability-related initiatives, programs, and applications.

One participant shared his observation that, on the intervention side, increased interoperability is empowering many great third-party companies that are already doing great work around mobile engagement, disease management, and so on.

“There’s a whole bunch of them. There’s been a sort of Darwinian experiment of all these different vendors about what approaches to take and we’re starting to see some rise to the top; to create the ability for them [providers] to sort of socket in a secure way and play on the platform and do things for the benefit of patients.”

Another shared that healthcare stakeholders have a collective obligation to create a competitive environment for the adoption of practical interoperability:

“I think when we talk about interoperability, we have just not a responsibility but really an obligation to create a competitive environment where they can come and play and let the best continue to rise to the top.”

And another shared a suggestion to healthcare providers who think they can avoid sharing their healthcare data.

One of the steps that we have to really focus on in terms of what do payers and providers have to do is: stop thinking you have to do everything yourself. You’re going to have to share data. Forget about arguing about that. Forget about it. You’re going to have to share everything. The deal is done. It’s over. You’re going to have to be transparent, get over it, stop complaining about it.”

And now, healthcare requires payers and providers are going to have to really start thinking about creating new, collaborative business models that engage consumers. And if they don’t do that and each go after the consumer in their own way, they’re just complicating the problem we have today which is: I want to go to one place to get all my health data. The fact that it’s a health plan as envisioned in the regulation should not preclude any progress.

Quality Measures: Data Requirements, Costs, & Impact of Upcoming Changes

A participant from a small health plan noted the number of new hybrid measures related to telehealth services and how interoperability mandates and related initiatives will impact provider collection of quality measures and submission to health plans; particularly as the CMS deadline for transition to all-digital quality measures takes place in 2025 and information currently being collected goes away.

Sharing Information – It’s the Law & The Right Thing to Do

This participant representing a small health plan expressed concern about the number of EMR systems in use at health systems, the overall lack of awareness, understanding and adoption of interoperability mandates among the provider community, and the challenges that present health plans – particularly smaller health plans – with accessing data from health systems.

She mentioned the cost impact of both complying with interoperability mandates and how some providers and health systems charge for access to data housed in their individual EMR’s.

“We’re sitting here knowing that our entire world is going to digital, knowing that we have to get to digital, seeing interoperability as one opportunity for everybody collectively to get to digital. But the adoption rate is The Big Question in my mind.”

Listen here to the leader of a small health plan share insight on accessing data

Information Blocking – Serious Consequences for Non-Compliance

Information Blocking. Section 4004 of the 21st Century Cures Act. Electronic Health Information (EHI). USCDI Version 1. Regulations. Interoperability

Source: Office of the National Coordinator for Health Information Technology (ONC)

Existing regulation concerning Information Blocking (Section 4004 of the 21st Century Cures Act) was raised with one participant noting that charging fees for accessing, exchanging, or using Electronic Health Information (EHI) – with exception per 45 CFR § 171.302 – is a felony.  He noted that while a smaller subset of EHI data (elements defined in USCDI Version 1) is currently subject to Information Blocking through October 5th, 2022, regulations expanding those data elements to USCDI version 2 are quickly approaching and the regulated community should make all EHI available as if the scope of EHI were not currently limited to Version 1.

Patience for Non-Compliance with Information Blocking Regulations is Decreasing

This topic of discussion was ended with this participant saying:

“And CMS and the [Biden] Administration have shown absolutely no patience whatsoever with that stance. So, I think health plans who were finding themselves running up against EMR’S who are trying to monetize data and the availability of data from their records, have the weight of the law behind them. Providers who try to monetize their data exchanges with health plans directly is not okay unless it’s purely at cost or something very close to at cost if it’s an extraordinary effort. And going forward it’s not going to command a very high premium to get data from the provider who’s treating a member.”

Listen here to a healthcare data expert on provider reluctance to share data with health plans

Learn More About Practical InteroperabilityPractical Interoperability. Electronic pre-authorization. Surescripts. HealthCare Executive Group. HCEG. Focus Area Roundtable. health plans, payers.

On September 8th, 2021, leaders of health plans, health systems, and provider organizations will have the opportunity to discuss the real-life initiatives, programs, applications, and technologies their organizations are considering, implementing, or currently using to address the challenges, issues, and opportunities recapped here and in the first post of this two-part series.  Leaders of health plans, health systems, and provider organizations are encouraged to request an invite here.

Special thanks to Ashley Clark and Tim Capstick of our sponsor Surescripts for sharing their unique insight in this roundtable. For information on any of the topics presented in this post, contact Tim Capstick or Ashley Clark.

To receive additional information on interoperability and other healthcare leader priorities presented on the 2021 HCEG Top 10+ list, subscribe to our newsletter and follow us on Twitter and LinkedIn.

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Discussing Barriers to Healthcare Interoperability, Use-Cases, and More – Part 1

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‘Interoperability’ – particularly between health plans and care providers – has been a high priority of healthcare executives for years. It ranks #6 on the 2021 HCEG Top 10+ list and has an impact on almost every area of healthcare. And recent, still evolving mandates regarding data transparency, information blocking, changes to current HIPAA regulations, and interoperability have placed significant challenges upon the health plans, provider organizations, and the technology partners serving the healthcare industry. Forward-thinking stakeholders are not considering mandates as barriers to healthcare interoperability but rather viewing compliance with mandates as opportunities for ensuring the ongoing viability of their healthcare business models.

In our first Focus Area Roundtable on Interoperability held Tuesday, July 20th, and facilitated by our Focus Area Partner Surescripts, leaders from health plans, health systems, and healthcare provider organizations shared their experience, insight, and information in a roundtable fashion on the topic of Interoperability. Surescripts Tim Capstick and Ashley Clark served as industry thought leaders providing their perspective on these interoperability-related topics, in particular from a health plan point of view.

This post presents the first part of a 2-part series sharing highlights of this first roundtable on interoperability. Leaders of health plans, health systems, and provider organizations are encouraged to participate in upcoming Focus Area Roundtables including the 2nd Interoperability roundtable on September 8th, 2021.

Read Part 2 of the recap of this first Focus Area Roundtable on Interoperability here.

