Archive for the ‘ARRA’ Category

Health Care Reform is a Journey Not an Event

Monday, July 26th, 2010

The recent passage of national health care reform legislation is an important milestone in the process of moving toward providing millions of Americans with access to health insurance. However, significant steps must still be taken in order to achieve the goals established in the legislation.

Specifically, greater clarification is needed to determine how reform will be implemented and, just as important, there is the challenge of effectively dealing with the critical issue of affordability. Health plans and providers have received many questions regarding how they will make the necessary changes within their business to help employers and trading partners comply with the new law.

While most answers are still unclear, we have developed initial comments to many of the questions dealing with the 2010 provisions, including:

  • Annual and lifetime limits
  • Pre-existing conditions
  • Employer penalties
  • Dependent coverage
  • Retirement health care benefits
  • Grandfathering
  • Rescissions
  • Wellness
  • Health care business, process, people and technology changes for payor and provider firms:

  • Eligibility
  • Medical coding standard changes (from ICD-9 to ICD-10)
  • Electronic data interchange (EDI) standards (from 4010 to HIPAA 5010)
  • Personal health information (PHI) data security and confidentiality
  • Electronic health records (EHR)
  • Meaningful Use for providers
  • CORE Operating Rules
  • Changes in Medical Loss Ratio Requirements
  • Cross impacts of different regulatory requirements. i.e. the impact of ICD-10 on meaningful use and EHR standards
  • Potential changes in risk analysis with changes in coverage requirements and population stratification due to coverage rules and ICD-10 definition of population categories of health
  • The impact changes in trending patterns as a result of many requirements simultaneously and identifying trend change causes the impact of the measurement of quality and efficiency in terms of reporting requirements and measurement specification changes.
  • Health Information Exchanges (HIE) and other data exchange requirements/standards
  • Comparative effectiveness research issues around quality of care.
  • We will cover these topics in subsequent releases of our blog. We will continue to monitor the detailed discussions during the lengthy implementation process.  Our focus will be on taking the time to make sure we help our clients get the implementation of reform right and addressing the most significant issue facing our industry – affordability.

    It is important to remember that most of the provisions in the legislation will not go into effect until 2014 or later.  The details of implementing legislation can take months, even years to work through the regulatory process.  Much of what Congress has passed will require additional regulations to bring further clarity to this new law, and those regulations will truly shape the impact on consumers and employers.

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    ICD-10 – A New Sherriff in Town – Penalties as well as Benefits

    Monday, June 21st, 2010

    Many white papers and blogs focus on benefits of ICD-10, but would be remiss if we didn’t also point out the punitive measures.  Health plans must file certification statements that they are in compliance with standards and operating rules by December 2013 including documentation, and provide proof of compliance.   In addition payers will have to provide documentation of proof of end to end to testing with providers.

    These Sarbanes-Oxley like measures certainly should get your executive team’s attention if the benefits do not.

    Penalties

    The laws have already been enacted. Organizations who do not comply may be subject to a fine of $1.00 per covered life per day if they do not meet the certification requirements.  These penalties double if inaccurate or incomplete information has been provided in the compliance documentation.   This means that a relatively small health plan with 100,000 members could be subject to a $2 million fine, per year.

    See ICD-10 Assessments here.

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