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25 posts from April 2012

April 27, 2012

ICD-10 Implementation Delay Announced for One Year to October 1, 2014

Kick The Can
The Department of Health & Human Services (HHS) officially proposed delaying the ICD-10 deadline by an extra year to Oct. 1, 2014 this past week.  ICD-10 is an update and expansion of diagnosis and procedure codes that are widely used in medical billing, as well as for research and other purposes.  

The ICD-10 compliance date change is part of a proposed rule that would adopt a standard for a unique health plan identifier (HPID), adopt a data element that would serve as an “other entity” identifier (OEID), and add a National Provider Identifier (NPI) requirement.  The 10th iteration of the disease-classification system will expand the number of codes in use from around 18,000 in the current ICD-9 code set to about 140,000. 

HHS also released a proposed rule establishing a unique health plan identifier with a standard length and format under the Health Insurance Portability and Accountability Act (HIPAA) that would make it easier for doctors, hospitals and health insurance companies to identify patients and issue payments for treatment.  By standardizing the length and format of the health plan identifier, healthcare provider offices will be able to automate and simplify their processes, particularly when managing bills and other transactions. 

Currently, health plans and third-party administrators, such as bill providers, are identified using a wide range of different identifiers that do not have a standard length or format.  The variety of formats causes a time-consuming problems, such as misrouting of transactions or even the rejection of bills by payers due to ID errors.  With the new identifier, insurers could avoid multiple identification codes they currently use to identify themselves, including taxpayer identification numbers, employer identification numbers and proprietary codes, reported LifeHealthPro

“The new health care law is cutting red tape, making our health care system more efficient and saving money,” Sebelius said.  “These important simplifications will mean doctors can spend less time filling out forms and more time seeing patients.”  

The proposed rule was developed by the Office of E-Health Standards and Services (OESS) as part of its ongoing role, delegated by HHS, to establish adopt standards for electronic health care transactions under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).  OESS is part of the Centers for Medicare & Medicaid Services (CMS).  Public comments are due in thirty days, and should include the docket reference CMS-0040-P. 

With the proposed rule, HHS follows through on its promise in February to delay the ICD-10 compliance deadline.  The agency said that postponing the deadline allows providers and insurers additional time to prepare and test their systems “to ensure a smooth and coordinated transition among all industry segments,” reported Computer World

The delay is “an attempt to give people some ability to reprioritize,” because providers and insurers also must comply with multiple reform law requirements such as implementation of electronic health records, Kaveh Safavi, an Accenture managing director, told The Wall Street Journal Health Blog

HHS Secretary Kathleen Sebelius said the identifier rule would cut "red tape" and save the industry $4.6 billion over the next 10 years. 


On January 16, 2009, HHS published a final rule to adopt ICD-10 as the HIPAA standard code sets to replace the previously adopted ICD–9–codes for diagnosis and procedure codes (see HIPAA Administrative Simplification;  Modifications to Medical Data Code Set Standards to Adopt ICD-10-CM and ICD-10-PCS,  74 FR 3328). The compliance date set by the final rule was October 1, 2013. 

Implementation of ICD-10 will accommodate new procedures and diagnoses unaccounted for in the ICD-9 code set and allow for greater specificity of diagnosis-related groups and preventive services.  This transition will lead to improved accuracy in reimbursement for medical services, fraud detection, and historical claims and diagnoses analysis for the health care system.  Many researchers have published articles on the far-reaching positive effects of ICD-10 on quality issues, including use of specific reasons for patient non-compliance and detailed procedure information by degree of difficulty, among other benefits. 

Some provider groups have expressed serious concerns about their ability to meet the October 1, 2013 compliance date.  Their concerns about the ICD-10 compliance date are based, in part, on implementation issues they have experienced meeting HHS’ compliance deadline for the Associated Standard Committee's (ASC) X12 Version 5010 standards (Version 5010) for electronic health care transactions.  Compliance with Version 5010 is necessary prior to implementation of ICD-10. 

All covered entities must transition to ICD-10 at the same time to ensure a smooth transition to the updated medical data code sets.  Failure of any one industry segment to achieve compliance with ICD-10 would negatively impact all other industry segments and result in rejected claims and provider payment delays.  HHS believes the change in the compliance date for ICD-10, as proposed in this rule, would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition among all industry segments.  

Delaying ICD-10 compliance has elicited a mix bag of reactions.  Insurers are woefully unprepared to meet the previous deadline, which was set for this October, but some experts have predicted that a one-year delay would be costly and do nothing to improve readiness for the implementation.  American Health Information Management Association CEO Lynne Thomas Gordon has opposed the ICD-10 deadline delay. “I'm scared there will be lost momentum,” she told InformationWeek Healthcare.

