PPSA’s Final Ruling is Here: Now What?

February 8th, 2013 § Leave a Comment

This interpretation was written by Leon Goldman, Kyruus’ Chief Privacy Officer and former Chief Compliance Officer at Beth Israel Deaconess Medical Center

The final rule of the Physician Payment Sunshine Act, commonly called “PPSA”, has been published in the Federal Register as of today, February 8, 2013. Anxiously awaited by the healthcare industry and the public alike, the final ruling means applicable manufacturers and group purchasing organizations will be frantically reviewing it, trying to ensure their organization’s processes and systems are ready and able to report the data to CMS by the deadline of March 31, 2014.

While there is anxious activity among the manufactures and GPOs, it is certainly less clear to hospitals and physicians what the PPSA will mean to them, and what exactly they need to be doing to prepare. Aside from providing the opportunity to review the data posted about them, PPSA does not place any statutory obligations on hospitals or physicians – it will, however, reveal a great deal of information about them to the public.

The process by which hospitals have monitored financial relationships with industry has long relied on individual disclosure, either on an annual or transactional basis triggered by specific events, such as seeking permission to perform research studies. Proactive review of publicly available information has not been part of standard review for most institutions – often because the perceived benefit of implementing such a process has not outweighed the cost of review, in both dollars and time. PPSA mandates not only the collection of a vast amount of information about “covered recipients” but also the creation of a vast database that must be downloadable, easily searchable, and aggregated. How and to what extent this will actually change the playing field is yet to be known.

This database will provide (relatively) easy access to vast amounts of information to the public, regulators, or the media for the first time. While some information is already available today via select states reporting and approximately 50 companies currently disclosing, PPSA will significantly increase the amount of information available to the public. We project the following:

  • Over 3 million public industry payment disclosures amounting to over $4 billion
  •  Over 700,000 healthcare professionals indicated with public industry payment disclosures
  • Over 1,500 companies disclosing payments

At Kyruus, we have little doubt that agencies, such as the National Institutes of Health, will use the information as a way to “verify” what they are told by their applicants. The media, too, will see the data as an interesting source of information for investigative reporting. Lastly, individual patients and families will likely use the data to become more informed about their physicians and the relationships those physicians have with industry. Given all who will likely use the data, it behooves hospitals and covered recipients to be aware of the data.

Nevertheless, the presence of such a database will not relieve institutions of the need to gather information on their own as they have been doing up to this point. Factors for consideration:

  1.  The annual posting of the data may not provide adequate information for organizations to fulfill their transactional obligations for events such as accepting payment from PHS for funded research.
  2. The PPSA database will contain nothing about non-physicians receiving payments or transfers of value about which the organizational policies require disclosure.
  3. There may be payments to physicians that need to be disclosed under an organization’s policies, but which are exempt from reporting under the PPSA and can only be discovered through an active disclosure process.
  4. Consolidation of reporting by manufactures may make the information that is reported less useful to the institution for their assessment need. Again – the institution will need to continue to monitor data internally to understand what PPSA will mean for them, and what they need to do.

Kyruus believes that best practices will move organizations to develop policies and procedures that actively collect disclosure information from affected individuals and actively monitor publicly available information. This allows organizations to be in control of the information, to reconcile discrepancies, identify and eliminate problem areas, and to respond quickly to both public and regulatory inquiries.

04 PPSAs Final Ruling is Here: Now What?

How Many Doctors Do I Need, and What Kind?

December 31st, 2012 § Leave a Comment

This is a post by Dr. Tim Crowley, Vice President of Physician Network Services at Kyruus.

This is a question I’m often asked when I help Hospitals and Healthcare systems build their Physician Network. The answer: It depends.

It depends on what you are trying to do, what you hope to build, and what kind of organization you aspire to become. For example, are you trying to build an integrated delivery system for a given population, are you trying to fill empty beds, or are you aiming to become the premier tertiary and quaternary referral center for a region?

