Are you planning on attending ASTRO and/or SROA conferences in San Diego from October 30th - November 3rd? Come by Booth # 816 and visit with Oncology Convergence.  Hear about how Oncology Convergence can assist your organziation with its Revenue Management challenges.  Also attending the Elekta Users Conference on October 30th. 

Amednews.com posted an article on Monday to discuss planned RAC audit expansions by the end of this year.  The Patient Protection and Affordable Care Act requires CMS to include in the audit umbrella Medicare Advantage, the Medicare drug benefit and Medicaid in addition to the current Medicare design.  The article notes that, “Earlier this year, President Obama called for expanding payment recapture audits throughout the federal government to improve payment accountability.” 

The president and CEO of HealthDataInsights, the Medicare RAC for audit region D, also mentioned expansion into the Veterans Health Administration and Tricare.  “To the extent that we can accelerate the national RAC program…speedy returns to the Medicare trust fund will be achieved,” she noted. 

This expansion would certainly be a huge benefit to the government, but issues persist.  Despite the looming Medicaid inclusion deadline, the director and CFO of CMS’ Office of Financial Management, Deborah Taylor, explained the difficulties they face in meeting that target.  Indeed, she noted, “We are still in the planning stages,” due to the fact that there are 50 state programs in Medicaid with which CMS needs to coordinate efforts.

Still, with the Medicare overbill recapture dollars growing from $54 million in the first year to $247 million in the second, plus the promise to help fund the recent healthcare bill overhaul with such RAC audit programs, pressure on CMS will be intense to meet the required deadline.  CMS has met some of the bill’s targets and are close to others.  For example, the requirement to expand the Medicare RACs to all 50 states has been met, and Taylor asserted they are far along with implementing the prescription drug benefit into the program.

In response to physician complaints which arose during the demonstration phase of the RAC audits, CMS has added many changes to the Permanent RAC program.  Amednews added a chart to the article that demonstrates those changes.  I’ve copied it below:

Source: Centers for Medicare & Medicaid Services Office of Financial Management

The bottom line is that the RACs are here to stay.  In addition to seeking and charging with crimes the overtly fraudulent Medicare schemes, they are also going after the unintended overbills arising from simple coding errors and rule misunderstandings.  Few specialties can surely be impacted by such audits as oncology, particularly with regard to Medicare.  With the volume of Medicare patients oncologists see and the complicated coding rules, it would be wise to be prepared for such an eventuality.

The Association of Community Cancer Centers’ annual members’ survey, “Cancer Care Trends in Community Cancer Centers”, reveal cost cutting measures and delays in large expenditures in weathering the economic recession.  In a press release posted July 15, 2010, the ACCC reports their key findings, including the following:

• Majority of respondents have enacted hiring freezes, while smaller percentages have actually reduced staff and cut services.  Despite such cost-cutting measures, 78% report, “…their cancer program’s financial status as good or very good,” with only 7% responding that it is “poor”.
• Large capital equipment purchases represent a mixed bag.  While such big ticket purchases as linear accelerators and ultrasound imaging machines have been delayed, some equipment and cancer service line offerings such as IMRT and robotic surgical systems have increased over last year.
• More patients are in need of financial assistance in affording meds, co-pays and transportation.  And, an overwhelming 73% of respondents are seeing an increase in uninsured and underinsured patients.
• Consolidation in hospitals, cancer centers and oncology physician practices is on the rise.
• Fewer private practice oncologists are in contractual relationships with cancer centers, as many physicians opt to be employees of a hospital.
• Use of EMRs jumped by 21 percentage points in one year, and many providers use more than one EMR software program.
• Oral chemotherapeutic agent use is low, up only 3 percentage points over the previous year. 

This is a follow-up to the post of just a couple days ago about CMS’ gathered advisory panel’s meeting to discuss RadOnc prostate cancer treatments and their effectiveness.  Essentially, the panel told CMS that there just isn’t enough data to determine it at this time.

Not only is there not enough clinical data on the safety of focused radiation treatments but there isn’t enough long-term patient-tracking or comparative effectiveness research.  Overall, only a few studies have been done to evaluate these treatments’ outcomes on prostate cancer.

As this panel was convened to advise CMS on appropriateness of covering such treatments, officials will be considering the results.  At this point, there will be no change to nation-wide coverage, which is currently allowed and disallowed by the individual Medicare regions.  Reuters has the whole story at this link: http://www.reuters.com/article/idUSTRE63K5P720100421.

Baltimore is hosting the Medicare Evidence Development & Coverage Advisory Committee meeting this week to determine whether coverage of certain radiation oncology treatments for prostate cancer is appropriate.  As prostate cancers are so slow-growing that most patients die of other causes, does it make sense for a patient to undergo risks and costs of surgery, invasive or non-invasive?

The RadOnc treatments being discussed include CyberKnife, external beam radiation and the implantable radiation seeds.  Currently, Medicare coverage of these treatments is determined on a region-by-region basis, with the Northwest not covering them at all and only certain areas of the West Region will pay for them.

The panel assembled to debate such treatments’ value include outside experts who will try to come to some consensus.  The final ruling by CMS is not expected for at least six months, but whatever they decide to do will most likely affect decisions by private insurance carriers.

Stay tuned for more details.  For more information on this meeting, go to this page http://www.reuters.com/article/idUSTRE63H26520100418 from Reuters.