In addition to this announcement, CMS last month extended the March 30, 2012 deadline for eligible professionals (EPs) to file their "eligibility" appeals under the electronic health record (EHR) incentive program.  The deadline is now April 30, 2012

“An eligibility appeal allows a provider to show that all the requirements for the Medicare EHR Incentive Program were met and that he or she should have received a payment but could not because of circumstances outside of the provider's control," CMS said in its April 3 announcement. CMS didn't divulge why it opted to extend this deadline. 

The deadline extension only applies to eligibility appeals.  It does not affect "Meaningful Use" and "incentive payment" appeals, for which the deadlines differ based upon when the provider receives notice regarding a payment or attestation issue from CMS.

CMS has selected Provider Resources, Inc. of Eire, Pa., to hear administrative appeals, with support to be provided by CMS' Office of Clinical Standards and Quality (OCSQ). Opinions of appeals will be posted on OCSQ's website. 

CMS affords providers with a two-level appeal process: an informal review and a request for reconsideration. Within the two-level appeal process, there are three types of appeals that can be filed in the Medicare EHR Incentive Program: (1) eligibility, (2) meaningful use, and (3) incentive payment appeals.  

Detailed guidance on the appeals process and additional information on all of the appeal types are available on the OCSQ website.


This is perhaps the first of several delay’s we will see in implantation.  According to one expert on electronic medical records and health systems, there could be at least two to three one year delays before ICD-10 is finally implemented.    ICD-11 is expected to be released sometime in the next couple of years, so this could easily morph before we adopt a new coding system.

April 26, 2012

Continuing Medical Education: ACP Looks at New Models to Achieve Quality Improvement

Quality Improvement
A recent article from the American College of Physicians look at new models of continuing medical education (CME), which seek not only to impart knowledge but to change physicians’ behavior and even play a role in facilitating organizational improvement.  These CME models thus share some of the same basic goals as the field of quality improvement (QI), namely behavioral change and systems redesign to improve patient outcomes. 

The article provides some practical ideas about how CME providers and QI experts may beneficially integrate these two fields.  The article outlines several models for harnessing the existing engagement in traditional CME to achieve the goal of equipping practitioners with knowledge and skills related to QI, while also addressing the widely recognized problems with traditional CME. The authors touch on possible incentives to make such integrated models of CME and QI attractive to practitioners. 


Physicians acquire new knowledge and skills and, thus, improve patient care by participating in CME.  As we have noted several times, CME has positive outcomes on physician practice and patient outcomes, with positive results usually associated with multiple teaching methods that incorporate interactive engagement of learners.  Despite success, some have called for major reform of CME, including the development of new models that emphasize more active participation than traditional didactic formats, promoting self-directed learning on topics relevant to participants’ routine practice. These new models of CME seek not only to change behavior but to play a role in reorganizing care to improve patient outcomes. 

The burgeoning field of quality improvement (QI) similarly seeks to improve patient care through reorganizing care delivery and changing physician behavior, however, “CME programs still rarely teach principles of QI, and most practicing physicians remain unfamiliar with them.”  Reviews of CME literature highlight the lack of relevant conceptual models for influencing behavior as the explanation for why so few programs change practice or improve outcomes. One recent framework sets CME in the context of a complex adaptive system in which many aspects of practice environments, along with appropriate resources, must be aligned to sustain changes in physician behavior. 

In response to the limitations of traditional formats, the scope of CME has broadened to include audit and feedback, opinion leaders, multifaceted interventions, reminders, and other more novel approaches. Online CME is also increasingly common.  However, a recent meta-analysis of more than 200 studies found that Internet-based education had similar effects as traditional CME on knowledge and skills and only modest effects on patient outcomes. Overall, designing and implementing CME programs that foster changes in practice patterns and improved patient outcomes remains challenging. 

From the beginning, the QI field has focused on improving patient outcomes by directly affecting physician behavior or redesigning practice systems to foster reliable delivery of optimal processes of care.  Yet, despite widespread attention to health care quality over the past decade, the language, goals, and tools of QI remain foreign to many physicians.  A national survey published in 2005 reported that only one third of physicians had ever undertaken QI projects in their practices. 

While the American Board of Medical Specialties has made practice improvement a requirement for maintenance of certification for more than a decade, the practice improvement component remains a new and frequently challenging experience among candidates for recertification. Many physicians remain unequipped to engage in improvement activities in their practices. 

CME and QI 

A growing number of educational efforts impart basic concepts and methods of QI to practitioners and trainees.  Successful programs have adopted principles of adult learning, combining experiential learning with didactic sessions.  The best outcomes are when learners received individualized coaching, performance data, or process improvement tools, such as educational material for patients and decision support for clinicians.  However, educational efforts to teach QI to clinicians have remained largely restricted to academic or large health systems. Engaging community-based physicians in learning QI occurs less frequently and poses greater challenges. 

