2011 has been a memorable year for MindHealthBiz. I hope I’ve helped steer some people in a positive direction with this bolg.
MindHealthBiz continues to evolve, focusing more on the core expertise, which incase you don’t know is Hands-on Electronic Health Record selection, implementation and vitalization. I’ve met some new friends this year, which inspires gratitude.
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I’ve also had some people from my past help me out in ways I could never foresee. A ton of “coincidences” have come my way, all positive.
I’ve had some personal trials this year, who hasn’t? I am convinced that every challenge has led me to a better spot. Perhaps it’s just the old addage “That which doesn not kill us makes us stronger”…I prefer to look at each one of these events and situatios in my life as gifts from the Universe.
Remember in 2012, Peace and Love is where it’s at! -T.
Read more →Executive Summary
New York State Medicaid Health Homes have been defined, including the offer of payment for providing the coordination of care among a network of providers required to be a Health Home. Providers are diligently completing applications (due November 1, 2011). Electronic communication to facilitate this coordination of care for Severely and Persistently Mentally Ill (SPMI) consumers is critical to deliver care in a reasonable amount of time. A prime goal for the Health Home is to reduce emergency room and hospital stays for these folks.
This system of care is most efficiently managed with the help of interoperable software. An exploration of current thinking follows, discussing questions that have been raised in conjunction with efficient and effective planning to share data among Health Home network providers and the involvement of the Electronic Health Record (EHR) in this effort at the care provider level, and the involvement of the RHIO in securely sharing that patient data at the network level.
Although the EHR is not required to be in place at the outset of the Health Home adventure, some system of communication throughout the Health Home network is required. Without an electronic solution with a modicum of automation, documentation and communication requirements for coordinating treatment for some consumers will be onerous. The requirement of a plan to have an EHR in place within 18 months for all care provider organizations involved with Health Homes seems like a lot of time to some. It’s not; there are too many project details involved to delay. A few software companies brag that they can have an EHR up and running in 90 days. That is likely true, MindHealthBiz actually uses similar rapid change cycle software implementation methods. Care providers on the other hand may falter in meeting aggressive targets simply because they don’t have professionals with requisite skills and bandwidth available to do the job in a short time frame. Implementing an enterprise EHR is a huge task in itself, and tackling electronic communications among care providers for a SPMI patient complicates the job…this is a completely new application for software that has only the foundation elements defined and not yet assembled.
Paying for EHR Software As usual, the first question that arises is “who’s going to pay for all this?”
HEAL grants have been suggested as a way to pay for EHRs at the provider organization level, as significant work will need to be performed to get software ready to securely and electronically share patient data among members of a Health Home network. A number of HEAL awards have been granted over the past few years with regard to sharing consumer information among care providers, as well as establishing regional centers for Health Information Technology (HIT) assistance. The results of these grants are available to providers if they choose to use them.
Currently, Meaningful Use incentives are the best bet in gaining revenue to offset the expense of software. A few software companies capable of deploying to a large HHS organization have gained certifications required to qualify to receive Meaningful Use incentive funds. Other software companies are in the process of earning the certification, or plan to apply soon. If a care provider agency plans to fund their EHR purchase with Meaningful Use incentives, there are a few things to pay attention to from the outset. • Currently an organization must apply for incentives through their eligible professionals (prescribers, usually doctors) (http://blog.samhsa.gov/2011/09/09/behavioral-health-organizations-begin-receiving-incentive-payments-for-health-it/) o For Behavioral Health, The Behavioral Health Information Technology Act of 2011 (S. 539) is active in the US Senate to establish more appropriate criteria (http://www.informationweek.com/news/healthcare/EMR/229301263) for our field, and expand the list of eligible professionals to include other licensed professionals o The current reimbursement is $63,750 per eligible professional…if you have ten doctors working, that’s a significant amount to be paid over five years. If you don’t you’ll need the aforementioned bill to pass in order to collect significant incentives for Psychologists and Licensed Mental Health Counselors • Thirty percent of the eligible professionals’ consumers served must be Medicaid funded • Core Measures (http://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf) are generally attested to by the EHR vendor, however the agency is responsible to use the tool and meet the requirements.
