February 25, 2020
11:51 am
Massive amounts of healthcare data are collected across the nation, and as technology advances the question of how to use it has continued to be a discussion. There have been hearings on Capitol Hill about interoperability and data privacy and security, and the Healthcare Leadership Council (HLC) recently hosted a congressional briefing on the subject of health data. The resources of the private sector have been focused on utilizing data for innovation in the treatment of patients. There has been open dialogue between healthcare organizations and government agencies regarding the best way to approach regulations surrounding the use of health data. Joseph Impicciche, the president and CEO of Ascension, in his Morning Consult op-ed supports proposed rules by the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare and Medicaid Services (CMS) on advancing nationwide interoperability and encourages additional work be done to ensure continuous improvement in patient outcomes.
HHS Policies to Promote Secure Exchange of Data Will Lead to Better Health Care
By Joseph Impicciche February 10, 2020
Health care is undergoing dramatic transformation, and the entities accountable for delivering compassionate care to patients are being challenged to meet these new and evolving needs. The dimensions of this transformation are deep and wide, and the complexities of providing care extend far beyond those traditionally involved in managing patients’ health and wellness.
Health care providers are focused on the same goal: improving health and health care for patients and consumers. This requires coordination across an expanding number of constituencies who must have access to greater clinical insight, leveraged to accelerate the delivery of novel care models and therapies. Essential to these requirements is access to robust clinical datasets and tools that facilitate real-time clinical workflow integration so that comprehensive care coordination is available to and benefits all those we serve, while maintaining patient data privacy and security.
With the future of health care dependent on the ability to make data-driven decisions, we applaud the Department of Health and Human Services’ continuous efforts and leadership through the Office of the National Coordinator for Health Information Technology and the Centers for Medicare and Medicaid Services on advancing nationwide interoperability. The proposed new policies have the potential to take an important next step in granting consumers seamless and secure access to data and increase the vehicles for the exchange of electronic health information across providers and systems. They should be used as the starting point for further discussions and potentially thoughtful modification, led by the spectrum of stakeholders involved in the delivery and receipt of care.
Every day, providers, patients and consumers find themselves trying to piece together the health information they need from siloed systems across the care delivery continuum. Within each of these systems, information is entombed in proprietary data models that effectively create dependency on a single electronic health record vendor’s platform.
Exchanging health information from disparate platforms has proven cumbersome. It can be difficult to positively confirm a patient’s identity, as no unique national identifier exists. And even when records can be accurately matched, the scope of data exchanged is often limited and not fully supportive of integrated care delivery across the continuum.
It recently has been suggested that these gaps are not significant impediments to the delivery of coordinated, whole-person care. Some argue that closing these gaps will create unsupportable fiscal and administrative burdens for health systems and providers, as well as untenable privacy and security risks for patients and consumers.
New policies must acknowledge and seek to ease the cost and administrative burden on providers; appropriate timelines should be afforded, and privacy and security risks should be mitigated. However, a properly considered rule should ultimately be finalized because of the overall benefit it will provide to patients and providers alike. We believe the cost of doing nothing is too high; the persistence of current approaches will not be economically sustainable and will not support the more sophisticated approaches to privacy and security that will be required to adequately serve patients, consumers and providers across the continuum.
Today, after incredible focus and expenditure by federal agencies and tireless work at technology adoption by numerous stakeholder groups, we’re still very far from realizing our shared goal: a robust, standards-based, cloud-enabled health care information architecture that will support broad health care data interoperability and benefit patients across the continuum of care.
The failure is multidimensional and includes the lack of common data model implementation at scale, the lack of a national health care information identifier at the individual level, and the absence of a meaningful scope of application program interfaces across health care technology platforms — both legacy and newly emerging platforms outside the traditional health care ecosystem.
The solution lies in applying new technologies — some developed in other industries — to accelerate the democratization of commoditized health care data housed in modern cloud-based architectures. Accordingly, we applaud the work of HHS, ONC and CMS in tackling what is admittedly a complex issue. They are seeking to develop a forward-looking policy that drives common health care data model development, supports accelerated development of APIs and promotes the development of software applications that support provider, patient and consumer choice in health care technology to enable true multiparty health care process integration.
