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Juggling the Emerging Data Mandates: The New Reality

August 30, 2011
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Healthcare reform will push the boundaries for IT leaders—and the stakes are very high indeed

Jane Metzger isn’t fooling around: she and her colleagues, the co-authors of a new white paper from CSC, are determined to shine a huge spotlight for healthcare leaders on the data and IS challenges facing them in the near future. The fact is, while most CIOs and other healthcare IT leaders are, justifiably enough, focusing on meaningful use under the HITECH ACT, Metzger and her colleagues point out that there are several crucial, non-voluntary data mandates going into effect right now, and in the coming several months, as mandated by federal healthcare reform.

Last week, I interviewed Jane regarding all these issues (see that interview on this website). She’s concerned that healthcare IT leaders and their organizations are at risk over these new mandates, coming out of three key different healthcare reform-mandated programs under Medicare: the value-based purchasing program, the hospital readmissions reduction program, and the hospital-acquired conditions program. Not only are all three of these new programs mandatory, not voluntary; they are all on different, but swiftly-advancing, timetables. And in the case of value-based purchasing, data collection for chart-abstracted measures for the first year of that program was supposed to begin on July 1—that’s two months ago now.

Yet few CIOs and CMIOs seem to be fully aware of all these requirements, partly because there are so many of them. Just sorting through the data-collection and data-reporting mandates from those three healthcare reform-mandated programs alone will inevitably be a challenging set of tasks for IT leaders. And of course, all these timetables are unfolding at the same time that the meaningful use process is moving ahead, with all its requirements and its own complicated set of timetables.

Fortunately, the kinds of requirements set forth in the healthcare reform-mandated programs under Medicare are broadly harmonious with those under meaningful use. Still, as Jane Metzger told me, it will be a rude shock to many healthcare IT leaders to scan those requirements and realize that the stage 1 requirements under meaningful use, 80 percent of a hospital organization’s patients need to be assigned a problem list with at least one problem. But in reality, that standard is far, far too mild to meet the requirements in these other programs; essentially, hospital organizations will need to quickly create problems lists that encompass all the problems for all of their patients, in order to satisfy the demands of those programs.

So, inevitably, CIOs, CMIOs, and their colleagues will need to learn to multitask; they will have to juggle all sorts of timetables, will have to move their individual program-focused teams forward all at the same time, constantly checking and cross-checking the work progress of those teams, in order to do what’s necessary to satisfy the demands from the federal government—and without a doubt, very soon, the vast majority of private payers—for greater accountability and transparency.

It’s also essential to keep in mind the costs of not moving forward on all these fronts at the same time. When the penalties from the value-based purchasing, readmissions reduction, and hospital-acquired condition programs are combined, the fact is that within just a few years, a hospital organization that finds itself in the bottom quartile of performers nationwide could see its Medicare reimbursement cut by as much as several percentage points by 2017. And that figure would not include the penalties for failing to meet meaningful use requirements by the end of 2015. (And of course, none of this includes the data collection and reporting requirements under the ACO shared savings program, which are yet another whole area--though also the one truly voluntary program, with no potential payment cuts for poor performance--or for non-participation, as under MU.)

Are we really talking about a poorly performing hospital losing, say, up to 9 percent of its annual Medicare reimbursement by 2017? Absolutely. Indeed, to be truly realistic, one must also take into account the clear possibility that even the best-performing U.S. hospitals could lose at least a few percentage points off their total annual Medicare reimbursement in the coming several years, based on the very difficult federal budget issues facing Congress this fall, and the likelihood that across-the-board Medicare provider cuts are in the offing.

So let’s be clear: the poorest-performing hospitals in this country are, in the next several years, facing a catastrophic combination of across-the-board reimbursement cuts and targeted outcomes-based pay cuts. How does a 12-percent overall Medicare reimbursement cut sound? For many resource-strapped hospitals already struggling to keep up with their competitors in their local markets, that level of reimbursement cut could truly be an organizational death sentence.