There are more details (like connectivity to SHIN-NY (Statewide Health Information Network for New York) to address and more measures to meet as the EHR is used. If we address the foundation elements above first, future requirements are designed to fall into place as long as the provider uses the EHR as intended according to the certification and follows the rules. Of course a gap analysis performed by a neutral party is appropriate due diligence for any organization planning to be included in a Health Home network.
Recently I performed a survey of major New York City providers, like New York City’s HHC, and discovered that the majority of hospitals and large human services provider organizations have no enterprise Behavioral Health EHR on line, and are either just now implementing, or more likely, engaged in a purchasing process for the software.
This last point is a stickler, and where providers of care can stumble a bit in doing what they need to do to continue collecting Meaningful Use incentives. Some agencies have created a full time position for this job, others contract with companies like MindHealthBiz to assure they collect the incentives without incurring penalties along the way. Participants in the Meaningful Use incentive program are required to provide on-going proof of performance like self-attestation that will need to be proven in order to avoid having to return incentives already paid.
Connectivity Who is your Regional Health Information Organization (RHIO)? Are they working with your software vendor? Answer these questions and you’ve started a project, so be prepared to have adequate human resources available with time, persistence and expertise to dig into the details. It is best for care providers to have a voice in development of any system regarding what data flows to what electronic destination, and exactly how it gets there. Software vendors have varying levels of knowledge and expertise in confidentiality requirements and exact workflow within care providing organizations. Your organization could be a model for development of the Health Home network plan for your vendor, with great say in product development. Act quickly.
The point of electronic connectivity is communication throughout a disparate, multi-provider treatment team, through the Health Home’s care coordinator / case manager. Technology exists for the software vendor and RHIO can enable this, and it’s necessary for them to cooperate with one another on exactly how the electronic communications will flow among treatment team members. Questions arise at the care-giving level: How do I know my consumer has seen another provider? Who owns the treatment plan, and how is it shared? What notes can/must I share? The list of elements that affect care at the provider level continues.
As shared earlier, it’s important to be involved from the outset with your EHR vendor and have some say in the development of how new functionality will work. Would you rather your professional staff guide the details of gathering and sharing consumer data, or a software company’s project manager and programming staff? This has been a pet peeve of mine in software manufacture; programmers seldom analyze several common workflows for the same task in different care provider settings. One very handy remedy to this problem has turned out to be the dual edged sword of designer tools that come included with software packages.
These tools can potentially help save a ton of development costs. On the other hand, if a care providing agency doesn’t know the vendor’s communications plan for the Health Home network or doesn’t want to wait for a solution they may develop their own technology with design tools. This can hurt the provider as the vendor follows its development roadmap at their intended, albeit usually slow, pace. Be aware of details like this and avoid mistakes that waste resources and money.
Oh, one more connectivity item in this short story….Managed Care for all NYS Medicaid is the next step for our world, so remember to garner some sort of electronic link to your EHR with your Managed Care Organization (MCO) or BHO. This avenue may provide valuable encounter data and speed authorization processes. The BHOs to move forward with have been (or are being) defined in your region, and that may or may not mean the provider agency is destined for big change for managed care.
A comprehensive Release of Information must be negotiated to meet requirements of the Health Home, 42 CFR, the other provider agencies in the network and other interested parties. My suggestion has been an electronic form provided through the RHIO that includes all network member agencies. I would like the ability to disclose the sorts of information that will be shared among agencies and give the option to the consumer to select which agencies he approves with checkboxes, or “all Health Home network agencies. Some plans laid for this adventure include only the latter, not the option for a consumer to pick and choose. That said, the consumer’s choice may boil down to costs being covered by Medicaid…or not. More will be revealed as the details are ironed out and the technology is fine tuned.
Of course, if you’d rather not rush into an enterprise EHR purchase, your RHIO may have a software solution they would be happy to provide for a monthly fee; you’ll still need to implement it, and that effort is still expensive in money and the provider agency’s human resources. This software would be an “Application Service Provider” (ASP) arrangement, and may be adequate for the interim period while agencies select their EHR. Just make sure the ASP software is certified for all ARRA purposes and you can live with the functionality limitations.