Let’s start from the top. Imagine you landed from outer space and came across a population of 1 million humans with no healthcare system in place. This is a simple math puzzle. To care for those 1 million residents, you’ll need 300 Primary Care Physicians (one for every 3,000 residents). If you hire Family Medicine physicians, you may only need 300 , assuming they can deliver babies and care for children. (You might only need a few Internists, Ob/Gyn’s, neonatal and pediatric specialists to take care of complicated cases; However, if your “population” is a bit more demanding and really wants specialized physicians, that mix would call for more pediatricians, internists and Ob/Gyns).

The next calculus is determining how many (and what kind of) specialists you’ll need. The answer is about 600-900 for this population. Keep the ratio of specialists at 2-3/1 for PCP’s and you will have enough pathology to make the economic model for work for all. The array of specialties can be determined by looking at the Graduate Medical Education Advisory Committee or “GEMENAC” study , which showed the population required to sustain specialty -and primary care, for that matter- physicians. Those of us who do this for a living also have certain “rules of thumb”, such as it takes about 6 PCP’s functioning at median productivity level (3700 OPVs/year) to keep a Gastroenterologist busy and about 10 to keep a non-invasive Cardiologist busy, and so on. From those numbers we know it takes 8-10 non-invasive Cardiologists to keep one Interventionalist or EP Cardiologist busy and double that to keep a Cardiovascular Surgeon happy (if that’s even possible!).

Unfortunately, life isn’t that simple. Chances are, unless you are in a rural community with no competition, you will have to take into account the “other fella,” as they say in the military. You are not taking the field unopposed. Therefore, the next step is to gather data on your physician market and determine how many and what kind of physicians are already in your TSA, which ones are loyal to you and which ones are aligned with your competitor(s).

Then it gets interesting.  If you are in South Central Texas, which has a severe primary care physician shortage, you can probably safely recruit young physicians right out a training and expect them to fill up in 9 months or less and not bankrupt you. Try that in a market that is saturated, and you may spend up to $500,000 before that PCP fully ramps up- if ever! That’s a very expensive way to build a system.

The specialty network physician needs assessment principles still will apply. Try to keep that ratio between 2 and 3/1.  Otherwise the “rat theory” will come into play (When there is enough cheese to eat, the rats eat the cheese. When there isn’t, the rats start eating the other rats). Then you get a fractious, dysfunctional medical staff who will start looking for other sources of income to support themselves– and we know where they will find it– by competing with you for ancillaries.

If you are merely trying to fill beds and match your capacity to your supply, that is also a fairly straight forward math equation. If you are a 300 bed hospital with an average census of 250, you need to fill 50 beds X 365 days or 18,250 bed-days. Each PCP- again, functioning at median level- will probably generate 80 discharges with an ALOS of 4-5 days (or 320-400 bed days). So you take which ever number your physicians currently practice (by looking at your community experience) and divide the 18,250 by that number. This shows you will need somewhere between 45 and 57 additional PCP’s to fill those beds. Back to your supply demand data- in Texas you can just recruit those new docs right out of training or from outside your market. In more competitive and more saturated markets, you will need to develop a sales/outreach network development process to identify which physicians you may want to attract to your system, what sorts of physician alignment arrangements you and your in-house legal counsel or outside legal advisors are comfortable offering and what resources you are willing to invest in this daunting and potentially risky process. As far as the specialists, don’t worry about them. If you attract the PCP’s who bring or grow your market share and covered lives- the specialist will follow! The only exceptions to that statement is if you have “holes” in your service line- either quality or access problems – that need to be addressed.  That can be determined by leakage data analytics.

Finally, if you are in a position to become the “Mayo Clinic” of your region, that is a completely different challenge and has more to do with quality, cost, access, service and relationship building with surrounding hospitals and physicians. If that doesn’t work, you might need to build remote ambulatory medical centers to send your specialists out into those communities to capture those referrals. That is an EXTEREMELY capital intensive campaign and could risk ALL the referrals from the outlying communities. Not something to be taken on lightly.

04 How Many Doctors Do I Need, and What Kind?

From “Leakage” to “Keepage”: The Conversation

December 26th, 2012 § Leave a Comment

This is a post by Dr. Tim Crowley, Vice President of Physician Network Services at Kyruus.

