HIMSS MBP Leadership Forum, Vanderbilt Center for Better Health, October 6 & 7, 2010
Our Leadership Forum is fast approaching and we invite you to save the date early for this important event! On October 6-7, 2010, our traditional Medical Banking Leadership Forum is changing format somewhat…all attendees will be placed into a stakeholder category and become part of our first G7 Roundtable. Stakeholder categories include: providers, banks, plans, consumers, government, technology firms and employers. This is a one-of-a-kind event to discuss a pressing issue – real time adjudication – and to provide your critical feedback into a national process that we have planned.
We will be assessing at least three aspects of “real time adjudication”:
(1) technological readiness;
(2) health payments interoperability; and
(3) health care reform – administrative aspects.
Note that the New York Times ran an article on this topic last Sunday – “See You In 6 Months. And The Insurer is OK With Your Bill” - http://www.nytimes.com/2010/06/27/business/27digi.html?src=busln. John Casillas responded to the column and received a response back so they are aware of our work and we’ll be updating them on further developments.
The nation’s first G7 Roundtable will be held at the Vanderbilt Center for Better Health in Nashville, Tennessee. We are working with our sponsors and Vanderbilt University to organize a press event just prior to the G7 after which all press will be asked to leave so we can get down to business!
Thank you for saving October 6-7, 2010 on your calendars for our G7@HIMSS MBP Leadership Forum more information to come!
HIMSS Business-Centered Systems Staff
Dear 8MBI@HIMSS10 Attendees
First of all I want to thank you very much for taking time to join our effort. I appreciate it and I hope you derived value. If not, I would like to know. Let me know what you would change too. This is free form – send me an email. I will acknowledge all replies and we will factor your suggestions into our 2011 planning process.
Our vision is simple: design an efficient healthcare financial network. By accomplishing this we can as an industry convert some $35 billion in wasted dollars so providers can offer better care, or expanded care, in their communities. To do this we must evolve and facilitate sustaining models. I want to say that again. Our efforts must focus on sustaining models. That is truly the only way to grow this area that, while having great social goals, must survive the ebb and flow of commerce and competition. This is one good reason why we are developing a new, neutral, G7 Roundtable of engagement. We need great “move forward ideas and solutions” that integrate the good work done to construct building blocks (privacy, technical standards, specialty payment systems, etc) into efficient end-to-end healthcare financial networks.
Our short term focus must now move from learning about how the HIMSS global engine can propel our movement (what we covered at the Institute) to discrete case studies of medical banking innovation in the marketplace. We need to focus on the pragmatic while at the same time evolving thought leadership. HIMSS Medical Banking Project will keep this new paradigm of activity and ideas in front of our membership. One way we’ll do this is by merging content areas in medical banking, financial systems and payer administration…and we will seek to develop resources targeting medical consumerism as well (globalization of healthcare, medical tourism, account-based plans, etc). The “tsunami” of 5010/ICD10 transformation is also a key forward focus as are other areas (mHealth, community care platforms, fraud and abuse, etc).
We look forward to, and frankly need, your continued engagement. Please join HIMSS MBProject if you’re not a member today. Our membership plan has changed dramatically in terms of cost and a whole new layer of benefits! We need your input ALL YEAR LONG, not just at the Institute! Thanks so much again for spending time with us in Atlanta!
Senior Vice President
HIMSS Medical Banking Project, Business and Financial Information Systems
230 East Ohio Street, Suite 500
Chicago IL 60611-3270
www.mbproject.org / www.himss.org
HIMSS...providing HIT leadership through knowledge and education for the betterment of healthcare. Go to www.himss.org to see how.
Designing the Healthcare Financial Network of the Future - The Medical Banking Institute@HIMSS10
Designing the Healthcare Financial Network of the Future, a centerpiece program that seeks to support overall health improvements by leveraging banking systems, is being offered on March 1-2 at the Omni Hotel in Atlanta, in conjunction with HIMSS10. The program's theme focuses on a new, multi-year global strategy tied to HIMSS' acquisition of the Medical Banking Project earlier this year. The Medical Banking Institute@HIMSS10 is open to all HIMSS attendees interested in the medical banking area.
