Showing posts with label PPACA. Show all posts
Showing posts with label PPACA. Show all posts

Sunday, August 19, 2012

Crazy busy

So I noticed it's been 4 months since I last posted on HIT Shrink. Lots of things going on. I've had a few people ask me about what I've been working on, so thought I'd put it up here... if only for me to keep track of, including all the links to these areas.

  • Epic Implementation
    After about 15 months of planning, meeting, coding, optimizing, and preparing, we went live on Epic a week ago. We had Cerner before that, and a homegrown CIS before that. The initial CIS was mostly labs, rads, and dictations as I recall. With Cerner PowerChart and FirstNet, we added nursing documentation, MAR, and some clinical documentation, though we had a hybrid system that included a paper chart for all non-dictated physician documentation (mostly progress notes, as H&Ps, consults, and DC summaries were dictated) and paper physician orders. A handful of small, contained areas (Peds, OB, Psych, ED) did do CPOE, but expanding that to the rest of the hospital, and our many community-based physicians, was untenable.

    Now we have (mostly) abandoned paper documentation, with all physician documentation being done by either phone dictation, templates (using Notes and/or Notewriter plus/minus partial dictation), or Dragon. We are piloting Dragon Enterprise with a small number of physicians, otherwise they are using their own licenses. Still having network connectivity problems with wireless devices, especially BYODs -- particularly those of the Apple persuasion. And ironing out printing issues.

    Overall, the switch has gone amazingly well. I attribute this to excellent executive support, mandatory classroom (not online) physician training (8-12 hours), extensive clinician involvement in the build, and heavy at-the-elbow support.

  • Maryland's Behavioral Health Integration
    In 2011 we kicked off an effort to combine the Department of Health and Mental Hygiene's two administrations -- Mental Hygiene Administration and Alcohol and Drug Abuse Administration -- into an integrated administration which is expected to be called the Behavioral Health Administration. The Joint Chairman's Report lays out much of the rationale, as well as the challenges. Health Secretary Joshua Sharfstein MD MPH, previously Baltimore City commissioner, then a stint at FDA, has led an admirably open, transparent, stakeholder-rich effort to shape this integration effort.

    The past 3 months have been heavy with 2-to-3-hour long Workgroup meetings. I've been attending many of these meetings (maybe a third to a half), representing the Maryland Psychiatric Society. The main points I've been making mostly revolve around ensuring mental health parity and integration of primary care. Besides the large overall Workgroup, there have been four, more focused, workgroups (links have meeting agenda, minutes, resource documents). Their charges are as follows:
    • Systems Linkage:
      Purpose: To make a recommendation on those factors that should be present to promote "integration." For example, should there be a shared electronic health record among all providers within an MCO? What factors indicate “integrated” care, and what factors indicate “collaborative” care?
    • State/Local and Non-Medicaid WorkgroupPurpose: To make a recommendation on what services/financing should be left outside a “Medicaid” integrated care model to accommodate non-Medicaid eligible populations, or non-Medicaid-eligible services. This Workgroup will also make a recommendation on the roles that state and local government should perform depending on which services/financing are left outside of the Medicaid financing model, as well as how to support and interface with selected model.
    • Evaluation and Data WorkgroupPurpose: To determine what data is available and relevant to the ultimate recommendation on the model, and to make a recommendation on potential measures to evaluate any selected model.
    • Chronic Health Homes Workgroup
    • Purpose: To make a recommendation on a new “Health Home” service under the Affordable Care Act, and make a recommendation on how the new service could be developed to support any integration model. For example, this workgroup would help define the service; define the population eligible for the service; and define the provider qualifications to deliver the service.
  • Maryland Health Benefit Exchange
    Maryland is among the earliest states to respond to the ACA's requirement of health insurance exchanges that include qualified health plans (QHPs) which must include a minimum set of essential health benefits (EHBs). This process has been unfolding extremely quickly over the past three months, with several meetings per week across all the advisory committees, as well as the governing Board. I've served on the Plan Management Advisory Committee, which has completed its work and submitted a Summary to the Board and to the legislature. Over 200 pages of public comments have been submitted to the Board, which met last week. Ensuring that there are requirements to demonstrate Parity compliance, as well as adequate provider network standards, has been the main focus of mental health advocates.

    The other advisory committees include Navigator, Continuity of Care, Financing, and Exchange Implementation.
  • Maryland Health Information Exchange
    The MHCC Policy Board continues to slog through its policy discussions. The current list of policies is in a .pdf document here. We've also been working on draft regulations for HIEs in Maryland. Initial public comments on these draft regulations are available on the HIE website.