After reading my introductory leakage post, hopefully you’ve looked at your data to figure out the “who/what”, and planned a time to sit down with your physicians (one-on-one, practice-by-practice), to find out WHY they are referring out of network.  By asking, you will only strengthen your organization – so give yourself a pat on the back for planning, and let’s get ready to talk logistics.

Who should do this work of searching for the “why”? Who can sit down with the physicians and figure this out? And how do you actually frame the question?

Well, you need someone who has clinical credibility, who is trusted by the physicians and who knows how to approach and engage them productively. As I mentioned before, you don’t accuse, imply disloyalty, and perhaps most importantly, never get defensive when you hear the answers, accurate or not. Also, be sure to get out of the bunker and go see them yourself in their office.  Don’t call them up to “Mahogany row.”

So, here’s how the “why” conversation might go:

“Doctor, we were reviewing our referral (or “Patient Retention,” if you prefer) data and noticed that you send a lot of XX patient care (specialty, imaging, inpatient, etc) out of the system, WHAT ARE WE DOING WRONG?”

Prompt further conversation by asking:

“What does our competitor do better? How do they make it easier? What do you hear from your patients about us or them, which lead you to believe that their care is better, their system is easier?”

Then LISTEN! If they trust you and your questions are sincere, they will give you the “why” you are looking for.  And remember (as they say in retail): The customer is always right!

After listening, you’ll need to determine if what you have just heard has any merit, or is simply due to ignorance. The referring physician may not know you have an EP specialist. They may not know the mortality of open-heart surgery at your competitor is twice as high as yours. Show them the data. Educate them about your services and specialists. Ask them whom else they respect in the system,  see if those physicians are referring to your hospital, and show them that data as well! Have those doctors TALK with them about what you have to offer.

Your conversations may have taught you a few lessons you weren’t ready to learn. The list of unexpected answers you weren’t prepared to hear could include:

1. LACK of a service you assumed you could provide

2. LACK of a qualified and QUALITY specialists you assumed you had on staff

3. LACK of higher quality and better outcomes- real or perceived- that you assumed you were providing at your facilities and you thought differentiated your systems from your competitors.

You may make some additional discoveries along the way, like, remember that really cool patient scheduling system you bought that you thought worked really well? Guess what? It is cumbersome, hard to use and much slower than the for-profit MRI vendor down the street or WORSE, the scheduling system your COMPETITOR hospital just purchased.

Oh, and that “Call center” or “Physician Finder” or other “solution” that someone sold you to help with this specific issue? Well, none of that works either, and  no one told you.  Why would they? The success of the whole system only depends on it!

Think of it this way: If you are a $1 billion system, with 50% leakage, you are really a $2 billion system- you just have 50% Leakage! If you can move the needle by 1%, it would result in a $20 million increase in revenues! (1% of the $2 billion generated by the patients in your system) Most of that should drop right to the bottom line, since hospitals are a fixed overhead business. That’s an instant 2% margin for every 1% reduction in leakage!  What would you be willing to pay for that?

Remember, you need to fix this problem NOW! Leakage in the current Fee For Service payment scheme is tragic. In the upcoming Fee For Value/Global Payment /Risk based Capitated system, which appears to be on the horizon- IT IS FATAL!

04 From Leakage to Keepage: The Conversation

Leakage: Aid and Comfort to the Enemy?

December 19th, 2012 § Leave a Comment

This is a post by Dr. Tim Crowley, Vice President of Physician Network Services at Kyruus.

 

Imagine you are a King in Medieval times, and your fortress is under siege by an invading force. You have planned for this by building up more provisions of food and water for your people than your opponent could possibly bring to the battle. As the height of the siege, you make a both terrifying and mystifying discovery: Your own people are sending food and water out to your enemy! 

This is the situation many hospital CEOs face every day when they review data revealing their own physicians– for whom they provide enormous “support” (read subsidies to cover losses), and whose very own paycheck depends on the revenues that specific system was expecting their patients to generate– are referring out of network. This is leakage in its purest form.

So how do you manage this problem?

The first thing you need is data, something most systems possess (in varying degrees of accuracy and “actionability”). It can be gathered and tracked internally, acquired from payers, data vendors and some cases, directly from the states that monitor and sell Physician identified data (see accompanying list).