Without a doubt, the pursuit of democratized health care information must be approached carefully and in parallel to the evolution of more sophisticated privacy and security frameworks. Multi-stakeholder input will be required to ensure that next-generation privacy and security policies account for the technological capabilities, increasing cybersecurity threats and greatly expanded scope of health care constituencies that now exist.
Recognition of the importance of these capabilities is not new. Foundational support for their achievement rests with a sweeping series of federal legislation enacted over the last 20 years, including the Health Insurance Portability and Accountability Act, the Health Information Technology for Economics and Clinical Health Act, the Affordable Care Act and others. The broad goal underpinning each of these policies was to create the framework necessary for the efficient and effective creation, distribution and utilization of digital health care information to benefit patients.
The work to build on these foundational policies must continue. HHS’ proposed rule warrants careful consideration and thoughtful modification to minimize burden, ensure data privacy and security and provide appropriate time for implementation. With such changes, HHS’ new rules will help advance the progression toward a framework that allows data to be optimally available to improve patient care while providing robust privacy protections and data security.
Joseph R. Impicciche, JD, MHA, is president and chief executive officer of Ascension.
January 28, 2020
3:42 pm
One area in which we have seen a great deal of bipartisanship in Washington is in the effort to prevent and treat substance use disorder. In 2018, Congress passed groundbreaking legislation by overwhelming margins in both houses that gave states the resources they need to combat what was then commonly known as the opioid crisis.
But as U.S. Representative Diana DeGette (D-CO) pointed out at a recent congressional hearing, the battle is far from over. As she said, this addiction crisis has come in waves – the first being prescription pain medicines, the second heroin, the third synthetic opioids like fentanyl, and now, “it looks like a ‘fourth wave’ of the crisis may have already arrived. The opioid epidemic has fueled a huge increase in methamphetamine use. In 2018, there were more than twice as many deaths involving meth as 2015, and meth is increasingly turning up in overdose deaths and drug busts across the country.”
Given this continued high level of addiction and overdose cases, it is imperative that we give healthcare providers the tools they need to effectively treat substance use disorder patients. So, an essential next step in combating this drug crisis must involve addressing regulatory barriers that are standing between medical professionals and the information they need to provide effective diagnosis and treatment.
A law that is more than 40 years old, known as 42 CFR Part 2, places information sharing in substance use disorder cases on a different plane that that applied to all other patients under HIPAA laws. 42 CFR Part 2 places strict limitations on confidential data sharing among front-line caregivers and, in so doing, makes care coordination extraordinarily difficult. This outdated law worsens the odds of substance use disorder patients surviving and recovering.
There are two bills that have been introduced in Congress to address this problem. The Overdose Prevention and Patient Safety Act in the House and the Protecting Jessica Grubb’s Legacy Act in the Senate would remove these regulatory stumbling blocks and enable caregivers to have the information they need to do their jobs.
The necessity of these measures was underscored by an official with the North Carolina Department of Health and Human Services, who told Congress, “We have invested a lot of resources through peer support and other tools to try to support that coordination, care management, etc. but there is still a huge limitation. Even doctors within the same system can’t easily talk to each other to coordinate care around their patients. North Carolina is fully supportive of modernizing 42 CFR in an attempt to maintain privacy but also move us to integrated care.”
September 19, 2019
4:19 pm
September 16-20 is National Obesity Care Week (NOCW). NOCW is a source for science-based information on obesity. More than 93 million Americans are affected by obesity, with an estimated cost of $480 billion to the healthcare system. The Healthcare Leadership Council (HLC) has joined as a partner of NOCW, advancing our conviction that people who struggle with obesity deserve access to quality care and must be treated with dignity and respect.
