Greg Des Rosiers, MBA, BSN, RN, PMP

AI’s Impact on CDI A recent ACDIS Survey of ACDIS members gauging impact of AI on CDI processes and the CDI profession revealed some interesting points and sentiments towards AI. The most common impacts from the implementation of CDI technology are increases in remote work and in productivity (cited by 67% each), followed by identifying “low-hanging fruit” queries (65%) and improving documentation issues with high-volume DRG groups (54%). Additional responses appear in Table 4 below. Remote work is not conducive to effectively providing sustainable measurable physician documentation educational training. One-on-One training or small group training is most effective in ultimately changing overall physician behavioral patterns of documentation. Often, the best form of training is small bit size nuggets provided in a quick conversation specific to a case on the floor. Productivity is not a valid and reliable measure of CDI performance. The mere fact that the CDIS reviewed a record does not necessarily equate to achieved improvement/integrity of the record. Identifying low hanging fruit diagnoses through queries implies CDI has room for improvement in physician documentation education through reinforcement that improves physician's muscle memory of better documentation practices. Electronic querying serves to mechanize the query process and is no substitute for physician documentation training and knowledge sharing. Physicians do not want more queries, they prefer to document right the first time versus more repetitive transactional reactive queries. AI definitely can assist and serve as an effective tool in CDI activity. However, it must be considered as a tool and not a crutch. There simply is no substitute for good old fashioned CDI boots on the ground, helping physicians achieve clinical documentation excellence through documentation training with reinforcement and guidance. AI is the panacea for improving documentation. #AI, #documentationimprovment, #notapanacea

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Epic Systems’ recent move to back the TEFCA medical records exchange is interesting. On the surface, it’s all about creating a seamless flow of patient data across hospitals, QHINs, and all relevant stakeholders. But let’s be real—data is the oil of the new economy, and interoperability is the pipeline that delivers this precious resource to all the right stakeholders. By aligning with TEFCA, Epic might just be positioning itself as the refinery. All in all, this is a welcoming move by Epic Systems—especially if it really is as straightforward as they make it sound. But given the lack of details, one has to wonder if there are any hidden catches. After all, when it comes to something as valuable as healthcare data, it’s wise to look out for the fine print. Let’s hope this is genuinely about improving patient care. https://lnkd.in/gDdDCcmj

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Information Systems Research (ISR) has recently published a new article to the Articles in Advance page:   Article Title "How Hospitals Differentiate Health Information Technology Portfolios for Clinical Care Efficiency: Insights from the HITECH Act"   Authors Jessica Pye (deceased), Arizona State University Arun Rai, Georgia State University John Qi Dong, National Technological University, Singapore   Problem definition We examine how hospitals differentiate their HIT portfolios in response to cost inefficiencies in clinical care processes and HIT policy uncertainty.   Relevance Adapting HIT portfolios to address cost-based shortfalls and policy uncertainty is crucial in shaping service delivery and impacting care costs, making it a key concern for policymakers and hospital decision-makers. Theoretical foundations We combine behavioral theory and institutional theory to explain how hospitals differentiate their HIT portfolios through idiosyncratic learning in response to cost-based performance shortfalls and shifting isomorphic pressures from changes in HIT policy uncertainty.   Methodology We constructed a panel dataset of 11,316 hospital-year observations from 3,319 U.S. hospitals over 2007–2014 to investigate how hospitals’ HIT search differentiation is influenced by cost-based performance shortfalls and policy uncertainty during the phases of the HITECH Act, from conceptualization to enactment to enforcement.   Results Our research provides a key insight: Moderate policy uncertainty, particularly during the HITECH Act's phases, significantly shapes hospitals' search for novel HIT solutions to address performance shortfalls. Hospitals enhance their search differentiation when uncertainty decreases from conceptualization to enactment but reduce it as uncertainty diminishes from enactment to enforcement.   Contributions Our findings surface the utility of combining the behavioral theory of the firm with institutional theory to explain the interdependence among a hospital’s cost-based performance shortfalls, HIT policy uncertainty, and HIT search differentiation. They show how hospital managers and policymakers can reorient their strategies to leverage the interdependencies among these elements, thereby encouraging the pursuit of innovative HIT systems over widespread imitation, to effectively address cost-based performance shortfalls in hospitals.   Short quote Unlocking Healthcare Innovation: hospitals excel in deploying new technologies through peer benchmarking and navigating moderate regulatory uncertainty. Dive into our research to see the transformative impact of this benchmarking strategy combined with moderate policy uncertainty!"   #HealthcareInnovation #HITECHAct #PolicyImpact   Keywords search differentiation, health information technology, performance shortfalls, policy uncertainty, behavioral theory of the firm, institutional theory   Link to article: https://lnkd.in/djh84uad