Once you’ve determined who is leaking, what they are leaking and where they are leaking to, the next task is to determine WHY these physicians are referring cases out of the system. Then, and only then, can the strategy for dealing with this incredibly exasperating problem be formulated and  implemented.

Figuring out the “WHY” requires one-on-one, practice-by-practice, or direct meetings with small groups or “Physician Pods,” to ask why physicians are referring out of network.

Warning: This question needs to be posed in the right way so you don’t make the problem worse. Also, the answers to this question may be quite humbling…

Remember, this is not a time to investigate, castigate, regulate or humiliate. It is an opportunity to ENGAGE with your physician staff, to LEARN about your system and find out why they refer patients away from your facilities and specialists.

The answer(s) to the “why” will become immediately (if not painfully) clear.  They may include:

1. Ignorance of services that you currently provide and assumed ALL knew about.

2. Ignorance of specialists who are on staff who provide services you assumed ALL knew about.

3. Ignorance of the quality and better outcomes of the services you provide and assumed ALL knew about

The  current generation of Primary Care Physicians, who now or at some time in the past made rounds on their inpatients before hospitalists came along, knew SOMETHING about your hospital and your specialists. However, as this generation  approaches retirement, replaced by the new generation of PCP’s (who never darken your door), this problem will only get worse.

Unless you ACTIVELY PROMOTE, INTRODUCE and EDUCATE your referring physicians about the services and specialists in your market, THEY WILL HAVE NO WAY OF KNOWING WHAT YOU CAN DO FOR THEM AND THEIR PATIENTS. (IF IT SOUNDS LIKE I AM SCREAMING, IT IS BECAUSE I AM!)

04 Leakage: Aid and Comfort to the Enemy?

What’s Your Gorilla?

December 12th, 2012 § Leave a Comment

This is a post by Dr. Tim Crowley, Vice President of Physician Network Services at Kyruus.

 

How important is perception? Prioritization? Taking a step back? Incredibly.

 

I recently attended a conference where the moderator presented a famous video of a group of people passing basketballs to each other. The group was asked to count the number of times the basketballs were passed back and forth. In the middle of the exercise, a person in a gorilla suit walks through the room in the video. Afterwards, when the group was asked about the number of passes, one person raised their hand  and asked, “What about the gorilla?”

Over two thirds of the group asked, “What gorilla?” Some insisted there was no gorilla at all, and even accused the moderator of showing two videos!

The point, of course, is that if you are too focused on one thing, you could be missing the real threat to your organization. That’s your gorilla.

Personally, I have seen at least three classic examples of this in Healthcare over the last five years:

1. Large Academic Medical Center in the Northeast proudly announces opening of $400 million,  state of the art Cardiovascular tower. Meanwhile, 1,000-provider physician group responsible for 17% of their discharges announces change of affiliation to competitor across the street.

2. Large National For Profit Hospital Management Company gathers its senior management to review 700 hours of physician interviews about “how they are regarded by their employed physicians.” Consulting firm opens the conference with the following statement to the eager crowd: “Let me give you the Executive Summary. Your physicians hate you and they think you suck.” If I hadn’t been in the room to hear it myself, I’m not sure I would have believed it.

3. Faith Based System in the Northeast turns around $50 million operating loss into $30 million operating gain in one year. Market crashes and old Defined Benefit Retirement Plan’s unfunded liability triples. Game over. Private Equity Firm buys system.

So, while you, the hospital administrator, are totally consumed by the installation of your new EMR, or your brilliant new E.D or your aggressive new quality improvement and cost containment projects, you might want to look around and see if there any gorillas are in the room.

Here are two “gorillas” that can pose an existential threat to your organization:

1. Lack of a dynamic, effective ONGOING Physician Network Development program. Our proprietary physician tracking data shows that over 1% of physicians move EVERY MONTH. 12-15% change location, leave their practice or move to a different system every year. In addition, a whole generation of Primary Care Physicians is approaching retirement in the next 5-10 years. Without the information to identify those likely to leave and a comprehensive succession plan to help recruit new physicians to care for those patients, you could lose significant market share. If you are not actively engaged with your physicians to build your physician network, you are probably already losing more than you are gaining.