Industry leaders representing payers, providers and other stakeholders will convene in a neutral setting to identify and discuss critical path issues that currently impede cross-industry efficiency. Topics include emerging functions in the new 'healthwealth' paradigm to standards and best practices that simplify and automate workflows. The Institute will feature sessions on health data privacy and security in banking channels as well as discussion that contextualizes general healthcare trends against medical banking metrics; a senior level banking panel that will help healthcare providers and payers to understand how banks are investing in revenue management technologies; and case studies that show the emergence of bankdriven community care platforms and more.
Preceding the Institute, HIMSS Medical Banking Boot Camp will offer attendees an overview on the emerging role of banks and financial institutions in healthcare. The Boot Camp will meet from 1-5 pm on Feb. 28, at the Georgia World Congress Center. Registration for the Institute and Boot Camp is now open. Visit http://www.mbproject.org/8MBI2010.php for more information. In addition to the Medical Banking Institute and Boot Camp, one of the Views from the Top sessions will explore why banks are interested in healthcare and examine the synergies between healthcare and treasury management. During Medical Banking: An Emerging Strategy to Improve Global Healthcare on March 3, attendees will hear how the world's largest custodial bank (with over $23 trillion in assets under custody) is gearing up for investment in the healthcare industry and how banks can help bring efficiencies to healthcare processing. For more information on this and other Views from the Top sessions, visit http://www.himssconference.org/viewsfromthetop General brochure here.
HIMSS Strives to Help Build Healthcare Financial Network of the Future
Interested in Medical Banking are Welcome at the 8th National Medical Banking
Institute @ HIMSS10 in Atlanta
CHICAGO – (December 8, 2009) – Designing the Healthcare Financial Network of the Future, a centerpiece program that seeks to support overall health improvements by leveraging banking systems, will be offered on March 1-2, 2010 at the Omni Hotel in Atlanta, Ga. The program is held in conjunction with the Healthcare Information and Management Systems Society (HIMSS) Annual Conference & Exhibition at the Georgia World Congress Center from March 1-4, 2010.
The program’s theme focuses on a new, multi-year global strategy tied to HIMSS’ acquisition of the Medical Banking Project earlier this year. The Medical Banking Institute@HIMSS10 is open to all HIMSS attendees interested in the medical banking area.
“Demands on financial systems, both domestic and global, have created new roles for banks, said John Casillas, senior vice president, HIMSS MBProject, Business and Financial Systems. “There is a growing need for banking systems to improve fiscal processes for payers and providers.”
Industry leaders representing payers, providers and other stakeholders will convene in a neutral setting to identify and discuss critical path issues that currently impede cross-industry efficiency. Topics include emerging functions in the new ‘health-wealth’ paradigm to standards and best practices that simplify and automate workflows.
The Institute will feature sessions on health data privacy and security in banking channels as well as:
- Discussion that contextualizes general healthcare trends against medical banking metrics;
- A senior level banking panel that will help healthcare providers and payers to understand how banks are investing in revenue management technologies;
- Case studies that show the emergence of bank-driven community care platforms and more.
Preceding the Institute, the HIMSS Medical Banking Boot Camp will offer attendees an overview on the emerging role of banks and financial institutions in healthcare. The Boot Camp will meet from 1-5 p.m. on Feb. 28, 2010 at the Georgia World Congress Center.
Registration for the Institute and Boot Camp is now open. Hotel reservations can be made through Ambassadors.
The Healthcare Information and Management Systems Society (HIMSS) is a comprehensive healthcare-stakeholder membership organization exclusively focused on providing global leadership for the optimal use of information technology (IT) and management systems for the betterment of healthcare. Founded in 1961 with offices in Chicago, Washington D.C., Brussels, Singapore, and other locations across the United States, HIMSS represents more than 23,000 individual members, of which 73% work in patient care delivery settings. HIMSS also includes over 380 corporate members and nearly 30 not-for-profit organizations that share our mission of transforming healthcare through the effective use of information technology and management systems. HIMSS frames and leads healthcare public policy and industry practices through its educational, professional development, and advocacy initiatives designed to promote information and management systems’ contributions to ensuring quality patient care. Visit www.himss.org for more information.
For more information, contact:
312-915-9237 – firstname.lastname@example.org
John Casillas on A Vision for eHealth Using Banks
Intro: Thank you Maureen and the entire team at the President’s Council, they deserve so much credit; Members and Sponsors.