Barriers to Healthcare Interoperability Payers & Providers are Encountering

HCEG’s Executive Director Ferris Taylor kicked off the roundtable by asking participants: What are the barriers to healthcare interoperability that health plans and health systems are encountering with respect to the broad topic of interoperability?

Consent Management – One of the Barriers to Healthcare Interoperability

One participant noted that when deploying interoperability solutions, one of the biggest challenges involves consent management for members and patients. Appropriately managing patient data and providing individuals the ability to weigh in on the sharing of their data is both a technical and policy problem. He noted while their organization is addressing consent management largely on their own, he expects the evolution of privacy laws in California and Europe will likely have a national impact across the United States.

Another participant shared that addressing consent management is key to the future of interoperability – not just between members/patients and their health plan and providers but also when providers are sharing information with other health systems/healthcare providers.

Listen here for more on the importance of consent management in advancing interoperability

Other Barriers to Interoperability for Health Plans and ProvidersHCEG HealthCare Executive Group focus area roundtable Barriers to Healthcare interoperability poll

Participants were presented with a list of potential barriers to interoperability and asked to select two barriers from the perspective of a health plan and a provider.

For health plans, Access to and Integrating Data Sources ranked first followed by Complex Privacy and Security Concerns.

For providers, Internal Challenges with Technology and a Lack of Knowledgeable Resources were identified as key barriers to healthcare interoperability.

Impact of Proposed Modifications to HIPAA’s Privacy Rule on Interoperability

Surescripts Ashley Clark shared that data rights are an issue her organization takes very seriously and that they’re currently looking at CMS legislation regarding expanding the definition of treatment under HIPAA and what information can be shared as medical treatment versus non-treatment. Ashley shared that pending regulation changes will likely open up a lot of doors in terms of information that can be shared on things like medication history.

Another participant shared his perspective on barriers to healthcare interoperability for payers and providers by sharing that from his vantage point he’s seeing tremendous reticence on the part of providers to address interoperability and data transparency in any deep way vis-à-vis their health plan partners; with the exception of some relationships forced by the COVID pandemic.

Who Owns Health Plan Member and Provider-Patient Data?

Health Plan Best Positioned to Own Data - HCEG-Industry Pulse Research Survey 2020

Data Ownership – 2020 Industry Pulse Report

The recent announcement by the Biden Administration to increase penalties on providers who are not making their pricing information available was identified as the first step toward breaking the long-held, culturally ingrained notion that patient care and the information generated from that critical activity belongs to the health system and to the provider community alone.  It was noted cultural acceptance – on the part of both payers and providers – that their existing business models are built on a largely zero-sum game is a large barrier that must be overcome in order for practical interoperability to be widely adopted.

Note: Respondents to the 2020 Industry Pulse Report shared their take on data ownership between payers and providers. See survey results in the graphic on the right.

Listen here to a roundtable participant discuss data ownership among health plans and providers

“Culture eats technology. Culture eats strategy. Culture eats operations. Culture even attempts to eat policy for lunch.” – Roundtable Participant Denny Brennan – Executive Director & Chief Executive Officer of HCEG partner Massachusetts Health Data Consortium

Health Plans as Primary Connection for Patients & Healthcare Consumers

The concept of data hoarding by providers and payers was discussed along with the idea that it’s easier for health plans to surface data than it is for providers to do so. January of 2023 – just over two years away – was noted as a deadline for providers to share almost all of ‘their data’ with health plans. Per the Interoperability and Patient Access final rule (CMS-9115-F), providers will have to send the entire patient medical record to a patient’s current health plan because that health plan is responsible for moving that to the patient’s next health plan.

“I know a lot of regulators and a lot of providers around the country have not yet internalized the idea that the primary connection for the patient is going to be the health plan and that providers are responsible for providing the health plan all the clinical data that’s necessary to maintain that connection. And to inform the patient and make it possible for payer-to-payer connectivity to work.”

RELATED: Key Interoperability, Health Information Technology, and Transparency Policies

How Health Plans Can Best Support Provider Organizations Address Barriers to Healthcare Interoperability

“If I were running a medical group or a community hospital, one of the first things I’d be thinking is:

  • How do I sit down with my major payers and figure out what I can upload?
  • What am I doing that I don’t have to do that payers can pick up with me?
  • How do I cement that partnership by taking over pieces of the business that they insist on taking over that I’m better equipped to do like delivering care to the patient?

I’m the one who’s going to engage the patient. Give me tools, help my staff get trained so that the doctor doesn’t have to talk to the patient about SDOH or the doctor doesn’t have to talk to the patient about their financial exposure.”

Listen here for more on how health plans can help healthcare providers enhance interoperability

Use Cases with Most Potential to Increase Interoperability

Ferris asked participants to share their insight on which use cases might best advance interoperability and improve payer-provider-patient/consumer collaboration.

Increasing Consumer Ownership & Assisting Stakeholders Serve Their Members/Patients

A health plan participant shared that the use cases he sees that have the most impact potential are ones that lead to an increased amount of consumer ownership and activation of the health system to serve the member/patient. He noted that the process of effecting these use cases requires healthcare organizations to face some level of deconstruction. He explained that addressing barriers to interoperability in healthcare means that everyone has to have a relationship with everyone else when it comes to data – and some organizations are uncomfortable with that. So, we have more work to do.

Automating High Friction Activities & Improving Patient Engagement

Another participant shared that his organization separates use cases into two major buckets. One in the realm of automating high friction activities between payers and providers. Frequently occurring activities that can be automated and that are happening in every other industry. And the other in the realm of interventions, population health, or value-based care efforts that actually improve care like patient engagement, chronic disease management, telemedicine, etcetera.  For each bucket he emphasized the importance of each use case:

  • Being capable of being rolled out on their own and in a stepwise fashion to get to some ideal future state.
  • Having deployable value on its own and being able to stand on its own.

As an example of the bucket on the automation side, one of the first things healthcare organizations should address is auto eligibility because something like three-quarters of the calls from providers to their payers is some flavor of eligibility. And, except for a long tale of rare cases, a lot of that is totally automatable.

In a recent Focus Area Roundtable facilitated by HealthSparq, participants discussed how new price transparency mandates will likely help drive opportunities for increased engagement between providers and their patients. Read more about this potential in Payer-Provider Collaboration Critical to Meeting Price Transparency Mandates.

