CMS is currently testing a new payment model seeking to avoid hospitalizations by funding nursing homes and practitioners for more extensive intervention.

On August 27, 2015, CMS reported that seven organizations will test the efficacy of the new payment model for nursing home operators and practitioners by funding higher intensity interventions in the nursing facilities for residents who may otherwise be hospitalized. The goal is in recognition of the fact that treatment at nursing homes is less expensive than hospitalizations.

The Centers for Medicare & Medicaid Services has been working with seven “Enhanced Care and Coordination Providers” (ECCPs) for the past three years to gather information. These organizations may apply to test the new payment model.

While this should come as no news to anyone involved in revenue cycle management for nursing homes or hospitals, the agency said that “improving the capacity of nursing facilities to treat common medical conditions as effectively as possible within the facility has the potential to improve the residents’ experience at lower cost than a hospital admission.”

Significantly, the model also includes payments to physicians, NPsand PAs– which makes me wonder if part of this initiative will also include increased responsibilities for the nurse practitioners and physician assistants.

This model is currently scheduled to run from October 2016 to October 2020.

 

 

Today was the absolute worst day ever

And don’t try to convince me that

There’s something good in every day

Because, when you take a closer look,

This world is a pretty evil place.

Even if

Some goodness does shine through once in a while

Satisfaction and happiness don’t last.

And it’s not true that

It’s all in the mind and heart

Because

True happiness can be obtained

Only if one’s surrounding are good

It’s not true that good exists

I’m sure you can agree that

The reality

Creates

My attitude

It’s all beyond my control

And you’ll never in a million years hear me say that

Today was a good day

 

Please, Now read from bottom to top

 

In reviewing the various reports of HIPAA breaches as a subset of the almost every day occurrence of significant data breaches, and the recent reports of significant data breaches of information that is either entrusted to the government (e.g. medical and/or credit information) or information that the government is both logically and legally responsible for safekeeping, there seems to be a significant disconnect. With respect to HIPAA, the current regulatory environment seeks a very high level of compliance with significant fines and governmental interventions in the case of a breach, but when the government drops the ball, the most we can expect is OOPS, and maybe not even that.

Without going through the litany of recent governmental breaches, I will highlight the White House’s recent confirmation that the Office of Personnel Management suffered a SECOND cyber attack in which the data of 4.2 million Federal employees was stolen. In addition, the April 2015 report of the Office of Inspector General (OIG) reported the results of its audit of the security controls of the Department of Health and Human Services (HHS) which identified numerous deficiencies.

Imagine a father heartily puffing on a cigar, and a mother vigorously inhaling the smoke from her cigarette lecturing their teen about the dangers of smoking, while at the same time (in the name of proper parenting skills) advising their child of the consequences they would administer if their child began smoking. I imagine that at least to some, this scene would seem somewhat hypocritical.

I fully understand that there must be limitations on the ability for private citizens to sue the government and/or its employees carrying out governmental functions (sovereign immunity), but the real question is the propriety of placing standards on private industry before one cleans up one’s own house.

You may find this to be HIPAA-Critical (hypocritical)or you may feel that there is a critical need for the protections that  HIPAA mandates and therefore,  immunity and consequence free breaches are  appropriate.

Irrespective of the answer, to the extent we can trust the government with private medical information (PHI) for its healthcare exchange, and to the extent that, at some level, the government may be competing with medical providers (e.g. various forms of Medicaid) is it appropriate to have two standards?

What do you think?

Identity theft is so prevalent that we are almost desensitized to its effects – unless of course we’re speaking about its victims who are left with the unenviable task of sifting through the rubble and trying to re-create their medical and/or credit identities. What is surprising is that the very laws that were enacted ( HIPAA etc. ) to protect patient privacy hinder the victims of medical/identity theft from accessing THEIR OWN medical records. The Wall Street Journal had an illuminating article regarding the rise of medical/identity theft ( How Identity Theft Sticks You With Hospital Bills ). There is no way to offer absolute protection under all circumstances. I am reminded of the tragedy that occurred when the captain and flight attendants could not gain access to the cabin of a German Wings flight, because the cabin was virtually impregnable as a safety measure against terrorists. The very measures that were put into effect to protect the passengers were the ones that ultimately cost them their lives. We cannot totally escape the Law of Unintended Consequences, but in making rules or drafting laws it is helpful to   be aware of the potential for looming risks.