Once a person visiting a restaurant in France was so taken by the entrée that she asked the Chef for the recipe. The following year she visited the same restaurant, ordered the same dish and asked for the Chef again. “I’ve tried it over and over again and its not coming out. What’s the missing ingredient?” The Chef replied, “madamme, after you follow the directions you must throw yourself into it”.
Today, during an unprecedented global crisis in banking and as our domestic healthcare systems strain under the weight of a growing underserved population, it may seem counter intuitive to link two ailing systems. But for those in banking and healthcare who have thrown themselves into the prospect of improving healthcare, a new vision of the future is emerging that is powerful, energizing and compelling! They have stumbled upon a missing ingredient in our national dialogue to improve healthcare – medical banking. And they realize there is simply too much at stake for banks not to be sitting at the table as we fix our healthcare system.
The recipe for economic disaster is a broken healthcare system. This was the central message of the President at last week’s healthcare summit. Thus all the things that drive the banking and financial services engine rely on healthy individuals and communities and a productive labor force. Dr. David Mirvis, who will be on our Federal Health Board panel today, researched this linkage and found that economies rise and fall based on the health of people in an article published in JAMA. Dr. Stephen Parente, who will also be on our panel today, wrote in our Dr. HSA Column that an economic stimulus pathway could be distributing using cards credited with $500 to be used for prescription drugs, adding that while he’s not very excited to see so much money being spent, if its going to happen anyway, let’s spend it smartly. Many see a clear link between healthcare and economic vitality so the real question is why wouldn’t banks be fully engaged, why wouldn’t banks use their resources in the national quest to fix healthcare.
We’ve all heard a common ingredient for success: “necessity is the mother of invention.” Perhaps it will be of necessity that we find healthcare using the rails of our banking complex to finally realize the national dream of real time data exchange between all the industry actors. When the dish is ready, we believe that banks can ramp healthcare onto a digital platform. Banking processes were at one time mired in paper too, and there is no question that the lessons they bring to the table, and in some cases their very systems and processes, in which they are highly invested, can fast forward our national eHealth strategy. Yet we don’t hear very much about this paradigm shift in the national process. We hear about spending billions of dollars to create a new digital system, but what about the digital system lying right under our nose?
Ultimately, our challenge is to forge a health-wealth view of the future, where banks join with fellow healthcare stakeholders to develop common solutions to help the uninsured and unbanked, to socialize better tools and information that families can use for their medical treatments, to help individuals get real time access to their healthcare records through online banking used by 55 million households in America and growing, and to enable community centers that President Obama is investing in with eligibility, funds and data transfer platforms that support far greater coordination of the finite healthcare assets in the community. Oh yes, we have a vital ingredient and a critical role in the national dialogue and don’t let anyone tell you otherwise.
Banks and financial services firms are teaming with health technology companies and others to create a new paradigm, starting with vastly improved administrative processes and moving up the value paradigm in phase 1, to automating workflows that remove the paper chase, leveraging the unique market position of the bank to process and capture payment data that improves revenue cycle decisioning through denial management or contract management routines that take up so much time in the business office, and finally moving to the top of the pyramid of value, to address the enterprise needs of the healthcare community. Different banks are evolving at different rates along this pyramid. As you do, know that the top contenders have found compelling prospects for profitability. As success stories come in, medical banking groups are following this strategic pathway, creating one of the nation’s most compelling “Green Tech” engines – another tie into the goals of the Obama Administration. Yes, we have a critical ingredient for the national dialogue to improve healthcare.
Moving to phase 2, we should align the immense annual investments in privacy and security in online banking with the unique data needs of each stakeholder. This calls for electronic integration of assets to liberate data so it can travel securely in real time. We’re all stirring this pot together – our own build-out of specialized banking platforms, NGA’s recent summit where former HHS Sec Leavitt called on leaders to “remember Argentina” and to invest in healthcare to stimulate the economy, John Halamka’s HISPC 11-state collaborative to normalize state laws that impede the flow of health data across state boundaries, WEDI’s leadership to move us toward the 5010, EHNACs program for clearinghouses, ABA’s HSA Council, TAWPIs new HPAS, HIMSS’ annual summit and much more – all of these efforts, in my view, are moving us towards greater data liquidity that at the end of the day will, and must, empower the consumer.
In phase 2, banks are embracing the power of their market position, reving up eHealth strategy, creating real time gateways with health IT partners, specializing card platforms to automate payment processing across stakeholders, leveraging online banking to support single-sign on for the consumer, giving families private access to health-wealth tools, and although Track 1 is a primary focus for many today, the recipes of the future belong to Track 2: innovations in medical consumerism.