Reshaping Patient Relationships with Providers

Another participant shared that their personal experience is that the patient-provider relationship is typically a transactional relationship – often a negotiation on a chargemaster – and that increased interoperability seems to have the potential at least to change that quite dramatically.

Most Impactful Use Cases Identified by Focus Area Roundtable Participants

After discussing interoperability-related use cases, participants responded to a poll on ‘Which interoperabiliHCEG HealthCare Executive Group focus area roundtable Barriers to Healthcare interoperability Use Cases pollty use cases offer the most opportunity to advance patient-payer-provider collaboration?’ This question was asked from the perspective of both health plans and providers and the following were equally ranked for both health plans and providers:

  • Shortening or Automating Prior Authorizations
  • Providing Pricing Data to Patients & Providers

Electronic Prior Authorizations – Webinar on August 25th at 2:00 PM ET

Automating the processing of prior authorizations via ‘electronic prior authorization’ (ePA) – particularly in settings like the pharmacy where a patient may be waiting – can significantly enhance patient/member engagement by reducing the time between a request being made and a patient receiving care. To learn more about the Fast Prior Authorization Technology Highway (Fast PATH) initiative launched by AHIP and several health plans, consider attending Electronic Prior Authorization: The Fast PATH Towards Better Patient Care on August 25, 2021 at 2:00 PM – 3:00 PM ET.

Cutting Through Administrative Chaos by Focusing on Specific High-Value Use Cases

Surescripts Ashley Clark shared some actions that can be performed to cut through the chaos of everything that’s going on administratively at health plans and provider organizations. These included:

  • Driving adoption and usage of a limited set of use cases by getting very specific about those use case
  • How achieving success with a limited set of use cases can lead to bigger decisions across the board.
  • Being very detailed about the information that is being shared back and forth so that it’s not seen as if irrelevant information were overlooked

Listen here for more from Surescripts Ashley Clark on cutting through administrative chaos

Plans and Providers Working Together to Avoid Duplicative Efforts

One participant whose organization is closely engaged with supporting provider organizations shared that when meeting with providers and health plans they talk regularly about “You both are doing the same things, you call them the same things. They’re a little bit different but why are you both doing Population Health Management?” He commented: “I don’t understand why people who are battling it out on engaging the patient are battling it out on collaboration at the level of administering clinical process.”

Who’s Best Positioned, Qualified, and Equipped to Own Specific Interoperability Use Cases

After discussing interoperability-focused use cases, roundtable participants shared their take on additional considerations regarding involvement and ownership. The following points were raised:

  • Health plans are much better equipped to do population health management.
  • Providers are much better equipped to deal with care requirements and patients in real-time.
  • Everybody is investing in systems that are enormously expensive.
  • Providers are spending a lot of money on tools that if they had better collaborative relationships with payers, they wouldn’t have to invest in.

Payers and providers each need to ask: What does practical interoperability mean for our business and how do we design our businesses?

Listen here for more from roundtable participants on interoperability-related use cases

Informing Care Decisions & Providing Insights to Either Side of the Network

As an individual who works directly with payers and who has colleagues working directly with providers, Tim Capstick shared that Surescripts tends to focus on informing care decisions, providing insights across the network to both sides of the network, and enhancing the prescribing process for providers.

Tim shared that on the payer side there is a lot of concern and issue around the consistency in which providers are utilizing enhanced prescribing services, what providers are getting out of prescription services enhanced by interoperability and the overall return on investment? And on the provider side: what is the quality of this information that’s being presented? Is data consistently being presented and can the data be trusted?

Listen here for more from Surescripts Tim Capstick on informing care decisions and increasing the adoption of interoperability use cases.

Additional Interoperability-related Topics of Discussion – Coming in Part 2

The first Focus Area Roundtable on Interoperability facilitated by Surescripts covered a lot of areas of interest to participants – way more than can be reasonably shared in a single post. In the second part of this two-part recap, information on the following will be shared:

  • Trust, quality, and scarcity as a mechanism for increasing adoption of interoperability use cases
  • The importance of balancing the amount of information payers share with providers
  • Interoperability’s increasing importance and impact on value-based arrangements
  • The importance of workflow
  • An interesting comment about charging for access to healthcare data and how another participant responded

Come Learn More & Share Your Insight

Our second Focus Area Roundtable on Interoperability takes place on Tuesday, September 8th at 10:00 AM PT / 2:00 PM ET and will build upon the topics shared in the first roundtable. In addition, our Focus Area Partner Surescripts will share information on and respond to participant challenges, issues, and opportunities regarding interoperability collected in advance of the roundtable.  Leaders of health plans, health systems, and provider organizations can request an invite here.

Special thanks to Ashley Clark and Tim Capstick of our sponsor Surescripts for sharing their unique insight in this roundtable. For information on any of the topics presented in this post, contact Tim Capstick or Ashley Clark.

To receive additional information on interoperability and other healthcare leader priorities on the 2021 HCEG Top 10+ list, subscribe to our newsletter and follow us on Twitter and LinkedIn.

Healthcare Policy Changes. Focus Area Roundtable. HCEG. HealthCare Executive Group. Regulatory. Regulations. Policy. Mandates. Interoperability. Data transparency. Non-Compliance.

Impact of Healthcare Policy Changes & New Regulations – Healthcare Leader Insight & Opinions

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With the new presidential administration, staying abreast of and responding to new and changing healthcare policy changes, legislation, and regulatory activities is more important than ever. And with uncertainties about the longevity and true value of changes forced by the pandemic, the ease in which nontraditional businesses are entering the health care space, and increasing opportunities for employing technology, learning how other health plans, health systems, and healthcare provider organizations are addressing these regulatory and policy impacts affords unique value to healthcare executives.

On Tuesday, May 26th, 2021, a dozen senior executives serving the healthcare industry gathered for our second Focus Area Roundtable on Healthcare Policy & the ACA. In this session moderated by HCEG Executive Director Ferris Taylor and supported by Kevin Deutsch, General Manager & SVP of Health Plan Cloud at Softheon – our Focus Area Partner for Healthcare Policy & ACA – attendees were presented with four questions on which to share their insight, ideas, and questions for each other.Healthcare Policy Changes. Focus Area Roundtable. HCEG. HealthCare Executive Group. Regulatory. Regulations. Policy. Mandates. Interoperability. Data transparency. Non-Compliance.