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It's wild to think in 2024 we're FIRST seeing the DOJ accuse telemedicine conglomerates of criminal drug distribution. How long have we known about these practices in brick and mortar care...? Answer: decades! Take it from someone who prescribed stimulants and other psychotropics to kids over the years - painstakingly measuring and documenting the need and impact - these appalling abuses by Done and Cerebral mean we need more calls for thoughtful pause when it comes to working with startups. Particularly about funding's role - my favorite topic! 🤑 How did we end up with venture capital and PE financing in healthcare that risk the safety of kids in the name of exorbitant returns? Not that all VC or PE dollars are bad, of course, but they're certainly key drivers who shouldn't be in that seat. Did we underestimate these funders as 'barbarians at the gate', much like the pharma reps of the 90's and early 2000's heyday? Have we not learned from Purdue Pharma's aggressive and deadly Oxoycontin marketing? Purdue pleaded guilty to criminal charges and paid $600 million in fines in 2007. Or TAP Pharmaceutical Products's Lupron kickback scheme for the prostate cancer drug? TAP also pleaded guilty to criminal charges and paid $875 million in fines in 2001. Or Pfizer marketing Neurontin, an anti-seizure drug, for off-label uses, such as treating pain and bipolar disorder, even though the drug was not approved for these purposes, and paying physicians kickbacks. In 2004, Pfizer pleaded guilty to criminal charges and paid $430 million in fines. Cerebral and Done's playbooks were practically the same thing, just with a modern mid-pandemic, low-regulatory scrutiny, digital-platform twist. Will appropriate regulation ever outpace American venture greed? Is it even possible to ensure patient safety AHEAD of tragedies driven by the intersection of innovation and venture funding? If you're keeping score, healthcare regulatory reactivity: 1 million. Healthcare ounces of smartly preventive policy: 3. Blech. 😖 When will we finally own that prevention in-house? #healthcare #overdoseprevention #suicideprevention

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OIG ALERT: Diagnoses reported only on enrollees’ HRAs and HRA-linked chart reviews, and not on any other 2022 service records, resulted in an estimated $7.5 billion in MA risk-adjusted payments for 2023. Before we dive in here I want to say that I have seen HRAs used appropriately and inappropriately during my time in this space. There can be great value for patients, particularly those with limited access to care and or those reluctant to visit their primary care provider. However there is tremendous risk to the system if these visits are a fragmented approach to care and or not aligned with care planning. What the OIG has identified represents the risks and shows care continuity breakdowns. Ultimately organizations and payers must know their vendor partners because there are some really good ones in this space. Earlier this week the OIG released a really interesting look into Health Risk Assessment, or HRAs. These HRAs are often performed in the home by payers or vendor partners. These should be in depth reviews of the patient and include a host of assessments that often are hard to complete in a condensed visit to a provider office. What the OIG found was that 7.5B or about 2% of all Medicare revenue was tied to conditions captured only during these visits. Is that bad? I don’t know. If these are new conditions and then ultimately incorporated into a broader care plan that improves outcomes then they are a great thing. If they are captured, never shared with the care team, and ultimately used to solely drive revenue with little focus on outcomes then it is bad. I suspect there is a mix of both. If I was at the OIG I would want to take a multi-year look at what was captured year over year only in a HRA as a next step. The report recommends CMS take the following actions. CMS subsequently agreed with recommendation number three but not numbers one and two. 1) Impose additional restrictions on the use of diagnoses reported only on in-home HRAs or chart reviews that are linked to in-home HRAs for risk-adjusted payments. 2) Conduct audits to validate diagnoses reported only on in-home HRAs and HRA-linked chart reviews. 3) Determine whether select health conditions that drove payments from in-home HRAs and HRA-linked chart reviews may be more susceptible to misuse among MA companies. I am doing some advanced analytics on information in the report for future posts but this is a nice easy read for folks. https://lnkd.in/ehNzzSWu