Functionality The right way to go about understanding shortcomings of software technology is to balance requirements with the reality of who enters what data where. A functionality grid fills in the blanks that are opened by a gap analysis and returns a “score” for each vendor involved. These grids are used commonly in Requests for Proposal, and can be limited to functionality needed to accomplish the goals of a Health Home. Some of the Health-Home-specific elements that should be considered include: • A robust referral module o Drop-down dictionary selections for all Health Home Network members for multiple screens involved in a consumer’s treatment o Other network care provider treatment and discharge information should be tracked as it may affect your care’s outcomes for the consumer (psychotropic medications, physical trauma, etc) • A Health Home Requirements Checklist to assure the Health Home Case Manager/ care coordinator has information required to make reasonable consumer care decisions; all providers involved need to share their findings and cooperate with one another, so the best solution would be interactive among care providers • The care coordinator will need live access to key data for utilization and quality reports from all Home Health Network providers • Treatment data transfer mechanisms compatible with a number of EHRs o Note: A number of formats are already in place for HIPAA electronic formats as well as tools like the Health Level-7 (HL7) to securely share demographic, clinical and transaction data…your vendor may or may not elect to use these standard formats, replacing them instead with their own proprietary mechanism; certification issues may ensue if that’s the case • A pool of funds is promised to Home Health networks for proving effective treatment: o What is the mechanism to measure improvement? o What is the base line for the measurement? o How is the data aggregated? o Are these Quality Control measures reflected in tools in each care provider agency’s EHR? • Account for the 3M Clinical Risk Groups within the EHR and entry of that data into the consumer record during intake and sharing the score with the multiple treatment team members • Immediate access to Diagnosis & Treatment data from other agencies & possible storage of some of that data in the patient’s local record. • Active tracking of available Health Home slots with Health Home Network interaction • Some required functionality may not be available from some vendors, however, if they intend to stay in business, there is a roadmap to comply with the requirements; Be aware, there may be additional costs to care providers • It is wise to track whatever a consumer does, counseling sessions, physical health treatment, even if they simply show up for activities, track their presence and reason for being in the facility • Document Imaging attaches electronic files like scanned treatment documents and fax files from other agencies to your EHR’s consumer record…All agencies in the Health Home network are required to have an EHR 18 months after the start date – until then, some will have little or no technology and rely on telephone calls and faxes until that time, so other members will need to account for recording conversations and attaching such electronic documents to the consumer record in their software; not all EHRs come with document imaging, sometimes they can be quite expensive to add into the mix
In Closing The Health Home goal of coordinating care for SPMI consumers is lofty, and has been proven effective in New York. For care provider agencies participating in the Health Home program, the EHR is a requirement, and a lot of work and inter-provider cooperation is involved in bringing it up to speed. There’s time to do this, however, with a task like this, a dedicated human resource needs to be involved in order to meet the 18 month requirement for completion and the likely wish to take advantage of Meaningful Use incentives to help pay for the EHR.
One critical aspect in creating a functional electronic network for the Health Home environment to communicate and coordinate consumer care is the willingness for the RHIO to work with a number of software vendors. Vendors tend to work with differing platforms. Even though they all may be ODBC compliant, they way they actually work can present challenges to communication. The jealously-guarded code and database behind the graphics we see can be as different as night and day among software programs. The RHIO’s willingness to work with all comers in this is only half the equation. Vendors will need to be willing to cooperate with the RHIO, other software vendors, and multiple care providers to define and possibly accept foreign methods of accomplishing the Health Home electronic communication goals. Be as certain of upcoming costs as possible, and understand an exact dollar amount is not likely to be available until the project is complete.
All focused functionality needs to be in place as soon as possible. Since this involves development on multiple platforms, a comprehensive plan is needed. It’s certain that at least some RHIOs and software companies are working on this, to their individual or partnership advantage. Are your RHIO and EHR vendor working together, or at least have an agreement to work together on the same plan?