Highlights of Healthcare Policy Changes – Focus Area Roundtable #2

This post shares some highlights of participants’ responses to the questions shared by Ferris and information shared by Kevin.  Access Healthcare Leaders Focus on Healthcare Policy & ACA – a recap of the 1st Focus Area Roundtable on Healthcare Policy & ACA and read on for more information on participating in future Focus Area Roundtables.

The roundtable kicked off with Ferris asking attendees: What are your expectations for healthcare policy changes over the next 2 to 4 years?

One participant suggested that the most important regulatory/policy areas for the government would be to set clear requirements and clarify the compliance details around interoperability and data transparency.  Policies to encourage and support digital health initiatives that address the practical flow and exchange of data – from the point of view of the regular doctor and patient – were identified as most important. Generating and consuming machine-readable data that includes prices healthcare providers negotiate with payers was identified as a primary challenge – particularly given the reluctance of payers and providers to publicize that type of data. Discussion continued on transparency mandates and policies.

A Backlash for Non-Compliance with Transparency Regulations?Healthcare Price Transparency Focus Area Roundtable

One provider participant suggested the current level of ambiguity regarding the type of pricing information hospital facilities must share, along with the relatively low current penalties for not meeting the requirement, might drive some organizations to simply face the potential cost of penalties versus the cost and implementation challenges associated with compliance. Attendees noted that costs and potential negative impact associated with disclosing contracted prices could be greater than the penalties of non-compliance. In the end, leaders of provider organizations must weigh the potential backlash of non-compliance against meeting detailed requirements of the regulations.

RELATED: Join us for our 2nd roundtable on Price Transparency on June 16th, 2021 at 10:00 AM PT / 1:00 PM ET

Ferris asked participants to share their insight on what the implications for non-compliance might be for the consumer.

A chief executive officer shared that he honestly could not assess how much, if any, of a consumer impact there might be due to current levels of skepticism about the utility of price transparency shopping tools. He noted recent research suggesting that, even if granted more information, people are not very good shoppers of healthcare services. He noted recent, direct experience in reaching out to health plan members with information on the potential to save over $1000 on an imaging exam where only 30% of the consumers accepted the recommendation with the balance going with their originally prescribed venue.

Participants noted that this reluctance from healthcare consumers might change over time and that healthcare organizations need to focus on educating and supporting consumer acceptance and usage of price transparency tools.

Bipartisan Support & Permanency of Pandemic-Induced Healthcare Policy Changes

A CEO participant shared that he was not very optimistic about significant changes to popular areas of policy such as Medicare Buy-In, Public Option, and Medicaid Expansion.  He suggested that the focus would be more about bipartisan issues as opposed to those demanding substantive partisan agreement. Drug pricing was noted as one bipartisan issue that may see some change.

Another area of the discussion centered on the permanency of policies that were temporarily reversed over the last year during the course of the pandemic. Policy extensions for things that probably should have been fixed long ago, telehealth for example which took a pandemic to shine a light on, would likely be made permanent.

Permanency & Impact of Policies Regarding Open Enrollment, Subsidies, & COBRAHealthcare policy changes and regulations. ACA open enrollment subsidies, single payer, public option, Medicare/Medicaid buy-in, block grants, CMS Interoperability and Patient Access

Ferris noted how open enrollment for individual markets had been extended and that eligibility for and levels of subsidies provided to individual members using ACA marketplaces has been expanded over the last year. Ferris queried participants as to whether those policies might be made permanent and what impact might result from reverting back to previous subsidy determinations as compared to the current environment where a million new individuals have enrolled into the ACA Marketplace.

Open enrollment policies were raised by one attendee as conditional based on employment levels and likely influenced by state-level needs and policy determinations.

While one participant noted the potential for more permanent changes to eligibility for subsidies and the level of subsidies, that participant also noted that subsidies related to COBRA coverage would likely not be made permanent because COBRA is directly impacted by the dynamics regarding unemployment and the need for coverage extension.

Impact of Open Enrollment & Subsidies on Underwriting & Reconciliations

Given mid-year changes to open enrollment periods and subsidy levels, a high degree of uncertainty as to what health plan populations look like can exist – all while health plans are building packages for the next benefit year. One participant shared that extended open enrollment periods introduce a variable that plans haven’t seen before and are likely to produce underwriting challenges for health plans in 2022 and beyond.

‘You’re never really closing the books on the one year before you’re getting ready to reload for the next year.’ – Roundtable Participant

RELATED: Healthcare Policy, ACA 2.0, Enrollment Period Lessons, & The Journey to the Exchange

Potential Areas for Healthcare Policy Changes & New Regulations

A number of areas were identified as top of mind for both health systems and health plans and ripe for new regulations and development of formal policies:

  • Payment parity for telehealth services
  • Removal of barriers to site of service and venue for telehealth engagement
  • Alternative payment models
  • Quality measures
  • Health equity
  • Holistic/whole-health care delivery

Cost of Care: A Failure of the ACA & Political Platform in 2022 & 2024?

Regulations and policies regarding eligibility for subsidies and their levels were noted as a symptom that the ACA, while it did a good job addressing coverage, didn’t really address the cost of care. While the cost of premiums can be controlled through greater subsidies, doing so doesn’t solve the problem. The problem is that health care costs too much and that’s driving either premiums up or subsidies up, neither of which are good.

One participant noted that the entry of non-traditional market participants like Amazon are just the results of not addressing the cost of care through the ACA over the last decade.

As one participant asked: ‘Can we really expect the current structure of the federal government to make major policy changes that might affect the cost of care?’ Another participant added: ‘While it may not happen this year or next, it’s possible that you’ll see the political parties run specifically on a cost of care platform for 2022. And certainly for 2024.’

Technology as a Force Multiplier to Address Healthcare Policy Changes

Ferris asked panelists what they see as the role of technology in addressing policy changes and how technology will make an impact beyond the ACA – to consumers, providers, health plans, payers, and hospitals.