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OIG ALERT: A new HCC review results in an extrapolated $4.7M penalty AND a new targeted condition. Let’s digest! Hope the holidays treated everyone well. It has been an amazing year so thank you for your support. A reported released Monday shows the OIG audit results for UCare Minnesota for 2017 and 2018 dates of service. Like prior targeted reviews, this review focused on 10 conditions that often have high levels of unsupported conditions on claims. In fact, 86% of conditions reviewed lacked supporting documentation. A few key findings: -The report found that 254 of the 294 conditions reviews lacked documentation support for the diagnosis placed on the claim. -These unsupported conditions accounted for $869k in unsupported payments. However, due to extrapolation, the OIG has requested $4.7M in repayments. The OIG originally found $5.7M of risk from high risk diagnoses. -A NEW category has been highlighted by the OIG. This is the first review that I have seen Ovarian cancer called out. The OIG highlighted this HCC as being at risk when a diagnosis is only on one claim and there is no evidence of treatment within 6 months before or after the date the code is on a claim. -Sepsis and Pressure Ulcers (both new in 2024 reports) were seen. The trend continues that the failure rate on these is much less than cancer and other acute episodes. Know your data. If you need help, I am happy to discuss it with you. Remember to educate providers, evaluate conditions captured once a year, and understand where technology you use may expose you to risk. https://lnkd.in/e2kSzZa6

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Effective communication is key to ensuring smooth EHR system transitions and minimizing disruptions in healthcare workflows. Learn how we can help your organization navigate these challenges with confidence: https://bit.ly/3RYyaFa

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Any mention of physician shortage, these days, gets linked to the problem of burnout and stress, which in turn gets connected to the documentation burden ("pyjama time"), which then takes us to the problems of #EHRs. As a result, ambient AI scribing, has become one of the fastest emerging use cases of generative AI in healthcare. An ambient AI scribing tool "listens" in the background during the physician-patient encounter and automatically produces the physician's note without the need for the physician to write anything. This is the promise of ambient AI scribing: by eliminating the need to write a note after the visit, physicians will have more time for patients or for themselves/families. I often wonder if the writing of the note is purely "wasted" time. Is note-writing not integral to our cognitive process and therefore to our ability to learn from each patient encounter and improve our 'practice' of medicine? To get some answers, I listened to this 1971 grand rounds by Larry Weed MD who invented the problem-oriented medical record: https://lnkd.in/g-WftXvi. Dr. Weed says at the beginning of the video: "...this record cannot be separated from the caring of the patient. This is not something.....the practice of medicine over here and the record over there. It is intertwined with it. It determines what you do in the long run." Therefore, in addition to studying the accuracy, evidence, and benefits (time, productivity, cost etc.) of these AI scribing tools, we should also consider the impact of the elimination of note-writing on physician's cognitive processes especially trainees - students and residents. #AI #generativeAI #ambientAIscribing #EHR #cognition #medicaleducation

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🙌🏻 Good. Also if you need help renegotiating these types of agreements 👋🏻 We have over 1.5 million benchmarks (and growing), I would love to show you exactly how to save money on joint contracts.

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Tornado chart.. Tornado chart.. Tornado chart.. Check out this dynamic, interactive dashboard that enables healthcare providers to analyze patient`s costs from provider perspective. Utilizing the add-in featured tornado chart, we can effortlessly compare incurred costs Vs charges. The tornado chart allows for real time parallel comparison between costs and charges among different patient age groups or different diseases. Applying business intelligence in healthcare.. #healthcare #healthcaredata #datanalytics

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Top Four Reasons You Need Accurate Data Mapping: 1. Enhance Quality of Care. 2. Improve Patient Outcomes. 3. Make Effective Data-Driven Decisions. 4. Keep Providers Happy. Learn more about Aesto's data mapping services: https://zurl.co/8JFe