So we ask you to apply yourselves diligently to the task of exploring how financial systems can align with the national process to improve healthcare; and this moves us to phase 3, examining how governance models, like the Federal Reserve, can spearhead common standards banks can use to empower business and consumers with mission-critical and family-critical tools…tools that hospitals can use to automate the routines in Phase 1, tools that health plans can use to reduce disbursement costs, tools that community care centers can use to access healthcare assets in real time, tools that will allow you and I to use a “healthcare ATM” just like we use the regular ATM, so if we travel abroad as a medical tourist or just across the country and we get ill, we have secure and private on demand access to our healthcare records and our financing resources at the swipe of a card. We can get this done!
Building an electronic medical banking community, the theme of our event, moves the President’s “Green Tech” agenda forward. Rationalizing the extreme paper chase in healthcare is core to modernizing our healthcare system. We’ve done good work digitizing the front door, sending the claim from the provider to the payor but the back door was left wide open and today, whenever you visit a care giver, a steady stream of paper follows you – almost all payment related. This mountain of paper invades our healthcare system, creating enormous barriers to efficiency, siloing data that needs to be securely liberated to improve healthcare at every point along the process and especially at point of service, where adverse drug events cause avoidable pain and loss.
Who will liberate this data? How will it happen? If you follow the trail, it leads through the banking world – a service is rendered, payments are processed. In this country, payments only move through banking systems. Thus banks can use their tremendous investments in information technology to ramp healthcare onto the on-demand paradigm that leads to better health programs for all the stakeholders. That is in large part what our educational program here is about. And what we need to do is understand how to add value to that data so it can address the unprecedented cash flow pressures our health care system is experiencing, not just from the economic downturn but because of the very complexity of our healthcare payment system. Today, I’m very proud to report success stories coming in from our members – one provider saving $4 million in 12 months after implementing a medical banking platform, another saving $660,000 and other stories that are catapulting medical banking into best practices. Yes, we have a Green Tech Message that is delivering compelling ROI and we need to spice up the national debate by making our voices heard. And I’m proud to say that that is what we can do at this Institute.
Sometimes when agonizing over problems you wake up to find solutions right under your nose. I want to suggest to you today that the medical banking build-out is inevitable. As banks linked with airline systems removed layers of inefficiency, enabling consumers with online tools, so medical banking is following a similar pathway, pushing paper out of the system, liberating data, fueling revenue cycles and decisioning; helping banks and their healthcare clients to gain a better view of the intrinsic value of the fundamental financial unit in healthcare, so taxed with myriad codes, and potentially unleashing $200 billion in credit from receivables that are wasting away on the books and records of our nation’s healthcare systems. Other industries have liquidated this asset. This is a mainstream practice except for healthcare, where the value of receivables is too often locked in a deep freeze. This will change in the new medical banking paradigm.
Now, do you remember how when growing up, Mom made you eat the peas? Some of you still don’t like peas because of that. Value should drive progress not legislative fiat. It may make sense to engage a legislative agenda at some point, but for now we’ve chosen to take our ideas to the marketplace and let the market decide. And they have. The 1100 employer strong Automotive Industry Action Group embraced medical banking as a strategy, helping us to create a new Tool Kit for Employers to diffuse medical banking practices in the marketplace, and we’re excited that LeapFrog and others are taking notice of our efforts. MBProject just aligned with NCPDP, the only group that is doing real time processing on a general basis, to cross-pollinate ideas with our banking members. The HFMA is here, a powerful healthcare group, and this is testimony to the power of our ideas. I look forward to hearing Bob Broadway tell us how we can help hospitals navigate one of the toughest times in the history of healthcare. As Obama said, we’re at that Thelma and Louise flashpoint in healthcare, where the car could go over the cliff. The medical banking community will not stand by idly and watch banking and healthcare crash burn. We’re in the game. Its Game On for Medical Banking!
We reached out to consumer groups too. Greg Scandlen, founder of Consumers for Health Care Choices, will share his ideas and I’m going to listen to him carefully. We need to listen to consumers, because our quest to build platforms that serve business will ultimately find critical mass in service to families. Banks know the power of scaling services for the masses, which they do everyday. As we collectively fine tune the vision in medical banking, new concepts will emerge of how to marry online banking, credit terminals, ATMs, branch systems, to personalized healthcare platforms that promote better lifestyles and better healthcare. Not only will this improve customer retention but banks may add three times more to the bottom line by creating a health-wealth portal, linked to online banking, based on an extrapolation of research done by Dr. Paul Whitman, here from California Lutheran University in Simi Valley.