2. Patient outmigration, or “leakage”. There is nothing more exasperating to the senior management teams at healthcare organizations than to see huge numbers of referrals go out to other organizations by their own physicians. What’s the point of creating and supporting a physician network if they aren’t willing to support your organizations and keep the care of their patients at the hospitals where they practice? Understanding why they are referring out is critical to fixing the problem.

Kyruus Physician Network Services can help your organization with both of these challenges. We have the tools and services to help you build, train and operate an effective Physician Network Development program and a Referral Management System that will help you promote patient retention.

04 What’s Your Gorilla?

There is a new standard for what you need to know about your hospital and physicians

August 22nd, 2012 § Leave a Comment

This is a guest post by Yusuke Yagi, Market Solutions, Kyruus

The concept of “public exposure” is now a key driver of how many of our clients are thinking about their physician network management policies, programs, and technology systems.  As the call for transparency in healthcare gains momentum, the number of public databases with information on physicians’ professional activities and outside relationships continues to grow at a fast clip, while the potential regulatory and media exposure for healthcare organizations grows commensurately.  For instance, the new NIH Financial Conflict-of-Interest (FCOI) policy goes into effect on August 24, and with it comes the need to monitor and manage any publicly-reported significant financial interests (SFI) amongst NIH-sponsored researchers that could expose an institution to regulatory scrutiny.

In this competitive and financially-constrained healthcare environment, these dynamics pose critical challenges to physicians and healthcare providers.  Physicians also potentially face high administrative costs associated with monitoring and managing their public disclosure profiles, which creates an opportunity for hospital and health system administrators to provide valuable, time-saving services to their staff to help deal with these issues.

To dig into the sentiment amongst providers about these points, we surveyed 100 practicing physicians to ask them not only what they thought about the public disclosures of life science company payments that are out there about them, but also what they would do if they found that data to be inaccurate, and what they would expect hospital administrators to do to help them deal with all this.

Our survey found that errors in publicly-disclosed payment data, as well as the role of hospital employers and affiliates in the management of those data, are top of mind for physicians.  We began by inquiring about general concern around industry interactions being disclosed in the public domain and found that 42% of physicians are very concerned or concerned about this.

“With the implementation of the PPACA Sunshine Provisions, physicians’ financial relationships with industry will be disclosed publicly on a government website.  How concerned are you about industry interactions being disclosed and reported in the public domain?”

data concern 300x155 There is a new standard for what you need to know about your hospital and physicians

To dig deeper into the issue, we qualified the question to cover the issue of accuracy of these data.  What we learned is that doctors answered this question dramatically differently.  If publicly-available data are found to be false or incorrect, 87% of physicians would be very concerned or concerned.

“How concerned would you be if you discovered that publicly-disclosed information from an industry source is false or incorrect?”

data errors 300x150 There is a new standard for what you need to know about your hospital and physicians

It’s not surprising that physicians have such a high degree of sensitivity for inaccuracies in the public data.  Reputation is of critical importance in the field of medicine, and data errors in the public domain may be misleading to patients and other interested parties.  In fact, the survey found that over 75% of physicians expected their hospital employers and affiliates to play a role in helping to identify and resolve these errors in public data, and 87% said they would value pre-population of their standard conflict-of-interest disclosure systems with data dynamically mined from the public domain.

“Do you want your compliance office to find and bring to your attention your publicly available industry interaction information?”

compliance role 300x174 There is a new standard for what you need to know about your hospital and physicians

 

“Would pre-population of publicly available data in your disclosure system be helpful to you? ”

prepopulation 300x167 There is a new standard for what you need to know about your hospital and physicians

About 90% of physicians report having financial relationships with life sciences manufacturers (everything from meals to drug samples to consulting arrangements).  Our estimates tell us that between one-fourth and one-third of those interactions are represented in public data today, but that statistic will grow to over 95% under the PPACA Physician Payment Sunshine Act, set to begin in 2013.  That means it’s not only the “academic physicians” at large research-oriented institutions who are being affected by this; we currently see many of our community hospital partners struggling with the same issues, at comparable scale to their academic counterparts.