One participant’s response:

‘I’m seeing technology as a force multiplier in a competitive advantage – a leveraging of clinicians whether they are acting as a call center coach or a nurse navigator. That model is tough to scale and so clinicians are best focused on high clinical acuity and complex care. And where we’re seeing technology best applied is where it’s being leveraged from a preventative, chronic care, and wellness perspective. You can engage more members and have a personalized experience across a broader swath of either membership and/or lines of business as well as it being a personalized experience.

And that includes leveraging remote patient monitoring capability, wearables, Etc. And so right now for a commercial line of business, you can do, for example, digital coaching and get reimbursed for it. But when it comes to government programs, that’s not been in effect yet. So, I think, as it becomes more commonplace in the commercial market in evolution it will be more common in government programs.’

No Area of Healthcare Will Be Untouched by Technology

A health plan chief executive officer shared:

‘It’s hard to think about any area that won’t be touched by technology. I think technology is going to reinvent the shopping experience in healthcare for both obtaining health insurance as well as care delivery. If we wonder what technology should do, we have to realize that Amazon is a technology company that brought the store to the house. And Netflix is a technology solution. And Uber is a technology solution. So why would we think that isn’t going to happen in healthcare, both on the plan and the care delivery side? I think technology is already revolutionizing care delivery so that much of it can be provided in the home if people want it there, or in the cloud.’

The participant went on to share additional insight on technologies likely impact on shopping, care delivery, and drug development.

RELATED: Healthcare Price Transparency – Leaders Share Insight – Part 1

Need for Ubiquitous Access to Healthcare Services & User Acceptance of Technology’s Limitations

One attendee commented about the need for ubiquitous access to healthcare services in all locations – urban, suburban, and rural – and the growing acceptance of technology-related glitches by healthcare consumers:

‘And the other thing that I really see that I think technology is going to go ahead and really flourish is that when you think about what happened with the pandemic and with people going ahead and deciding to work remotely; for some of them to flee the city’s and go to places where they may not be directly surrounded with a lot of health care options. They’re going to want to have the convenience of obtaining health care through technology because they’re not going to be so close to healthcare service options anymore.

I also see the attitude right now that when people used to say: ‘OK, there was something wrong with the technology and I’m not going to use it.’ Now they say: ‘Okay, well that’s just part of the package, something’s going to happen. There’s going to be a glitch but that’s just part of it’’ And they accept it. So, I think that with more of that type of acceptance, more and more people are just going to, as far as physicians and everyone’s health systems, are just going to accept it.’

Disintermediation – Patient, Physician/Provider, or Payer – All Others BewareHCEG Healthcare Policy Patient Payer Physician Provider Triangle

A chief executive officer of a provider organization offered that there’s going to be a lot of disintermediation between the real customer who’s the patient, the provider who’s the physician, and the health plan who’s the payer. He believes this because the information that’s available via personal digital tools and the movement to at-home care are going to really empower patients – i.e., consumers – to do a lot better with their health. He stressed the importance of focusing digital solutions on what providers and patients need – not on supporting the economics of the healthcare model.

He described a triangle of who’s paying, who’s getting the care, and who’s providing it and opined that companies not in that triangle are going to be disintermediated over the coming years.

Join Our Focus Area Roundtables

If you’re an executive/leader of a health plan, health system, or healthcare provider organization, consider joining one or more of our Focus Area Roundtables. In addition to Healthcare Policy & ACA, we currently have roundtables on Price Transparency, Interoperability, Next Gen/Value Payment Models, M&A/Joint Ventures and are establishing others based on 2021 HCEG Top 10+ focus areas.Join HCEG and/or participate in our Focus Area Roundtables

Complete this short form to share the focus areas you are interested in and how you’d like to participate with the HealthCare Executive Group. We’ll get back to you with information on participation.

For more insight and information on the challenges, issues, and opportunities facing healthcare leaders, subscribe to our newsletter and connect with us on Twitter and LinkedIn.Healthcare Executive Group Focus Area Partners HealthSparq Softheon Surescripts Zelis

Price Transparency Compliance Regulations Mandates. Policies, programs, and tools. Data standards. Operational considerations. Increasing adoption. End-user education and support. Payer-provider relationships.

Beyond Price Transparency Compliance – Stakeholder Thoughts – Part 2

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The Transparency in Coverage Mandate and the No Surprises Act are forcing health plans, health systems, healthcare providers to focus their attention and already overburdened resources on price transparency compliance-related activities. While price transparency mandates and regulations are intended to help make healthcare better and more cost-effective for health plan members and healthcare provider’s patients, there are strategic and tactical reasons to holistically address the following aspects of price transparency:

  • Policies, Programs, & Tools
  • Data Standards, Data Collection & Operational Considerations
  • Increasing End-User Adoption
  • End-user Education & Support
  • Payer-Provider Relationships

In the first post of a two-part series, Healthcare Price Transparency – Leaders Share Insight – Part 1, highlights from our first Focus Area Roundtable on Costs & Transparency held on April 5, 2021 were shared. HCEG members working for health plans, healthcare providers, and healthcare-related technology/service organizations shared their responses to some questions presented by Andy Hoffman and Matt Parker, two thought leaders with our 2021 Focus Area Partner for Costs & Transparency: HealthSparq.

Stakeholder Adoption, End-User Support, & Payer-Provider Relationships

In this second post, comments and insights from Focus Area Roundtable participants on the following aspects of price transparency are presented:

  1. Increasing stakeholder adoption of price transparency tools and services
  2. The importance of end-user education and support
  3. Payer-provider relationships to support access to price transparency information

RELATED: Understanding the Transparency in Coverage Mandate

Increasing Stakeholder Adoption of Price Transparency Tools

I think the concept of just being a liaison will go a long way on either side through this process. (Health Plan)

Go into the prescriber’s workflow with price transparency, going to the physician’s workflow with pricing information that not only saves the system money but that directly affects the consumer in a way that is frictionless. (Industry Analyst)

Whenever these conversations come up, taking a step back and saying [asking] Who’s going to benefit the most? And by that, I mean not just like the individual or the entity but the health system at large. If it doesn’t really waterfall to the whole cost of care and care opportunities, then we’re probably just clogging up the system. Who’s this going to piss off? Who’s going to lose from that deal? Companies taking rebates are going to lose. Companies overcharging and hiding pricing are going to lose. Intermediaries who aren’t necessary may lose. (Industry Analyst)

We’ve kind of assumed that we have to have all of these systems connected and all this interoperability wired in order to do that. But I’ve seen some really successful approaches and getting information into the decision maker’s hands that benefits the end consumer of health. (Industry Analyst)

Take something like hip and knee replacements. There’s an awareness of ambulatory participation, acute participation, post-acute participation on a couple of levels whether that’s brick and mortar and or home on the post-acute side. (Technology Provider)HCEG Focus Area Roundtable. Costs & Price Transparency. Compliance Regulations Mandates. Policies, programs, and tools. Data standards. Operational considerations. Increasing adoption. End-user education and support. Payer-provider relationships.