We need to gather other chefs into the kitchen who don’t mind the heat. So we reached out to national leadership like the Mayo Clinic Health Policy Center. Bob Schmoldt, a leading national figure from Mayo, recently concluded a high level meeting in DC to fine tune the concept of a US Health Board. We’ll explore this area today and gain your valuable input. So you better plan on throwing yourself into this discussion, which we will document and provide to the White House Office for Health Reform.
Healthcare and banking groups are sharing ingredients, they are finding common ground to improve healthcare in increasingly powerful ways. When I first started talking about this in 1996, I was met with a field of bank stares. Yet convergence is vital to the national dialogue to improve healthcare. The Medical Banking Project has pioneered new ground; we’ve thrown ourselves into the healthcare dialogue with a critical ingredient and with our members, we are making great strides. All of you, top executives in your domains, must know that you are an integral part of the process, not a bystander. You should not accept the fact that everyone in healthcare is sitting around a table and leaving you out. You must be in the process, you must, if necessary, throw yourself into the process to fuel an electronic medical banking community that provides powerful and relevant services for our ailing healthcare system.
This is not a time sit back. I know there are groups that are struggling. I know that you are coming here trying to find your footing in this dynamic and complex area. I know its not easy. But I exhort you to move forward. Hold on and invest. Your ideas are far too compelling and you have a very good chance of being rewarded well for your efforts. You must not give up! Your participation is vital to the healthcare interests of our nation.
To help you, MBProject has created new tools:
Our Gold Seal program, is the essential underpinning of our movement. Its not just a technology platform that we need; we must build a platform of trust for business and consumers and bankers know that all too well. One slip up, and 58% of your customers will change banks. Your margin for error is almost non-existent. I encourage you, because even though today’s climate of low confidence is tough, consumers are still depositing funds into your accounts, using ATMs, credit cards and more. Let’s not throw the baby out with the bath water. Banks will continue to provide a central driving force in the evolution of healthcare solutions.
Our Dispute Resolution Initiative is a key tool that Sheila Schweitzer will discuss at our National Roundtable during lunchtime.
Our Medical Banking Tool Kit for Employers will be unveiled tomorrow where we’ll hear from Scott Sharland, Executive Director of the Automotive Industry Action Group; about their initiatives to manage fiscal stress, and how medical banking offers a key ingredient for their long term viability.
Our International Journal of Medical Banking, as Maureen discussed, provides a peer reviewed tool that helps to get the mental juices flowing to spur creative strategies linking banking and healthcare systems.
Our Executive Training Program, as announced by John English, a professor at Vanderbilt University, will address a growing need to train new medical banking talent and to foster critical leadership standards in this emerging area.
And there are more exciting programs being developed our Tool Shed. Tools that are being honed by an awesome cast of executives – our members – who are building common standards for creating a Green Economy, A Digital Economy, A Lean Economy; (a lean, green, stimulus machine)…they are building an electronic medical banking community. We urge you to become part of the process! Don’t sit aside when we need you to come to the table. We can’t educate you in medical banking in three days! This is much like drinking water from a fire hydrant. To get the recipe right, you need to be involved 12 months out of the year, you need to join MBProject and help us to make a difference!
In closing, I want to emphasize again that necessity is the mother of invention. What if one of the most important and critical ingredients for fixing our banking and healthcare crisis was to find common ways to help each other? What if two broken, elephantine systems, prodded by a dancing mouse, discovered new ways to heal themselves? Cleary, a healthy community supports a productive workforce that ultimately results in healthy deposits. Healthcare and banking leaders truly have much in common. There is good reason to invest in healthcare to energize the bottom line, and get the economy moving forward again. I believe we have an historic opportunity to influence the progress of our nation by throw ourselves into the creation of an electronic medical banking community. Towards this end, we offer this Institute to inform the national process, so that we can collectively build a healthy-wealthy future for our families and communities. Thank-you.