Contact MindHealthBiz at 631-419-6879 or info@ehrsio.com to discuss details of your situation and how your agency can influence the process to implement an effective, efficient EHR solution. Leverage the earned wisdom of an IT professional required to advance your project to participate an electronically integrated Health Home network.
Read more →Fact: data sits unused, and that’s a disservice to both consumers and business.
In a fast-paced, complex treatment environment, professionals seldom think of how data can help them treat a consumer…they’re busy treating the person for the primary problem they’re supposed to address. A customer of mine recently hit the six month mark of including new data into their Electronic Health Record (EHR).
Over the course of that six months, we integrated processes that are based on results backed up by data. I truly believe that without the data, our success would not have been perceived as something that contributes not only to organizational survival, but scratched the surface for improving treatment.
The clinic is an outpatient medication-assisted substance abuse program, dealing with chronic addicts.
Since addiction to another substance has been the focus for many years, alcoholism has taken a second-row seat in the clinic, when for some folks enrolled in the program, it’s been an alternative to using the preferred substance. There’s a related alcohol outpatient treatment program next door that makes it convenient to increase business for the overall organization. New York State OASAS includes a service chargeable to Medicaid for simply walking a consumer through an assessment to determine whether she may actually have a drinking problem. By including the assessment as a part of the clinic’s focus, consumers have been referred next door for treatment.
A few instances of success, helping consumers come to grips with their alcohol problem while showing staff the assessment can be successful in raising revenue and improving treatment, has been backed up by data. The assessment is a service that’s paid by the consumer’s payor, and a few have at least taken action over the data gathering period. The next step is to increase the staff’s efforts. Counselors and nurses have always informally invited consumers to investigate their alcohol use if they suspect it looks excessive, however referrals have seldom resulted in enrollments at the outpatient program next door. Since we have increased attention to the alcohol problem, the plan is to get staff buy-in to administer the assessments in addition to the consumer’s regular treatment sessions. By bringing more focused attention to the problem on a regular basis, we expect more success. Since we have data to back up the staff’s minor successes so far, we expect more consumer referrals once all suspected alcohol abusers are administered the assessment three times a year as is permitted (and paid for) by Medicaid.
Tracking the assessments in the EHR will deliver further opportunity for followup with the alcohol treatment program after the consumer’s initial treatment is complete and there’s even more data to review and judge effectiveness. The scheduling module in the EHR is designed to assure the follow-up activities actually happen. To date, the scheduling module has not been valuable for many functions, so it’s been neglected. Because the treatment in the clinic next door will certainly not be on the professional’s mind, a timely reminder to discuss the treatment with the consumer and the professional next door will help the two clinics collaborate, grow and become more effective. Needless to say, the organization sees benefit from the revenue generated by both the original and follow-up activities. Incidentally, this encourages another program designed to coordinate consumer treatment by a multiple providers, Health Homes. Health Homes are designed to keep all professionals providing complex care of different types appraised of the total treatment picture for a consumer. The design is meant to decrease emergency room visits and hospital stays for consumers with complicated multiple problems. In the case of today’s topics, the interventions and treatment discussed are all wrapped up in the EHR, so the data could be automatically sent to professionals who need it most in order to avoid drug interactions and generally know what’s happening in the consumer’s life…oh, and for my example clinics, that means more “Complex-Care” services, which can also generate more revenue.
As we progress into this new age of EHR effectiveness, data is king.
Read more →The last thing Americans need is another hit in the wallet, and the thought of upcoming increases in health insurance rates has been rolling around in the back of my mind for a while…it has to happen.
A lot of legislative movement has been made over the past few years in the interest of increasing mental healthcare quality and availability, and one thing limiting quality people from entering the field as treatment professionals has been the pay scale for counselors. People either avoid or get out of the mental healthcare industry and into supporting services like I did partly because the paycheck opportunities have been better.
Twenty years or so ago I considered a career change and getting out of IT, sales and business management altogether. I made the decision not to go back to school to earn a Master of Social Work degree and become a therapist concentrating on addiction recovery as I had considered during an employment crossroads at the time. The paycheck up-ramp was too slow. Mental Health Parity legislation is supposed to rectify this problem, increasing the availability of higher quality people in the field who receive higher paychecks for what they do. Theoretically, good mental healthcare providers will keep helping people if they can get paid on par with physical healthcare practitioners.