Health Plan, Health System, & Healthcare Provider Leaders – Click on the Above to Join a Focus Area Roundtable

Importance of End-User Education and Support for Price Transparency

Price transparency has different meanings to different people depending on their roles and expectations. (Provider)

I think hospitals will have to somehow educate patients and that can come in different forms. And whether it’s on a one-on-one setting or more about broader communication, there is an element of patient education that will need to happen. It’s going to be a lot more complex because it’s going to also have to account for the impact of the health plan. So, the education component is going to be large. (Industry Analyst)

I think the reality is most of us don’t really want to solve the problem in terms of us being the recipient of care. So, if I’m a patient, member, consumer, employee, I want the system to fix these things. I want my health plan that I signed up for to be smart. I want my doctor to have information and just do stuff that doesn’t cost me excess money. I want my pharmacist. (Industry Analyst)

We’re in rural areas so that’s a big, big challenge for us. But what does it mean to the consumer? Do they think that when they go in and try this tool that they’re going to understand precisely what the cost of their knee surgery is? And then is it going to be a big dissatisfier when they learned that surgeon had to do something more, or it was more complex than they originally thought? And as a result of that, they disengage. So, will this help or harm them? (Health Plan)

And then there’s the component of things that even an educated consumer might not know about like the anesthesiologist in the acute setting which rarely gets talked about. And then a bill shows up, let alone the medications that are incurred post-acute. (Technology Provider)

We also have a couple, sort of, denominators there. Am I able to figure this out on my own? Do I have search skills? And EOB skills? And ICD-10 code skills? And then the other is: Am I on Medicaid or sort of a capped model where what do I care about the price? (Industry Analyst)

Patient-Physician Relationships May Offset Price Transparency Benefits

I think it’s a personal thing. For surgeries you develop a relationship with your physicians so even if you see a great price somewhere else, I don’t think that people would jump out to go have say like a knee replacement or shoulder replacement or something even more critical with another physician somewhere else. (Provider)

If they have a relation, they tend to sort of stick with what they know. The people that would make the change are not the people that we would see price making the decision from a true consumer choice perspective but those that are just utterly desperate and have, maybe require something that they can’t otherwise get at which is, again, not part of, not really the spirit of the law, per se. (Health Plan/Provider)

RELATED: Healthcare Leaders Focus on Healthcare Policy & ACA

Payer-Provider Relationships Impacts from Price Transparency Compliance

How do you see the relationship between payers and providers in the space of both informing about price transparency but also making sure that the messaging is consistent? Because again, your got contract disputes and a lot of the No Surprise Act is going to come around contract disputes. (Technology Provider)

This [price transparency] could change the relationship between the provider and the payer. And we’re already seeing a lot of movement around mergers and acquisitions and perhaps this would incent that kind of behaviors further – or maybe not. But I think there will be some sort of macro-level impact as this becomes more widespread. (Health Plan)

Well, I think when it comes to that relationship of payer and provider, one key element that’s going to go a long way actually is support. And support probably more for the hospital side because there’s an element of an IT integration of the back end that you have to think about. And how does it all fit together? And what codes they have to integrate through? (Thought Leader)

Join a Focus Area Roundtable – Connect with Healthcare Peers

Additional Focus Area Roundtables on Costs & Transparency – and other 2021 HCEG Top 10+ focus areas such as Healthcare Policy & ACA, Interoperability, and M & A /Joint Ventures, among others – will take place throughout 2021. If you are interested in participating, reach out to us via email or complete this short form to indicate your interests.

To receive recaps of our Focus Area Roundtables and other information of potential use for leaders of health plans, health systems, and healthcare provider organizations, join our newsletter.

Healthcare Price Transparency Price Transparency Regulations & Compliance, Policies, Programs, & Tools, Data Standards & Operational Considerations

Healthcare Price Transparency – Leaders Share Insight – Part 1

By | Events, Focus Area Roundtable, Resources | 3 Comments

Healthcare price transparency has a lot of attention and focus right now, especially in the mandate-driven space. But addressing price transparency via compliance with regulations is just a portion of what health plans and healthcare provider organizations should be focusing on to help make healthcare better and more cost-effective for their members and patients.

In our first Focus Area Roundtable on Costs & Transparency held April 5, 2021, a group of HCEG members working for health plans, healthcare providers, and healthcare-related technology/service organizations gathered to discuss some of the challenges, issues, and opportunities associated with addressing price transparency.

Challenges, Issues, & Opportunities Beyond Price Transparency Regulations

Andy Hoffman and Matt Parker, two thought leaders with our Focus Area Partner HealthSparq, shared a timeline overview of the Transparency in Coverage Mandate and the No Surprises Act and facilitated the following questions:

  • How are you thinking about price transparency within a rather heavily regulated space?
  • What do you see as key issues and risks in the price transparency space? What’s the role of the 80/20 rule?Healthcare Price Transparency Regulations & Compliance, Policies, Programs, & Tools, Data Standards & Operational Considerations
  • How can we really focus on what health plan members and provider patients need to make good health care decisions, knowing that members and patients often have to navigate in antagonistic payer-provider environments?
  • How can we balance supporting patient needs and operate as an ongoing business while also informing people what things are going to cost before they have to spend unlimited amounts of money?
  • What unique challenges or strategies are you thinking about with respect to price transparency? And what opportunities are you looking to take advantage of regarding price transparency?