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Wearable tech and patient-generated health data (PGHD) are poised to revolutionize electronic health records (#EHRs), offering clinicians unprecedented real-time insights into patient health. By integrating data from wearables, such as heart rate variability and oxygen levels, EHRs can help identify early warning signs, track trends, and personalize care in ways traditional visits cannot. However, to maximize impact, we must address challenges like data overload, privacy concerns, and the need for smarter, action-oriented EHR dashboards. As healthcare executives and physician leaders, 𝘯𝘰𝘸 𝘪𝘴 𝘵𝘩𝘦 𝘵𝘪𝘮𝘦 𝘵𝘰 𝘱𝘳𝘦𝘱𝘢𝘳𝘦 𝘧𝘰𝘳 𝘵𝘩𝘪𝘴 𝘸𝘢𝘷𝘦 𝘰𝘧 𝘪𝘯𝘯𝘰𝘷𝘢𝘵𝘪𝘰𝘯. Proactive planning will ensure your organization stays ahead of the curve. 𝗔𝗰𝘁𝗶𝗼𝗻 𝗜𝘁𝗲𝗺𝘀 𝗳𝗼𝗿 𝗛𝗲𝗮𝗹𝘁𝗵𝗰𝗮𝗿𝗲 𝗘𝘅𝗲𝗰𝘂𝘁𝗶𝘃𝗲𝘀: 🩺 𝗖𝗵𝗮𝗺𝗽𝗶𝗼𝗻 𝗜𝗻𝘁𝗲𝗴𝗿𝗮𝘁𝗶𝗼𝗻: Prioritize EHR upgrades that can accommodate wearable data and provide clinicians with user-friendly dashboards. 🛡️ 𝗦𝘁𝗿𝗲𝗻𝗴𝘁𝗵𝗲𝗻 𝗦𝗲𝗰𝘂𝗿𝗶𝘁𝘆: Invest in robust data privacy measures to build and maintain patient trust. 🤖 𝗘𝗺𝗯𝗿𝗮𝗰𝗲 𝗔𝗜: Leverage advanced algorithms to filter and highlight actionable insights, minimizing clinician burnout. 🤝 𝗖𝗼𝗹𝗹𝗮𝗯𝗼𝗿𝗮𝘁𝗲 𝘄𝗶𝘁𝗵 𝗣𝗮𝘁𝗶𝗲𝗻𝘁𝘀: Develop policies that empower patients to control what data is shared, fostering trust and engagement.

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The Future of Healthcare Data Exchange: Analyzing the HTI-2 Final Rule and TEFCA Framework Introduction The Department of Health and Human Services (HHS) has taken another significant step forward in advancing nationwide health information exchange with the release of the Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability final rule (HTI-2). This rule, published in December 2024, represents a focused effort to establish clear regulatory frameworks around the Trusted Exchange Framework and Common Agreement (TEFCA) while also implementing select administrative updates to existing health IT certification criteria. The HTI-2 final rule specifically addresses three key areas: 1. Implementation of regulatory provisions related to TEFCA, including requirements for Qualified Health Information Networks (QHINs) 2. Administrative updates to the ONC Health IT Certification Program 3. Modifications to information blocking regulations specifically related to TEFCA This essay provides a comprehensive analysis of the final rule, examining its implications for healthcare organizations, technology vendors, and ultimately patient care. We'll explore how these regulations aim to advance interoperability while establishing governance frameworks that promote security, privacy, and trust in health information exchange. TEFCA Framework and Regulatory Implementation The centerpiece of the HTI-2 final rule is the establishment of regulatory provisions around TEFCA implementation. TEFCA represents a critical initiative to create a universal floor for interoperability across the country through a network-of-networks approach. The final rule codifies key aspects of TEFCA governance while maintaining flexibility for the framework to evolve. QHIN Requirements and Governance The rule establishes comprehensive requirements for organizations seeking to become QHINs, which serve as the backbone entities facilitating health information exchange under TEFCA. Key qualification requirements include: Ownership and Control Requirements: - Must be a U.S. Entity subject to U.S. jurisdiction - Cannot be under foreign control - Directors, officers, executives and 5%+ owners cannot be on restricted lists - Must maintain principal place of business in the U.S. Technical Exchange Capabilities: - Ability to exchange information between multiple unaffiliated organizations - Capability to exchange all Required Information as defined in the framework - Must be actively exchanging information for at least one Exchange Purpose - Ability to receive and respond to transactions from other QHINs - Technical capacity to support high transaction volumes Continued (link in bio)…