Other things I've been working on include APA's Committee on Electronic Health Records, M3Clinician (a clinician portal for the M3 mental health screening tool), and mental health parity. This last thing includes working with folks in the Parity Implementation Coalition, testifying at a Congressional parity hearing, and even appearing on the Diane Rehm Show.

I'll try to post a bit more often here, but you can also keep an eye on Shrink Rap, Clinical Psychiatry News, and a new column on health IT to start soon in Psychiatric News.
Thank you for reading.

Tuesday, July 12, 2011

Health Insurance Exchange Regs: Mental Health Coverage and 45 CFR Parts 155-156

The NPRM for the Health Insurance Exchanges portion (45 CFR Part 155 & 45 CFR Part 156) of the Affordable Care Act came out yesterday (thanks for the tip-off, +David Harlow). I quickly scanned it for specific mentions of standards related to mental health coverage. See below for relevant sections. (I'll look at Part 153 later.)

First impressions: it does encourage specific considerations for folks with mental illnesses and other disabilities be addressed, but I am so far (just based on the above) unimpressed with provisions ensuring parity for this population -- a population that was heavily marginalized and discriminated against during the managed care cycle from the 80s and 90s. I did not find a single reference to the Mental Health Parity Act (45 CFR Part 146), either. It also mentions the need for accurate provider directories, which are notoriously inaccurate in behavioral health. It encourages input about how to hold Exchanges accountable for accuracy, including indicating whether providers are accepting new patients.
[pg 30] According to section 1311(d)(6) of the Affordable Care Act, Exchanges are required to consult with certain groups of stakeholders as they establish their programs and throughout ongoing operations. We propose that the Exchange consult on an ongoing basis with key stakeholders, including:
  • a. Educated health care consumers who are enrollees in QHPs; “educated” is the term used in Section 1311(d)(6)(A) of the Affordable Care Act to describe consumers who must be consulted. We recommend that Exchanges include in these consultations individuals with disabilities;
  • b. Individuals and entities with experience in facilitating enrollment in health coverage;
  • c. Advocates for enrolling hard-to-reach populations, which includes individuals with a mental health or substance abuse disorder. We also encourage Exchanges to include advocates for individuals with disabilities and those who need culturally and linguistically appropriate services;

[pg 44] In paragraph (e), we propose that the Exchange conduct outreach and education activities to educate consumers about the Exchange and to encourage participation, separate from the implementation of a Navigator program described in §155.210. Exchanges should aim to maximize enrollment of eligible individuals into QHPs to increase QHP participation and competition which in turn increases consumer choice and purchasing clout. This will also reduce the number of individuals without health insurance coverage. We encourage Exchanges to conduct outreach broadly as well as in ways that are accessible to people with disabilities,
individuals with low literacy, and those with limited English proficiency. In addition, we encourage Exchanges to target specific groups including hard to reach populations and populations that experience health disparities due to low literacy, race, color, national origin, or disability, including mental illnesses and substance use disorders.

[pg 186] §155.130 Stakeholder consultation.
The Exchange must regularly consult on an ongoing basis with the following
stakeholders:
  • (a) Educated health care consumers who are enrollees in QHPs;
  • (b) Individuals and entities with experience in facilitating enrollment in health coverage;
  • (c) Advocates for enrolling hard to reach populations, which include individuals with a mental health or substance abuse disorder;
  • (d) Small businesses and self-employed individuals;
  • (e) State Medicaid and CHIP agencies;
  • (f) Federally-recognized Tribes, as defined in the Federally Recognized Indian Tribe List Act of 1994, 25 USC §479a, that are located within such Exchange’s geographic area;
  • (g) Public health experts;
  • (h) Health care providers;
  • (i) Large employers;
  • (j) Health insurance issuers; and
  • (k) Agents and brokers.


[pg 202] §155.430 Termination of coverage.
...
(c) Termination of coverage tracking and approval. The Exchange must –
  • (1) Establish mandatory procedures for issuers of QHPs to maintain records of termination of coverage;
  • (2) Track number of coverage terminations and submit that information to HHS on a monthly basis;
  • (3) Establish standards for termination of coverage that require issuers of QHPs to provide reasonable accommodations to individuals with mental or cognitive conditions, including mental and substance use disorders, Alzheimer’s disease, and developmental disabilities before terminating coverage for such individuals; and
  • (4) Retain records in order to facilitate audit functions.