This post shares insight and information shared by roundtable participants on the above questions pertaining to the following categories:

  1. Regulations and compliance including their importance and value to various stakeholders
  2. Price transparency policies, programs, and tools
  3. Data standards and operational considerations to advance price transparency

A second post highlighting participant responses pertaining to the following categories will be shared shortly:

  1. Increasing adoption and the importance of end-user education and support
  2. Payer-provider relationships to support access to price transparency information
  3. Advancing healthcare price transparency and next steps

RELATED: Healthcare Leaders Focus on Healthcare Policy & ACA

Thoughts on Price Transparency Regulations & Compliance

As a payer and provider, I can look at other hospitals across the state and they’re not even using our latest pricing. They’re just putting something out there to meet the requirement. So, if there’s not consistency in the data, it doesn’t actually help anybody. It just creates profound confusion. (Health Plan/Provider)

Some of the things that I hear my peers talk about is: Are we just solving certain regulatory requirements or are we solving something members think they want but won’t actually be able to use in an effective way?  Or are we on a road to something that will be of value to all the parties involved? (Health Plan)

So, what are the different things people are putting out there? How do we then know this is the best? This is what we should be doing versus this is what we are doing. Because I think everybody is just trying to meet the intent of the law or the letter of the law, but a lot of people don’t know how. And so, I think that’s one of the things that we’ve got to [consider] if there’s anything we can do. (Technology/Service Provider)

These are people who are sick and injured and hurt and need health care. And we’ve got to do our part to help them out and we can do that in a way that drives our overall business priorities. This sets the floor. We talk about these mandates being a floor and you build an experience on top of that that supports your member needs and supports your patient’s needs. (Technology/Service Provider)

So, I think it’s a good thing that the conversation has started. But I think that the end product is going to be significantly different from what it is that we’re looking at this point. (Health Plan)

I feel like the price transparency is just a way to get our prices out there – for the most part as individuals [procedures]. Unless it’s very comparative in descriptions, information is really hard to compare apples to apples between hospitals. (Provider)

Healthcare Price Transparency Policies, Programs & Tools

Whenever I used to roll out tools and or guidance, probably two decades ago and in more than one state, you have to understand the nature of what it is that your end goal is. And sort of work backward from that. But just sort of putting some things out there, you end up getting exactly what you put into it. (Health Plan/Provider)

For a lot of these hospitals, putting out their prices shows major vulnerabilities for them when it comes to inappropriate pricing, when it comes to the contracts that they’re having. It does highlight the contracts that they have with their different vendors. (Technology/Service Provider)

I think some plans are in sort of this game of chicken to some extent because the No Surprises Act isn’t finalized yet. (Technology/Service Provider)

And how can we give voice to that as part of the overall conversation with the administration because I think they’re trying but they’re sort of missing the point. So, I think it’s incumbent upon us as an industry to start to respond back on all of those fronts as to how best to rethink how to do that since it started out previously and it’s been through lots of different iterations. But that lack of standards or consistency is just…(Health Plan)

Price Transparency Data Standards & Operational Considerations

From the payer or provider perspective, without somewhat more explicit data structure guidance across the board, it’s [price transparency mandate] not helpful. (Health Plan/Provider)

We need a standardization so that everybody can follow that. (Provider)

I don’t think you can do comparisons. It’s not the latest data. It’s not even the same from hospital to hospital. It’s kind of all over the place. (Health Plan/Provider)

So as an industry, I think whether that’s vendor-specific or provider, payer, or even consumer, I think I’d like to see a conversation around how do we drive to those data standards? (Health Plan/Provider)

I would agree that the majority of people and hospitals are doing that [trying to comply in good faith.] They don’t collect the data internally in ways that’s terribly helpful. So, to publish it [price transparency information] requires an infrastructure that frankly many of them don’t have in a way that makes it useful as say maybe a payer would. (Health Plan/Provider)

Healthcare is local, that’s very much true. So that’ll impact the dynamics and the impact of what price transparency brings to the table. (Thought Leader)

There are operational challenges that we have to address and plan to address to be compliant with the new regulations that the question becomes: How will this look and feel to the consumer because pricing can vary so significantly? (Health Plan)

One of the challenges that we see when we engage with plans is: Who are the folks and entities within the organization that are trying to solve this problem? We’ve got to get fee schedules from your contracting folks, and you need member eligibility and claims verification. You had to pull all these different systems together and that’s been one of the things we’ve seen as a big challenge – especially with bigger payers, these big vast entities that have to solve these problems with groups that really hardly ever talk to each other. (Technology/Service Provider)

Join a Focus Area Roundtable – Connect with Healthcare Peers

Additional Focus Area Roundtables on Costs & Transparency – and other 2021 HCEG Top 10+ focus areas such as Healthcare Policy & ACA, Interoperability, and M & A /Joint Ventures, among others – will take place throughout 2021. If you are interested in participating, reach out to us via email or complete this short form to indicate your interests.

To receive recaps of our Focus Area Roundtables and other information of potential use for leaders of health plans, health systems, and healthcare provider organizations, join our newsletter.

Healthcare Policy ACA Focus Area Roundtable. Medicare/Medicaid beneficiaries. Health Insurance Marketplace. HealthCare Executive Group HCEG. Softheon. American Rescue Plan (ARP). Expanded APTC Eligibility and Subsidy Amounts May Drive Individual Market Growth. real-time prior authorization requirements.

Healthcare Leaders Focus on Healthcare Policy & ACA

By | Focus Area Roundtable, HCEG Content, Research | 4 Comments

Early indicators of healthcare policies’ prioritization, implementation, and/or likelihood of success can provide a head start to healthcare organizations – particularly those serving Medicare/Medicaid beneficiaries and those operating in the Health Insurance Marketplace or looking to join the Marketplace in 2022. It is in that spirit that the HealthCare Executive Group (HCEG) has created Focus Area Roundtables to promote dialogue among HCEG members on important 2021 HCEG Top 10+ priorities. This post shares highlights of the initial online discussion about Healthcare Policy & ACA and presents additional information regarding future Focus Area Roundtable discussions.