Public data disclosure and accuracy have serious implications for the hospitals and health care systems that either employ or provide privileges to physicians.  Rightfully so, doctors are looking to their administrators to assist in the monitoring and management of those discrepancies, so that they can focus on their core jobs as clinicians and researchers.  This presents an opportunity for hospitals and health systems to engage with their physician network on this important issue. Through the provision of data monitoring, dispute management, disclosure system pre-population, and reporting services to physicians, administrators can both help maintain the credibility, reputation, and peace-of-mind of their staff, as well as reduce their administrative overhead so that they can focus on what is most important – practicing medicine and performing innovative research.

Interested in learning more about the survey? Download the Perspectives Whitepaper for more details.

04 There is a new standard for what you need to know about your hospital and physicians

Conflict-of-interest (COI) Policies: Drawing Some Lines in the Sand

August 9th, 2012 § Leave a Comment

As healthcare’s regulatory landscape continues to change in unprecedented ways, significant financial interests and potential commercial conflicts held by physicians are garnering much attention and scrutiny. A recent Wall Street Journal article underscored the significance of potential reputational risk of physician-industry relationships by detailing the payments made by GlaxoSmithKline to a high-profile celebrity doctor that surfaced as the result of the recent record-setting settlement with the DOJ.   In addition, the DOJ has stepped up its scrutiny of medical device implantations due to concerns of over-utilization and medical necessity, and the surgeons performing those cases may have significant relationships with the manufacturers of those products – oftentimes for very good reasons (collaboration to invent new products and conduct innovative clinical trials), but sometimes under-managed, nonetheless.

At Kyruus, we use Big Data and analytics to solve a host of health care challenges, and with many of our hospital and health system clients, we are currently tackling this hotly debated topic of conflict-of-interest management.  While technology can play a central role in COI management, establishing and communicating the right policies clearly and effectively to medical staff members, AND providing them with efficient, well-defined processes to maintain compliance, are equally essential to the success of a program.

To better understand how institutions have traditionally handled conflict-of-interest management, the team here at Kyruus recently conducted an analysis of a set of publicly-available hospital COI policies to evaluate the commonalities across institutions.  Our team sampled COI policies from 22 institutions across all major geographic regions of the country, and parsed out the individual provisions that were addressed by each institution.  For instance, did the institution have a provision covering the management of gifts from life science representatives?  Did the institution have a monetary threshold for requiring disclosure to the compliance department?  The graph below depicts the percentage of institutions that addressed specific provisions in their COI policies.

COI Policy Conflict of interest (COI) Policies: Drawing Some Lines in the Sand

While some provisions were consistently addressed across the board, others were less systematic.  For example, consider the “no samples” policy provision – only 6 out of 22 institutions had a policy in place that prohibited physicians from taking samples from pharmaceutical and medical device companies.  Despite the fact that this topic has grabbed the attention of both physicians and pharmaceutical companies, as discussed in a recent AMA article that states that 23% of doctors refuse samples, it appears that institutions may not be providing enough policy guidance to physicians to be able to deal productively with this issue.  Another interesting finding from our study is that only 9 out of 22 institutions provided guidelines for on-site presence of life science industry representatives.  While institutions are entitled to set their own policies, the Office of the Inspector General (OIG) provides useful guidance on its website for physicians on this topic.

In addition, 15 out of 22 policies reviewed did not have a provision requiring an annual COI disclosure report.  The low percentage is not shocking considering the functional challenges involved in operating and maintaining a robust annual disclosure process.  Many institutions struggle with the handling of disparate siloes of physician data, multiple hospital departments who care about different aspects of industry relationships, and even the basic maintenance of staff lists that would be required to support a regular annual COI disclosure process.  However, in this day and age of transparency, where more data about physician-industry relationships are being pushed into the public domain, it is imperative for institutions to maintain a single source of truth of their physicians’ professional activities and industry relationships so that they are not caught by surprise when public scrutiny hits their organization.   Programs such as the Pew Prescription Project are addressing this issue in their work, conducting research to help institutions create pragmatic policies.

