The U.S. Dept. of Health & Human Services recently announced a new strategy to reduce the administrative and regulatory burdens of electronic health record and other technology systems. Designed to give clinicians more time to focus on patient care, the strategy may fall well short of its objectives for better patient access and improved physician experiences.
Just last week, the U.S. Department of Health and Human Services (HHS) released the final version of a comprehensive strategy developed jointly by the Centers for Medicare & Medicaid Services and the Office for the National Coordinator for Health Information Technology (ONC), following public comment solicited in late 2018. The document, “The Strategy on Reducing Regulatory and Administrative Burdens Relating to the Use of Health IT and EHRs (Electronic Healthcare systems)”, aims to apply the agencies’ rulemaking powers and considerable healthcare industry influence to “give clinicians more time to focus on what matters - caring for their patients.”
It is fair to say that everyone in the U.S. has an interest in the healthcare industry’s success improving the performance of their EHR systems - both as providers and patients. In research published nearly a year ago by Kaiser Health News and Fortune titled, “Death By 1,000 Clicks: Where Electronic Health Records Went Wrong.” The authors observed that “10 years after President Barak Obama signed a law to accelerate the digitization of medical records - with the federal government, so far, sinking $35 billion into the effort - American has little to show for its investment.”
The Fortune/KHN research goes on to state that “Rather than an electronic ecosystem of information , the nation’s thousands of EHRs largely remain a sprawling, disconnected patchwork. Moreover, the effort has handcuffed health providers to technology they mostly can‘t stand and has enriched and empowered the $13 -billion-a-year industry that sells it.”
Author, physician and CEO of Haven Healthcare Atul Gawande, also spoke to this issue in a New Yorker magazine article titled “Why Doctors Hate Their Computers” In it, Dr. Gawande asks “are screens coming between doctors and patients?” describing in detail the many negative outcomes for physicians and patients when doctors are required to interact with systems that were not designed to suit them or their work.
In an announcement from the Centers for Medicare and Medicaid Services (CMS) of the HHS strategy’s release, CMS administrator Seema Verna, noted that “The
taxpayers made a massive investment in EHRs with the expectation that it would solve the many issues that plagued paper-bound health records. Unfortunately - as this report shows - the cure has been worse than the disease.” Ms. Verna went on to say that “it is unacceptable that the application of health IT still struggles to provider ready access to medical records, access that might mean the difference between life and death.”
HHS’s strategy report focuses on three primary goals, offering recommendations to:
- Reduce the effort and time required to record information in EHRs for healthcare provider when they are seeing patients.
- Reduce the effort and time required to meet regulatory reporting requirements of clinicians, hospitals and healthcare organizations; and
- Improve the functionality and intuitiveness (ease of use) of EHRs
HHS’s strategy announcement has been met with a blend of optimism and skepticism. Healthcare providers and their agencies have complimented the agency’s attention to reducing excessive burden, a problem that is universally acknowledged among hospitals and other providers. However, in a comment published the day following the announcement, the American Hospital Association (AHA) stated that “some ONC recommendations…could have unintended consequences for adoption of current standards and would not address the lack of transparency or uniformity around payer requirements.”
The AHA went on to recommend that the agency “align Medicare and Medicaid clinician requirements in the Promoting Interoperability Program; improve its systems for attesting to meaningful use of EHRs (a condition for the above referenced federal funding); and improve its certification requirements.” The AHA also noted that “the lack of interoperability affects the usability of EHRs and urged the agencies to more forward with policies to support information exchange.”
As with any high-level strategy, the success of HHS’s proposal and the American healthcare industry’s effort to reduce the administrative and regulatory burdens on Health IT and EHR systems will depend on the details. Details that may be more complex and challenging than in any other sector of the American economy. When one considers the size of the industry ($3.3 Trillion, representing close to 20% of GDP), the scope and scale of this challenge makes sense.
Taking a Larger View of the Patient Journey
The EHR and Health IT problems facing healthcare are not confined to clinically-related functionality. They affect every other aspect of the patient’s experiences. In their respective statements, CMS Administrator Verner and Dr. Gawande point out how flaws in EHR and other Health IT systems can compromise patient safety. Often missed in this discussion, however, are other aspects of the patient’s care experience. Specifically, the financial dimension of care.
In an article published by Loyale Healthcare last year titled, “Electronic Medical Record Systems: Powerful for Clinical Engagement, A Liability for Patient Financial Engagement”, Loyale CEO Kevin Fleming focused not on the clinical deficiencies inherent to these disparate, overly complicated systems but to the financial and administrative obstacles they have placed between patients and their care. Mr. Fleming also noted how the massive investments of time, effort and money necessary to deploy and operate these systems often create organizational fatigue that blinds healthcare providers to other investments with the potential to improve the performance of their EHR to provide patients with better access and experiences.
In our view, improved patient access and experiences are relevant at the beginning of a patient’s care journey, when the decision whether or not to seek care is made. Astonishingly for more than half of Americans at that early stage, out-of-pocket costs are the deciding factor. According to research published late last year, 51% of survey respondents said that they had avoided care due to an inability to pay. 78% have been afraid to go to the hospital because of cost. For patients, affordability has become a healthcare crisis.
For many healthcare providers, affordability is synonymous with transparency; more specifically, the ability for patients to know what the cost for their care will be in advance, before treatment has begun. This issue was explored in greater detail in a more recent Loyale article examining another CMS initiative. Titled “Medicare’s Price Transparency Rules Alone Don’t Deliver What Patients Need - A Patient-First Approach Does.”
In this article, Mr. Fleming applauds CMS’s intentions. However, like the AHA’s criticism of the new HHS strategy to reduce EHR burdens, he notes that the rules themselves are inadequate for achieving their stated objectives. “CMS rules threaten to distract providers and payers from the larger, more important issue facing healthcare and patients. That issue is patient financial engagement.” To that end, five essential healthcare deliverables were described:
- Present upfront cost estimates for the anticipated course of treatment and all associated expenses, including pre-service eligibility so a reliable out-of-pocket estimate is also presented.
- Offer multiple payment options to address patient affordability. The Loyale Affordability Workbench, for example, offers provider-configured options that may include discounts for prompt or upfront payment; short-term interest free financing; or longer-term payment plans funded by third party lenders with a reputation for client care.
- Interactive self-service options with secure personalized experiences that measure up to the best online experiences consumers have with trusted brands like Amazon, Apple, Zappos and other industry leaders. This is the new standard by which providers will be measured.
- Personalized, contextual digital communications that honor each patient’s preferences and behavior. For some providers up until recently, every patient with an unpaid balance became little more than a number - a balance to be collected. In an industry dedicated to health and well-being, no provider can hope to compete without engaging in the financial dimension of care.
- End-to-end data analytics, so providers have the information they need to make evidence-based decisions about their patient-pay portfolios and manage for success - as care givers and as business operators.
Many of the same flaws affect both HHS’s new EHR Burden Reduction Strategy and CMS’s Price Transparency rules. Fortunately, the remedies for both are similar. The solution calls for developing a platform approach to healthcare’s operating model. An approach that incorporates multiple system inputs into a single, manageable whole. One that makes sense for provider-users and delights patients at the same time. At Loyale, we are confident our industry will succeed in hitting that mark.