See below for Additional Focus Area Roundtables Currently Being Assembled

Healthcare Leaders Discuss Healthcare Policy & ACA

On March 11th, executives from mid-sized health plans (MSH), an integrated delivery system (IDS), a national specialty care provider (NSP), and a not-for-profit consortium focused on advancing healthcare data and technology transformation (EDC) participated in the roundtable. In a roundtable fashion, these leaders shared their thoughts, ideas, and concerns on Healthcare Policy & ACA and forecasts for how the Biden administration may reshape the American healthcare ecosystem for the years to come.

The session was moderated by HCEG Executive Director Ferris Taylor and supported by Kevin Deutsch, General Manager and SVP of Health Plan Cloud at Softheon, the 2021 Focus Area Partner for Healthcare Policy & ACA.

What are your healthcare policy & ACA-related priorities, thoughts, and concerns?

Dealing with volume and uncertainty of healthcare policy and regulations amid rapidly changing and often unstructured government programs: ACA enrollment/subsidies, single payer, public option, Medicare/Medicaid buy-in, block grants, CMS Interoperability and Patient Access, etc.It was noted that no one has a crystal ball and none of the participants were “inside” of the administration, so discussions of this type help to develop the ability to respond to the many uncertainties.  The needed speed of learning and agility to respond to changes in healthcare policy is the “new normal.”  Specific perspectives were exchanged among the roundtable participants.

MSH: Expressed concern on how to keep premium costs down for members who are largely low-income.

NSP: With $2 billion at risk in value-based programs and whose patients are mostly Medicare beneficiaries with multiple comorbidities, healthcare policy needs to:

  • Facilitate cost-effective access to coverage for Medicare and other beneficiaries.
  • Establish reasonable value-based programs and not just push out a bunch of voluntary risk-sharing programs long on objectives but short on details.
  • Support coverage and payment for virtual care, particularly remote monitoring.

EDC: Shared that consortium members have noted that recently passed rules on Interoperability and Information Blocking are top of mind. These two areas of regulation and the advent of technology standards like FHIR and code sets such as LOINC, SNOMED, and others are helping to establish a common language and ‘gauge’ to help providers to speak the same language – particularly with payers.

What components of the recently passed American Rescue Plan (ARP) are most promising to you?

MSH: As a health plan, we struggle to address premium affordability and overall cost to the member and aim to keep increases to premiums at inflation or lower. Additional costs beyond the member premium often prevent members from accessing needed care. While the pandemic did not materially impact our overall member count, it did impact the composition of members as the number of commercial members decreased while Medicaid members increased.

NSP: Mentioned the need for providers and supply-side organizations to better understand the true cost of the services and products and services they provide. And another participant noted experience with a wide variety of costs and outcomes for services provided to seemingly similar patients.

FACT SHEET: American Rescue Plan and the Marketplace

What are ARP’s Immediate, Mid-Term, & Long-Term Benefits?

Healthcare Policy ACA Focus Area Roundtable. Medicare/Medicaid beneficiaries. Health Insurance Marketplace. HealthCare Executive Group HCEG. Softheon. American Rescue Plan (ARP). Expanded APTC Eligibility and Subsidy Amounts May Drive Individual Market Growth. real-time prior authorization requirements.All participants agreed there is a large and immediate benefit associated with ARP funding for vaccine-related availability, administration, and tracking.

NSP: Increased funding of COBRA premiums at 100% through September 2021 and increases to Medicaid funding seem to be a positive, as more unemployed people will be less likely to forgo or delay needed care.

Longer-term benefits from the funding and attention drawn to mental health services by the ARP were also noted. One participant called out how historically low funding and the stigma associated with mental and behavioral health services has led to a large, undiagnosed population. The need to invest more in mental health now is needed to save more serious issues later.

EDC: Consortium members have noted the importance of funding and policy related to community health centers and the need for policy and standards related to the collection and use of Social Determinants of Health (SDoH) – particularly for Dual-Eligibles.

Softheon’s Kevin Deutsch noted that changes to ACA subsidy thresholds and payment amounts brought about by the ARP will further complicate reconciliation and payment challenges. And that additional changes to subsidies and cost-sharing reductions by the Biden Administration will likely happen, further complicating these already non-trivial plan administration and payment reconciliation challenges.

RELATED: Expanded APTC Eligibility and Subsidy Amounts May Drive Individual Market Growth

Topics for Next Healthcare Policy & ACA Focus Area Roundtable

Healthcare Policy ACA Focus Area Roundtable. Medicare/Medicaid beneficiaries. Health Insurance Marketplace. HealthCare Executive Group HCEG. Softheon. American Rescue Plan (ARP). Expanded APTC Eligibility and Subsidy Amounts May Drive Individual Market Growth. real-time prior authorization requirements.As the allocated time for the roundtable flew by, Ferris moved to close the inaugural Focus Area Roundtable by asking participants what was top-of-mind in regard to Healthcare Policy & ACA and what participants thought would be the most important topics for the next roundtable. Topics raised by participants as having potential value to other HCEG members, that might be addressed in future roundtables, and would benefit from Softheon’s experience and views across their customers include:

  • Addressing policy/regulations in regard to controlling costs – particularly for high-need, high-cost members/patients.
  • Challenges, issues, and opportunities related to direct provider contracting and value-based payment arrangements.
  • Understanding and addressing costs related to internal operations and process modifications.
  • Sharing lessons learned as to what other healthcare stakeholders are doing, and not doing, in response to rapidly changing Healthcare Policy & ACA.
  • Preparing for the many regulatory deadlines (and the frequent adjustments to timelines) such as the 1/1/2022 real-time prior authorization requirements.

Additional Focus Area Roundtables Currently Being Assembled

HCEG is currently assembling roundtable discussions on Costs & Transparency and Interoperability – two other HCEG Top 10+ focus areas closely related to and impacted by Healthcare Policy & ACA.  Additional focus areas will be added in the coming months.

If you’re an executive of a health plan, health system, or healthcare provider organization who’d like to join one of these informal, small group discussions, please reach out to us here or share your contact information via this tool. And consider joining our newsletter to receive information of potential value to healthcare executives including recaps of future Focus Area Roundtables.oin HCEG and/or participate in our Focus Area Roundtables

RELATED: Healthcare Policy, ACA 2.0, Enrollment Period Lessons, & The Journey to the Exchange