What do these findings mean, and more importantly, what’s next?  As we move forward in defining the “best practices” of COI policies and COI management programs, there are a number of future events to consider.  Perhaps most relevant is the Physician Payment Sunshine Act (PPSA), which will exponentially increase the amount of physician-industry interaction data available for public review by outside stakeholders.  Physicians, life sciences companies, and teaching hospitals have expressed concern to CMS about the daunting task ahead: ensuring the accuracy and appropriate contextualization of these interaction reports.  Only with state-of-the-art data integration, disambiguation, and analytics platforms will organizations and individuals be able to effectively manage this deluge of potentially controversial information.

Another policy of relevance is the new NIH FCOI regulation, going into effect on August 24, which creates a new burden for institutions to proactively identify, manage, and respond to public requests for disclosure of significant industry relationships amogst individuals involved in federally-funded research.   Again, without the ability to apply real-time analytics to identify potential areas of risk across large populations of physicians and researchers, institutions may struggle to comply with these stringent laws.

Our clients are already beginning to take advantage of the insights generated through this COI policy analysis, as well as leveraging our national benchmark database of physician-industry relationships to project the operational burden that their organizations will face under these new laws.   Are you facing similar issues?   We’d love to talk – please contact us to schedule some time with our subject matter experts and we’ll review these learnings in more detail.

Photo by kyknoord

04 Conflict of interest (COI) Policies: Drawing Some Lines in the Sand

Disclosure, Cost and Technology

June 28th, 2012 § Leave a Comment

This is a guest post by Jeff Gold, Solutions Architect at Kyruus

As the costs of health care continue to rise, demand for transparency and better oversight of physician interactions with industry is mounting. Transparent Innovations has closely covered progress on the Sunshine Act and recently, Iowa Senator Chuck Grassley challenged the National Institutes of Health (NIH) over the award of a research grant to a physician who had previously been identified for failing to disclose an industry relationship while working on a federal study. As we’ve reported before, institutions applying for or receiving NIH funding must be in compliance with more stringent financial conflict of interest requirements no later than August 24, 2012.

For institutions, complying with new regulations is costly. According to Doctor Kristy Weber, chair of the Council on Research and Quality at Johns Hopkins, lowering the NIH monetary thresholds from $10K to $5K, “will greatly increase paperwork for many individuals and institutions.” There certainly isn’t a shortage of viewpoints on the Sunshine Act either. Proponents say any transparency is a good thing, regardless of cost while others believe the high price of compliance outweighs the usefulness of the data.

The Trade Off Between Productivity and Transparency

Using a traditional manual process, an institution naturally faces a trade-off between productivity and transparency. Why? Because the most productive environment is one where no time is spent on administrative tasks. That’s obviously not possible in this environment of increased transparency. Similar to a zero-sum game, the more time spent of transparency, the lower the productivity as shown in the graph below.

blog tradeoff1 300x227 Disclosure, Cost and Technology

 

There is a better way

Complying with increased transparency and disclosure requirements while mitigating costs is possible with better technology. We know that stakeholders in the healthcare system will need to manage these relationships to allow for high productivity and high transparency. In the end, physicians and industry will need to work together to collaborate and preserve innovation. With technology, we can achieve both. We can shift the curve.

blog better 300x231 Disclosure, Cost and Technology

 

 

 

 

 

 

 

 

There has never been a better time for information technology to address these problems. Software development as a practice has been maturing and three changes offer reason for optimism.

First is the importance of user experience. Google, Apple and other companies have raised expectations. Design advice from experts like Steve Krugg and Jakob Nielsen is being embraced. Programmers are better equipped to eliminate the tedious parts of data entry and to provide intuitive applications that are easy to use.

Second, Big Data technology is breaking down previous silos and allowing better business insight than previously possible. Analytics provide meaningful results and business users are able to continuously refine results until the desired outcome is reached.

Third, companies that deliver software are more nimble and customer focused than ever. Large, inflexible corporations have given way to small, vibrant companies that delight their customers.

There will always be obstacles to adoption in a market as complex as health care. Many ideas and companies that seem promising will fail. But some may make health care more transparent without compromising its ability to learn from industry and grow. At Kyruus, we hope to be part of that.