This also sets the stage for raising insurance rates…when mental healthcare costs more to provide, insurance rates increase.
Kathleen Sebelius, U.S. Health and Human Services Secretary praised New York Governor Patterson for taking control of insurance rate hikes by establishing a law enabling the state to pound a rubber stamp on premium increases. When an insurance company is not regulated, large profits have been included in rate increases simply because it makes good business sense to make more profit, and nobody said they couldn’t. The law delivers a modicum of control over greed.
The outcomes of this could be good, or not. Civil servants will be charged with the reviews, and if they’re anything like the people at the Office of the Medicaid Inspector General (OMIG), they will not be people to rub the wrong way (OMIG is charged with uprooting Medicaid fraud and recouping overpayments from healthcare providers when mistakes are made in billing). Will government-salaried Insurance rate inspectors be hyper-vigilant, or ambivalent? Will they be pit-bulls after the evil insurance empire, or will they be as susceptible to greed and corruption as the insurance industry has been?
Time will tell. The insurance industry’s lobbying machine has created a marvelously profitable world for a lot of people, and greed can make people do stupid things.
Being a Pollyanna sort, I have hopes toward the positive side that the intent will play out in reality, and the result will be improved level mental health and reduced addiction in America without undue chunks of my paycheck going to the insurance industry.
Read more →A number of non-profit agencies in New York State (and probably across the nation) will disappear over the next couple years. It’s imperative to change perspective in these agencies to a for-profit viewpoint.
Surviving the Office of Mental Health clinic restructure and the OASAS switch of charging methods to APGs with fee-for service elements in New York will include a very tough lesson for some provider agencies. Agencies are discussing mergers and acquisitions to consolidate resources (which loses jobs) in order to increase efficiencies. Financial models are being created and most discarded because they just won’t bring in enough revenue and they expend too much human energy to deliver the services to earn the revenue.
People are feverishly working overtime to come up with plans to save jobs.
Although projecting income requirements is a big part of the survival work, I don’t hear much about the nuts and bolts of the matter: Service Pairing.
Since threshold visits are disappearing (one charge per day with most services performed for the client included in that charge), the new financial model for these agencies needs to include two separately charged services for a visit. A number of elements come into play in determining which services are scheduled, and when.
It’s no secret that agencies work differently; they all have a different personality. The business processes of each agency need to be evaluated and modified; exactly when the second service is scheduled and what it will be for a client visit will vary.
The questions bring up concerns and change from agency to agency.
Is your agency ready to include service scheduling at the time the treatment plan is written? Is your front desk person of the personality type to effectively juggle a few more balls, a few more considerations in scheduling visits? What workflow procedures need to be considered in the workflow models? Is the team ready to evolve on this business level with the client treatment needs?
Analyzing and redesigning business processes needs to be part of the restructure of your financial model. You may need to hire a masters level person at the central scheduling desk (expensive, effective in some situations). You may need to upgrade your enterprise software to the tune of thousands of dollars…oh, you don’t have enterprise software?
If your agency is properly staffed to survive, there just aren’t enough human resources to analyze, design and implement new processes and you need help: info@ehrsio.com.
Read more →What a joy it is to spend a day digging through New York OMH materials to make sense of the new clinic model for reimbursement. It was truly a test for the Attention Deficit Disorder that wants to take over my life. It is, however, something we need to concentrate on, and fast.
I just received a correction in my simple understanding of the restructure of billing, boiling it down to the lowest common denominator. I had thought CPT codes needed to be in the same APG to be reimbursed for a given day, however, I was told that’s not the case.
In order to get reimbursed under the new model for a day’s service,
– Multiple CPT codes can be billed for that day o e.g. 96118 (psych testing) and 90853 (1 hr group therapy) o Two services is supposed to be the daily limit, but OMH is still working on this – The CPT codes must be contained in separate APGs for a day’s billing o Per the example above o There will be exceptions, which haven’t been mapped out yet – The OMH provided spreadsheet-calculators rule regarding rates o They’re available on the OMH website, search for Clinic Restructuring – The provider simply bills for their base rate for appropriate APGs, to be reimbursed according to the weighted rate for each CPT code.