While physicians face quality problems in their practice, most physicians are unlikely to participate in a CME program that is explicitly focused on QI methods.  As a result, the authors suggested that exposure to and participation in QI activities be embedded in CME focused on clinical content areas.  Accordingly, the article outlined models with 4 levels of increasing ambitiousness and physician engagement. The lower levels are less resource-intensive and can be implemented relatively easily within traditional CME programs.  The higher levels require resources and infrastructure to support the experiential components. 

  1. 1.    Highlight Clinical Areas With Quality Problems in Traditional CME 

Attendees at CME conferences seek to update their knowledge of a particular disease or specialty area.  The topics covered at such conferences overwhelmingly consist of new treatment methods (drugs or devices) and advances in diagnostic technologies. However, other topics present important clinical information while also delivering content related to health care quality.  For instance, a diabetes CME program, in addition to covering recent developments with new classes of drugs and technologies, can include sessions designed to improve patient outcomes by optimizing reduction of cardiovascular risk factors or assessing and managing comorbid depression. Programs can also present practical strategies for recognizing the need to intensify glycemic control.  These topics do not teach QI skills per se, but they promote attention to clinical issues involving well-documented gaps in quality for patients with diabetes.  This approach can be applied to CME programs tailored for both generalists and specialists. 

  1. 2.    Explicitly Add QI Content in CME on Specific Clinical Topics

While highlighting gaps in quality represents a reasonable start, physicians need skills to act on this information.  CME programs on clinical topics could include sessions that show participants how to identify quality gaps in their own practices and cover specific methods to address these problems.  For example, a program on diabetes could teach chart auditing focused on key processes of care or the adequacy of glycemic control. 

The material could include examples of common reasons for suboptimal performance and outline strategies for addressing these problems.  Where evidence supports specific improvement strategies—for example, some forms of case management for diabetes and heart failure clinics—sessions may focus on practical aspects of implementing these strategies. With this approach, participants would learn specific tools to implement QI in the context of acquiring new knowledge on clinical topics that interest them. 

  1. 3.    Supplement CME With Postevent Deliverables 

Postevent deliverables, such as submitting results of QI projects after a CME course, would provide physicians with experience in applying QI in their own practices.  For example, participants in a course on diabetes may learn about structured practice audits focused on evidence-based performance measures and strategies to address quality

gaps identified in the audit.  After the CME program, participants could conduct audits in their practices, develop improvement plans, and potentially submit their plans to CME providers.  Such activities could be aligned with maintenance of certification so that participants receive credit for a component of the recertification process. This approach requires further investment of physicians’ time but has the advantage of truly engaging physicians in QI activities in their own settings. 

  1. 4.    Embed CME Activities in Larger QI Initiatives 

Coordination of CME with larger-scale QI initiatives offers another potential strategy to engage physicians.  For instance, a specialty organization could target a particular quality problem and develop a multi-component QI strategy that integrates CME with online best evidence resources, toolkits related to specific improvement strategies, and the establishment of learning communities for physicians to share their experiences as they try to implement improvements. The American College of Physician’s Closing the Gap program represents one such example, as does the American College of Cardiology’s Door-to-Balloon project, which linked participation in a disease registry and nationwide QI program with CME credit and demonstrated substantial improvements in the target process of care.  Other examples of CME activities linked to broader QI initiatives have involved primary care for diabetes and asthma and management of acute gastroenteritis in children. 


Greater integration of CME and QI offers the opportunity to improve health care quality and simultaneously address the widespread calls for changes in CME.  The Accreditation Council for Continuing Medical Education recently began pushing CME providers to establish quality metrics in planning and evaluating educational activities

To achieve this integration, a culture shift will be necessary and CME providers will also incur costs.  

Continuing medical education may ultimately move away from traditional lecture-based formats in favor of activities that demonstrate target competencies (6), including skills in QI.  Support from organizations with a commitment to QI, such as large health care systems, professional organizations, or health care payers, as well as incentives for participants based on additional CME credits or credentialing benefits, could help moderate cost increases and overcome resistance among physicians.  Realistically, additional incentives may be required. 

For example, the government of Ontario, Canada, has launched a program in which physicians engaged in certain types of QI activities can receive financial compensation for their time.  The gesture of compensating for physicians’ time, as much as the modest remuneration itself, has resulted in the participation of approximately one third of eligible physicians.  Learning collaboratives can also support physicians by linking them with colleagues who are engaged in similar QI activities to share experiences of overcoming barriers to implementing specific changes in practice. 

Ultimately, while the three proposed examples of integration between CME and QI incorporate traditional meeting-based CME, they all depart from tradition by emphasizing clinical topics relevant to improving care, rather than the longstanding narrow focus on new therapeutics, and by providing skills that support clinicians’ efforts to improve their practices. The authors concluded by asserting that, “these changes would meet the growing calls for CME reform and simultaneously make teaching QI more accessible to physicians who seek to provide high-quality patient care.”


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