Necessary to healthcare adoption of EHR technologies are rules for certifying those HIT’s.  CMS will need to establish what is necessary for EHR certification in order for participating Medicare and Medicaid providers to qualify for HITECH Act incentive dollars for installing such technologies.  To that end, the Department of Health and Human Services HIT unit has released a Proposed Establishment of Certification Programs for Health Information Technology (http://www.federalregister.gov/OFRUpload/OFRData/2010-04991_PI.pdf) Notice of Public Rule Making (NPRM) putting forward its intentions on how the process will transpire.

Two proposals have been made in order to carry this process towards a permanent certification program.  The first allows for a temporary certification program, authorizing “...organizations to test and certify Complete EHRs and/or EHR Modules, thereby assuring the availability of Certified EHR Technology prior to the reporting period in which health care providers may seek the incentive payments available under the Medicare and Medicaid EHR Incentives Program demonstrating meaningful use of Certified EHR Technology.” (http://healthit.hhs.gov/portal/server.pt?open=512&mode=2&objID=1746zzzzzzzzzzz)

The second proposal provides for the permanent certification program which will replace the temporary one.  Both programs will overlap during Q1 2012, with the permanent one fully replacing the temporary one in Q2 2012.  While the temporary one requires organizations to “…perform both the testing and certification of Complete EHRs and/or EHR Modules,” with accredited test labs performing the testing, the permanent one only requires organizations to perform certification.  Additionally, under the temporary program, the Office of the National Coordinator for Health Information Technology (ONC) will oversee accreditation, but that function will be assigned to private organization under the permanent program.  ONC intends for the National Institute of Standards and Technology’s (NIST) National Voluntary Laboratory Accreditation Program (NVLAP) to fulfill that role.

As these government programs are in the proposal stage, they are open to public comment.  HHS has provided a site, http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480a7c48a, where written comments can be submitted electronically.

For additional information on the proposal, HHS has provided a “Facts-At-A-Glace” page at http://healthit.hhs.gov/portal/server.pt?open=512&mode=2&objID=1746 and an FAQs page at http://healthit.hhs.gov/portal/server.pt?open=512&mode=2&objID=1747.

At a hearing on medical radiation conducted by the House Energy and Commerce Health Subcommittee, E. Stephen Amis, MD, FACR and chair of the ACR Task Force on Radiation Done in Medicine called for “…accreditation of all facilities which bill Medicare for advanced medical imaging and radiation oncology services, including those in hospitals, to reduce the likelihood of adverse patient events and help assure a baseline quality of care nationwide,” according to a news release on ACR’s website (http://www.acr.org/MainMenuCategories/media_room/FeaturedCategories/PressReleases/ACRCallsforMandatoryAccreditation.aspx?css=print).

While CMS will require such accreditation for providers that bill for advanced medical imaging services under Medicare part B as of 1/1/2012, that requirement does not include hospitals or radiation oncology.  Amis notes, “Patients have a right to expect the same quality of care regardless of the setting in which they receive it.”  Any accrediting body CMS chooses to determine such accreditation should be highly knowledgeable on radiology and radiation oncology, according to Amis’ comments to the committee.  He went on to note that a national CT registry like the one ACR has been working with the industry to develop should also be implemented.

Just this week I posted an article explaining key points of the HITECH Act and EHR conversion.  With hospital incentive payouts set to begin October 1, 2010, and physician payouts January 1, 2011, most providers won’t be able to qualify for those initial dollars.  Beacon Partners, a consulting group, commissioned a survey of executives from 168 healthcare organizations to gauge the extent of EHR preparedness.  While the respondents work for hospitals, the findings can surely be extrapolated to private practices, too.  You can view the slideshow of results at this site: http://www.beaconpartners.com/ehradoption/BeaconPartners_EHR_AdoptionStudy.pdf.

Some key findings include the optimal level of Medicare patients to make the HITECH Act incentives worthwhile, driving forces behind EHR adoption, extent of completed EHR conversion, obstacles in completion and increased employment expectations. 

Some good news to oncology-focused organizations is that providers with anywhere from 41%-75% of their revenue from Medicare will benefit from the incentives.  As this is often the case with oncologists, it is certainly worthwhile to convert to EHR sooner rather than later in order to maximize incentives.  Moreover, the study notes that in those hospitals with the highest physician EHR-adoption rates, patient satisfaction is also on the rise.  Given that by far the most important reason stated for implementing an EHR system is improving patient care (by more than forty percentage points over receiving stimulus funds), the knowledge that patient satisfaction increases post-conversion is encouraging.

A minority of the executives surveyed reported having implemented some form of EHR system but are by no means complete.  They reported that, “These early adopters have migrated from paper to a hybrid record system and are moving along the journey to an EHR.”  At the same time a majority comment that their biggest obstacle to EHR adoption concerns their own internal resources (such as change management and clinical workflow integration).  Nearly half note that they don’t have the necessary resources to successfully implement EHR.

When asked how they expect the implementation to be handled, a project management approach throughout the whole process was preferred.  A majority plan to hire more employees for the conversion or to outsource the project. 

The authors note,

Healthcare organizations…will need a full-service firm with a service excellence philosophy to support their patient care strategy and align the strategic issues facing the healthcare organization, including change management, physician adoption, revenue cycle management and overall clinical transformation.