That being the case, the foundation work for clinics lies in scheduling the proper procedures for every patient visit in order to maximize revenue. These allowable procedures are designed to encourage better outcomes of treatment. Does your scheduling process include a person who can make these decisions, or appropriate logic built into your scheduling software?
These thoughts relate back to the October, 2009 David Lloyd presentation, Workshop A – Proven Strategies for Improving Clinic Operation, Profits and the Quality of Care. It’s almost like somebody had a plan.
Naturally the devil is in the details. It can be easy to loose track of foundation objectives and become embroiled in busywork…I think the point of the restructure is to eliminate that sort of wasted effort, be more productive and produce better outcomes.
OK, so once we understand the best way to maximize revenue for the resource spent to earn it, who implements this plan in the clinics? After all, people in the clinics already have jobs.
Terry McLeod stands ready to help.
Read more →New York judges have saved New Yorkers $41 Million by testing the Rockefeller drug law reform statutes.
In a recent paper “Drug Law Resentencing: Saving Tax Dollars with Minimal Community Risk”, the Legal Aid Society’s Criminal Defense Division in New York City says that drug law sentences have been proven too long, and that shorter re-sentencing is effective and less expensive.
Lesser sentences for lesser offenders is apparently working by saving millions of dollars and returning citizens to productive lives after the wake up call in jail. Meanwhile, major offenders who are determined by the courts to continue to give New Yorkers trouble remain behind bars a long time.
Naturally, addiction treatment providers are charged with a number of these lesser offenders, which just may lead to recovery….good news for all, and as an added “plus” I see a growing revenue stream.
Sounds good to me, what do you think? Is this version too good to be true?
Read more →The law firm of Moritt, Hock, Hamroff & Horowitz, LLP just won a landmark case for people in early recovery in Suffolk County, NY.
Judge Joseph F. Bianco of the United States District Court for the Eastern District of New York decided for the benefit of Oxford House, annulling Suffolk County’s local law regulating substance abuse houses on the basis that the law was facially discriminatory and was preempted by the Federal Fair Housing Act. The decision was a huge victory because upholding that law would deprive people disabled by alcohol and substance abuse problems of their ability to maintain recovery housing.
I’m from Oregon, and as far as I know, they don’t have sober houses there. Insomuch as recovering alcoholics and addicts are extremely vulnerable to that first drink or drug in their early sobriety, and it’s the first drink or drug that sets the monster loose, sober houses may be a good environment for a group of recovering folks to try to stay clean.
That being said, alcoholics do relapse, early recovery is a struggle to change the mind. The outcome of this case is a baby step in attempts to make laws more reasonable with regard to addiction and disease, from which nobody’s immune. Better to support recovery than not.
Sober Houses are a controversial subject, and your thoughts count.
Read more →One of the changes brought on by the NYS-OMH clinic restructuring is the realization that two or three services will need to be rendered for each patient visit in order to survive financially.
This presents interesting scheduling complications for organizations considering the nature of services to perform for the patient. A number of issues come into play. • Which combinations of services will deliver the highest monetary return? • Which services deliver the best outcomes? • Is the diagnosis appropriate, addressing the above questions?
I’m sure there are more, so feed me the complications I’m missing.
I ran across a presentation from Centerstone Research Institute on this subject, and to make a long story short, their study considered outcomes from specific services like Case Management, Group & Individual Therapy and Medications. A number of assessments were employed in the study, and outcomes from specific services and service combinations offered.
It looked like 70% of the outcomes of their cases were indeed predictable based on these service combinations…better outcomes = treatment success = good marketing, and can mean funding opportunities. More than that, better outcomes means the humans doing the work are not spinning their wheels delivering treatment, and efficiency of the provider organization is increased, which means everybody gets raises…or at least cutbacks are minimized.
In the end, the study depends on data…and each agency will need to provide its own data.
More to come on this subject.
Read more →