04 Disclosure, Cost and Technology

May Flowers Bring Sunshine Letters

May 24th, 2012 § Leave a Comment

Multiple letters between the senators that authored the original Physician Payments Sunshine Act and CMS have recently added clarity to the timeline for the final rule and when data gathering is likely to start in earnest. As part of the Patient Protection and Affordable Care Act (PPACA), the Sunshine Act was supposed to be finalized last October with data gathering slated to begin in 2012. As that date slipped and a comment period was opened early in 2012, it became clear that any data gathering this year was going to be difficult to achieve.

In April, Sen. Chuck Grassley and Sen. Herb Kohl sent a letter requesting an update on the status of the final rule. The letter voiced their desire for CMS to “be clear on guidelines and context so that the data posted online is meaningful and understandable”. The senators also recommended swift action on finalizing the rule. A suggested deadline of June was proposed so that data gathering could still be performed this year.

Acting Administrator & Chief Operating Officer of CMS, Marilyn Tavenner, responded to the senators in early May. Her letter outlined some reasons for the delay and positive steps that CMS has taken on implementing the final rule.

  • CMS received over 300 comments earlier this year and is working to address these. Comments from various stakeholders are being taken into consideration and will be represented in the final rule.
  • A working group has been established of both technical and policy staff to assess the resource requirements for full implementation.
  • The notion of data gathering in 2012 has been eliminated. The earliest data gathering will be required is January 2013.
  • CMS provides more information on a web page titled, Affordable Care Act in Action at CMS.

If the timeline of a final rule in the fall, followed data gathering early next year sounds familiar to anyone tracking progress on the Sunshine Act, it should. When the rule is finalized at the end of this year, it will be almost exactly a year delayed from the timeframe outlined in the PPACA, which originally called for a final rule in October of 2011 with data gathering to begin on Jan. 1 2012. That might not be such a bad thing given that some recent surveys show that more than half (56%) of physicians surveyed are concerned about the Sunshine Act. Clearly there is more education work necessary to get physicians more comfortable with the transparency that the Sunshine Act promises.

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04 May Flowers Bring Sunshine Letters

Administration Pledges $200 Million For Big Data

April 9th, 2012 § Leave a Comment

This is a guest blog by Katie Dixon, Market Solutions Associate at Kyruus

The Obama Administration is investing big time in big data.  On Friday, March 30, the Administration’s Office of Science and Technology Policy (OSTP) launched a $200 million, multi-agency effort titled the “Big Data Research and Development Initiative.”  Fundamentally, the initiative’s mission is to highlight and create public-private partnerships in big data.  The Administration is inviting industry, research universities, and non-profits to join forces and make the most of the opportunities created by big data.  To view the announcement, click here or you can view the streaming video webcast.

While the initiative launches six new agency efforts, numerous agencies are already involved in the big data revolution including the: Department of Defense (DOD), Department of Homeland Security (DHS), Department of Energy (DOE), Department of Veterans Administration (VA), Department of Health and Human Services (HHS) and National Security Agency (NSA), among others.  These agencies administer some of the most fundamental aspects of the American public’s life.  For more detail, check out the official Big Data Fact Sheet.

The Implications

What can we infer from the announcement?  The initiative is an institutional precedent for big data as a discipline.  In a sense, the federal government is legitimizing a practice that science and commercial companies have benefitted from for years.  This is huge.  One can extrapolate that big data is moving from an introductory/pioneering stage to a growth stage in its commercial life cycle.  Big data is legit, it’s commercially viable and it can help the public live better.

A Call To Action

The announcement last week was designed to spur action.  Now is the time for academia, corporations, NGOs, associations, foundations, governments and everything in between to step forward and make things happen.  Collaboration is the key to identifying opportunities, inventing better products and systems, and reducing costs.  The Administration knows that no one actor individually can address the biggest issues facing our citizenry.  Together, however, possibilities are endless.

If you are interested in learning more about the announcement and big data initiatives, here are a few links.

Why Science Really Needs Big Data
Feds Launch Big Data Initiative to Advance Science
Why Big Data is a Magnet for Startups

Photo by James Vilija

 

 

 

 

 

 

04 Administration Pledges $200 Million For Big Data