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Sharing key takeaways on the CMS Hospital Inpatient Quality Reporting program for FY2025. - Seven new measures are added (which are welcome, with the caveat of let's see how they work out) -> Patient Safety Structural Measure beginning CY 2025 with payment determination in FY 2027 -> Age Friendly Hospital CY 2025/FY 2027 -> Catheter-Associated Urinary Tract Infection Standardized Infection Ratio Stratified for Oncology Locations (CAUTI- Onc) CY 2026/FY 2028 -> Central Line-Associated Bloodstream Infection Standardized Infection Ratio Stratified for Oncology Locations (CLABSI-Onc) CY 2026/FY 2028 -> Hospital Harm – Falls with Injury (eCQM) CY 2026/FY 2028 -> Hospital Harm – Postoperative Respiratory Failure (eCQM) CY 2026/FY 2028 -> Thirty-day Risk-Standardized Death Rate Among Surgical Inpatients with Complications July 1, 2023–June 30, 2025/ FY 2027 - Five existing measures are removed (which is a breath of fresh air) - the unpopular PSI-04, and measures related to 30-day episode payments for acute myocardial infarction, pneumonia, total hip/ knee arthroplasty, heart failure - Two existing measures are modified (Global malnutrition composite score expanded from seniors over 65 to anyone older than 18 - this is very positive; and Refined HCAHPS measure - will post details on this next week.)

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"Gen AI 'mission-creep' is the biggest health IT and RCM threat I see right now," said Mark Townsend, MD, chief clinical innovation officer at Cincinnati-based Bon Secours Mercy Health. "Don't get me wrong, I believe in the potential of generative AI to help us work smarter and not harder. We are working hard to create new technology using generative AI, we are selectively investing in Gen AI, and Gen AI is not a panacea for patient care or for operational performance." "The mission-creep of gen AI is to oversell its potential and under-deliver on its performance, which absolutely requires a human being in the loop to validate every output," said Dr. Townsend. "Said differently, challenging ourselves to truly quantify the value of gen AI tools is a tall order at this point." https://lnkd.in/euaYzMD6

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OIG ALERT- Another targeted condition review, the 5th this year, was released this week. While the penalty is only $297k, the risk found was 51X the penalty. I repeat... 51 times. In addition to the settlement with a health plan announced by the DOJ yesterday, the OIG also posted its most recent targeted review of conditions for a Medicare Advantage plan. These targeted reviews focus on conditions the OIG has identified as having an extreme likelihood for overpayment. Nothing is necessarily new in this report, especially since the dates of service were 2015 and 2016 dates of service. The details: -9 different clinical conditions were reviewed for potential over-capture. All 9 of these have been on prior reports. However, this is the first time vascular claudication has shown up in a 2024 report. I suspect that is because the dates of service are older and not representative of an increased emphasis on the condition. -73% of conditions reviewed failed to have supporting documentation. This number is consistent with prior reviews by the OIG. -Interestingly, depression and vascular claudication were supported in 93% of the reviews. This is on the high end and also one of the reasons the OIG has decreased emphasis on these conditions. -90% of heart attack, stroke, and cancer patients reviewed failed to have supporting documentation. The OIG found that in total the overpayment was $297k. However, this is due to the sampling was limited by condition and extrapolated payment penalties were not allowed for these dates of service. Had they been, the penalty would likely have been 51X higher since the OIG identified $15.3M of risk for these conditions. I expect that now that extrapolation is allowed we can expect to see more OIG reviews with larger penalties. Additionally, with yesterday's DOJ settlement with Independent Health and in particular the $2M penalty to former DxID CEO, I expect 2025 will bring more review findings. If you aren't reviewing your risk then you are susceptible for takebacks. https://lnkd.in/e_Sae-79

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