Presentation of awards
Medical Banking Project is driven by a mission: to convert digital savings into charitable resources. We do this by optimizing banking resources for healthcare. What gives life to our mission are the executives that have come into our process as members and leaders of our workgroups and councils. We want to acknowledge each of these leaders for their hard work. Each year, one or two people rise to the surface.
Tools For Building An Electronic Medical Banking Community
The theme of our 2009 Medical Banking Institute, "Building An Electronic Medical Banking Community", wasn't an empty promise! Our Members have been very busy!
We are pleased to announce the creation of a new series of digital and educational tools for the growing medical banking community! These tools will do things like help assure the marketplace that medical banking organizations are meeting the highest standards of privacy, confidentiality and security, rationalizing costs in the healthcare revenue cycle, implementing medical banking programs that save time and money for groups that purchase healthcare and much more!
Make sure to check back often! More MBTools are being developed to increase the efficacy and efficiency of your operations! Send comments and suggestions to: email@example.com. We wish you every continued success engaging and developing medical banking programs!
Panel: Driving Medical Banking Into Everyday Practice - A New Tool Kit for Employers
John Casillas, Chair, Medical Banking Institute
J. Scot Sharland, Executive Director, Automotive Industry Action Group (AIAG), Southfield, MI
June St. John, Chair, Education and Programming, Medical Banking Institute; Wells Fargo
Eric Booth, COO, The Leapfrog Group, Washington, DC
The role of an educational video
Capitalizing A Whole New Industry
Kevin Lavender, Senior Vice President, Healthcare Finance, Firth Third Bank, Nashville, TN
Keynote Panel - Banking on Better Healthcare
John Casillas, Chair, Medical Banking Institute
Al Briand, Division Head, BNY Mellon Treasury Services Product Management and Strategic Development, New York, NY
Making the case for standards allowing for economies of scale and will determine the success of medical banking
Mentioned SWIFT and messages moving capabilities; they should be studied to see how they produced their standards
Paula Fryland, Senior Vice President and managing Director- Corporate Banking, PNC Bank, Louisville, KY
Community involvement, community development
Boards members at community hospitals
Charitable giving - building facilities, fundraising
Health NPOs liquidity markets have collapsed, banks have stepped up
Extending and/or customizing current products or services
Point of Sale technologies
Whole new solutions
Pete Wheeler, Wells Fargo
Leading by example to create knowledge dissemination
WF 281,000 employees; HSAs, wellness program
Huge deposit base, huge lending base, huge brokerage presence, huge mutual fund presence, huge geographic reach
As employees go to other companies they bring their knowledge of the medical banking options to others firms
Global angst re: banks
PNC: Virtual wallet, healthcare 10s of millions of dollars in business investment, incredible opportunities in administrative transactions of hc, including noncredit products to build relationships
BNY Mellon: Can't count on certain aspects of traditional business so discovery of new opportunities must be explored; there must be a business case for them; friction (not seemlessness in transactions) means opportunity; consumer-centered healthcare; health custodians
WF: Opportunities coming from the synergies of combining 2 banks
Question from floor: quality rating on bonds
How will existing clearinghouse and transaction engines be tied together; current "RAILS" in place
How will XBRL and international standards impact -- bring as many players to the table to create and apply the standards
Economy of scale is THE DRIVER
Super-regional and community banks: Smaller banks have many healthcare related account; train a couple of SMEs first, build portfolios over time; attend conferences and be involved in groups active in the space
Will banks repeat their earlier investment in automation to accounts receivables
Health Wealth Portals? Convenience for either business or retail banks is important; cell phone convergence metaphor
How does hc impact your strategy? PHRs??? Wealthy individuals request new services; back office accounting of wealth management tools
How does the money saved by more efficient transaction being targeted to indigent care by hc orgs impact your banks? Banks have not recognized indirect benefits of their efficiencies investment in the communities they serve
TAKE AWAY: Economy of scale is THE DRIVER, standards are THE ENABLERS
Next Steps for Moving the Industry Forward
Maureen Turo, President, National Medical Banking Institute, VP, Healthcare Strategy, The Bank of New York Mellon Treasury Services Division, Pittsburgh, PA
Comments from many on how many different constituencies are represented at the Institute and in MBProject
There needs to be a voice for Washington, DC
1) Task Force, Richard Mobley, Lead - 18 volunteers to climb the Hill