Recently, HLC has been focused on how the healthcare system can utilize research on social determinants of health so that essential socioeconomic and environmental factors can be considered and addressed in addition to one’s clinical care. At the beginning of this week, HLC hosted a Hill briefing that had an expert panel present on reducing disparities in health. While this particular briefing looked at the whole patient from a pediatric and senior perspective rather than zeroing in on obesity, there is a strong relationship between obesity and low socioeconomic status that cannot be ignored.
Many HLC members have recognized the need to reach out and invest in the well-being of surrounding communities:
- BlueCross BlueShield of Tennessee has taken many avenues to encourage healthy lifestyles of Tennesseans, such as revitalizing neighborhoods with parks, and repaving the roads with bike lanes.
- The Bristol-Myers Squibb Foundation provided resources to establish one of New Jersey’s largest and most comprehensive children’s hospitals which includes a clinical center of excellence dedicated to the study and treat childhood obesity.
- Fairview Health System launched a new 24-week Healthy Lifestyle Plan that combines evidence-based weight loss strategies with one-on-one lifestyle coaching. This approach can address medical issues that make it hard for someone to lose weight on their own, such as hormone levels, the side effects of prescription drugs, or chronic conditions like sleep apnea.
- Teladoc Health has invested in a personalized virtual care platform for physical and behavioral health, addressing the root of the problem for chronic disease with digital therapeutic interventions and sustainable behavioral change.
It is promising that across the healthcare spectrum there have been a variety of solutions offered to address obesity, but much progress must still be achieved to make a lasting impact on the health of millions of Americans. Many people do not know that obesity is a disease, and education is the just the first step to achieving NOCW’s goal of access to comprehensive obesity care. More voices are needed to enact change. Additional information about ways to take action is available on ObesityCareWeek.org/ACTION.
September 11, 2019
12:03 pm
Several years ago, there was a significant push in Congress to allow wholesale importation of prescription drugs from other countries into the United States. The Healthcare Leadership Council found itself in an opportune position to examine this idea, given that our membership includes not only pharmaceutical manufacturers and healthcare payers, but also the companies that would facilitate the distribution of these imported products.
We found that the promised cost savings from importation were an illusion. When shipping, relabeling, storage, liability coverage and other costs were factored into the mix, the cost differential between medicines in this country and those from countries that employ government price controls was largely erased. It has never been surprising that HHS Secretaries and FDA Commissioners from both Republican and Democratic presidential administrations over the years have attested that the risks connected with drug importation far exceeded any possible rewards.
But now the issue is back in a big way. States – including Vermont, Colorado, and Florida – have passed legislation to set up their own drug importation programs, pending federal government approval, and the current administration has indicated a willingness to work with them in making this happen. Also, Congress is once again considering importation legislation. This is troubling.
The only difference between the drug importation issue today and when we first examined it is that the dangers have exacerbated while the benefits have not. There are certain facts that policymakers should keep in mind when contemplating the prospects of opening our borders to drugs from outside the U.S.
- We already have a drug crisis in this country, much of it fueled by the proliferation of lethal fentanyl that is originating in other countries and finding its way here through our ports and via the international mail service.
- The world is facing an enormous health challenge driven by the increase in counterfeit drugs. The World Health Organization has estimated that one in every 10 pharmaceutical products in low- and middle-income countries is falsified or substandard. Opening our borders increases our exposure to this danger.
- Since we first examined this issue, there has been an explosion in the number of online pharmacies. According to the National Association of Boards of Pharmacy, there are over 35,000 online drug sellers and 96 percent of them are in violation of applicable laws. Many of these operations are based in Canada, the nation often cited as the safe place from which to import drugs.
- And just to dispense with the notion that importing drugs from Canada will drastically lower prices, the numbers simply don’t work. Canada’s population is barely more than one-tenth that of the United States and our neighbors to the north have already been enduring problems with drug shortages. The idea that Canada can provide a sufficient supply of prescription medications to meet American demands is ludicrous.
By all means, we should be having a national conversation on healthcare affordability and accessibility in the United States, seeking solutions that will ensure patients have access to the treatments they need while also maintaining an environment that incentivizes lifesaving medical innovation. A serious discussion requires credible ideas, though, and drug importation doesn’t fit that bill.
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