2) Ideas collected by the Mayo Clinic at the Institute will be compiled and emailed to attendees
Medical Banking Report provided on a quarterly basis at the MBP Portal
Deven McGraw on the Great Privacy Debate: Impact of ARRA 2009
Health Privacy Project at Center for Democracy and Technology
- Health IT and electronic health information exchange have tremendous potential to improve health care quality, reduce costs, and empower consumers
- The public wants health IT – but also has significant privacy concerns
- Failure to build foundation of trust is an obstacle to achieving greater health information exchange
Health Privacy Project at CDT
- For years there was no progress on resolving the privacy and security issues raised by e-health
- Project’s aim: Develop and promote workable privacy and security policy solutions for personal health information
Evolution of Federal Privacy Protections
1996 – Enactment of Health Insurance Portability and Accountability Act (HIPAA)
- Congress gives itself 3 years to enact privacy legislation
- 1999 – Proposed rules
- 2000 – Final rule
- 2002 – Regulatory changes
- 2003 – Effective for most
Era of Health Information Technology
Health IT bills stalled in 108th &109th
- Privacy was framed as the obstacle – but it wasn’t the only issue
Legislation moved furthest in 110th – but economic woes stalled progress
ARRA (Title XIII- HITECH)
- Broke the privacy "logjam"
- Most significant change to the healthcare privacy and security environment since the original HIPAA privacy rule
- Not a change to everything about HIPAA – but some significant changes that will need to be addressed by many entities handling health care information
- Most provisions require further regulatory clarification
Privacy and Security Provisions – Overview
- Substantive changes to HIPAA statutory provisions and privacy and security regulations
- Enhanced enforcement of HIPAA
- Provisions to address health information held by some entities not covered by HIPAA
- Misc: Administration/Studies/Reports/Educational Initiatives
Substantive HIPAA Changes
Breach notification requirement
- Definition of breach
- Safe harbor for “protected” data
- Detailed requirements re: timing and content of notice; how provided to individual and HHS
- Business Associates must notify covered entities Strengthened individual right to restrict disclosures to health plans for payment and operations
- Secretary guidance on minimum necessary
- Use of limited data set where possible in interim
- Discloser determines minimum necessary Minimum necessary still does not apply to treatment
- Requirement applies after standard and regulations are developed
- Phased in over time
- Covers only 3 years Change with respect to how business associates comply
- Can direct record to another entity or individual (PHR) Changes to definition of marketing
- Limited right to use information for marketing if the communication is paid for by an outside entity
- Exceptions for treatment communications and communications about current drugs and biologics Opt-out for fundraising communications
- Public health
- Treatment of an individual
- Sale of a facility/business
- Payments to business associates
- Copies to individuals
- Designated by Secretary in regulations
Accounting for disclosure requirements for entities using electronic health records
Patient right of electronic access
BA contracts required for RHIOs – and PHRs in some instances
Prohibition on “sale” of health records or protected health information
HIPAA EnforcementBusiness Associates accountable to authorities for compliance with some HIPAA privacy and security rules (+ new provisions)
Application of HIPAA criminal provisions to individuals
Ability to civilly enforce where violation qualifies as criminal but no criminal penalties pursued
Requirement to impose civil penalties in cases of willful neglect
- Corrective action may still be pursued for lesser offenses
Distribution of % of civil penalties to individuals (penalties also go to OCR)
State AG civil enforcement
Secretary required to do periodic audits
Provisions for Entities not Covered by HIPAATemporary breach notification provisions for PHR vendors and internet applications
- Breach definition
- Same safe harbor for protected information
- Enforced by FTC
- Which agency should regulate?
- Timeframe for regulations (no specific authority to regulate)
Misc. (Administration/Studies/Reports/Educational Initiatives)
- Strengthened authority for ONC
- New advisory committees on policy and standards
- OCR public education initiative on uses of PHI and individual rights under HIPAA
- Privacy Officers in each HHS region
- Chief Privacy Officer within ONC - Not charged with HIPAA enforcement/oversight
Misc. (Studies/Reports/Educational Initiatives)
- Studies/Reports by HHS Secretary
- Annual report on enforcement
- Study on implementation of the de-identification requirements
- Study of HIPAA definition of psychotherapy notes with respect to inclusion of test data and materials used for evaluative purposes
- GAO Studies:
- Methodology for providing individuals with a % of civil monetary penalties
- Report on best practices for disclosure of PHI for treatment purposes
- Report on Impact of ARRA provisions on health care costs and adoption of EHRs