H. Stephen Lieber

Next up, the Practice Management Committee session lead by Mark R. Jones and Alan Eisman at Emergency Department Practice Management Association (EDPMA) Solutions Summit! Powerful content on Contracting and Partner Relations (Bing Pao), Machine Learning AI (Dave Friedenson, MD, FACEP) and IDR Best Practices (Ed Gaines)! #EDPMA #SolutionsSummit24

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Within the new #hti2 rule are some critical signals: 1. It is a joint effort between Office of the National Coordinator for Health Information Technology (ONC) and Centers for Disease Control and Prevention —and also heavily influenced by recent rules from Centers for Medicare & Medicaid Services 2. #mfa (multi-factor authentication) is called out as required in some use cases 3. #ai algorithms for #caremanagement will need to be more transparent. 4. It attempts to harmonize #tefca from the The Sequoia Project 4. It sets specific versions of USCDI, and #fhir. https://lnkd.in/edb7NpaZ

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The Association of Healthcare Value Analysis Professionals (AHVAP) celebrates Elizabeth Eisenberg, MSN, RN, CVAHP from Scripps Health for commitment to excellence in the specialty of healthcare value analysis! Liz has signified this commitment by signing the official Association of Healthcare Value Analysis Professionals (AHVAP) healthcare value analysis pledge. To learn more about the Association of Healthcare Value Analysis Professionals (AHVAP) Commitment pledge: https://lnkd.in/gqEWPBue. #AHVAP #valuebasedcare #excellenceincare #valueanalysis

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It seems that the government is serious about finally realizing the vision of true health data interoperability. The attached Point-of-Care Partners blog post describes the recently released HTI-2 Proposed Rule which is another step in the fruition of that vision. Point-of-Care Partners can help your healthcare organization stay ahead of the waves of regulatory activity around interoperability. Let me know if you are interested in learning how.

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Title: Bridging the Gap: Public and Private Healthcare Collaboration On June 11, we hosted a pivotal meeting with key voices from both private healthcare providers and public healthcare regulators and providers. The consensus was clear: collaboration between the public and private sectors is essential to create a robust and sustainable healthcare system. Here’s how we can achieve this: 1. Unified Vision:Establish common goals like improving patient outcomes and increasing accessibility. 2. Leverage Strengths:Public systems excel in broad coverage and preventive care, while private providers lead in innovation and efficiency. 3. Data Sharing:Integrate data to enhance diagnosis, treatment, and preventive measures. 4. Joint Investment:Collaborate on funding for advanced medical technologies and telemedicine. 5. Policy Harmonization:Align policies to reduce bureaucratic hurdles and foster innovation. 6. Public-Private Partnerships: Pool resources to tackle infrastructure and rural healthcare challenges. 7. Continuous Improvement: Regular feedback and communication to adapt to changing needs. Our meeting highlighted the potential of collaboration in transforming healthcare. By working together, we can build a more efficient, equitable, and responsive healthcare system. Let’s commit to this collaborative journey for a healthier future. #UHC #medicalai #health #PPP

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I’ve been given advice that the fastest way to monetize HER Heard without charging the end user (woman) is trackers and selling data. Instead, I’d like to build something more trustworthy. I don’t want to be in a headline like this. If you are not paying, then you are the product (you/your data are being sold). There are newer ways to deindentify data or even to aggregate things women search for that can be of interest to various stakeholders. In theory that could be okay to sell, but in a post-Roe world with laws encouraging bounty hunting, I am vetting the choices ahead. I am all for moving fast, without breaking things.

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On October 8th, U.S. News & World Report released its annual rankings of Children's Hospitals, called "Best Children's Hospitals". It is a 174-page report describing the methodology and data tables which I scanned through. Appendix C-10 has the data on Pediatric Pulmonology which I took a deep dive into. In the attached carousel, I have recreated two datasets that matter. If I were to shop around for a hospital for my care, what really matters to me is the outcome data for a particular condition I am seeking care for and not the reputation score. However what separates the top-ranked "Best Children's Hospitals" is their reputation scores, not the outcome scores for selected conditions as in asthma here. It's a different matter whether the outcome scores used in the rankings are good measures. We will discuss them in another post. What are your thoughts? Feel free to like, share, and comment. #healthcare #hospitals #physician

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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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For the AJMC - The American Journal of Managed Care, Giuliana Grossi provides relevant updates and an excellent summary of how the #MedicaidDisenrollment process has evolved, noting some progress in reducing technical barriers, yet the #disparity of those impacted is clear. The latter remains my concern. I question the inherent complexities of operating Medicaid programs with federal oversight yet state-level execution. Federally, we can anticipate further unwinding and reductions in Medicaid funding, support, and quality of care under the upcoming Administration. Past actions, such as the imposition of work requirements for Medicaid recipients, have set a precedent for policies aimed at reducing the federal commitment to Medicaid. Additionally, proposals to cap federal funding for Medicaid or allow states to relax protections under the Affordable Care Act (ACA) could further strain access to care, especially for those with preexisting conditions. As of yet, there are no specific proposals to reduce Medicaid spending. However, Stat News (https://lnkd.in/gheKdhQn) did highlight the 2025 budget plan by the Republican Study Committee (https://lnkd.in/gR46jUxK) and the 2025 House Republican budget resolution (https://lnkd.in/gZwdcuQ6) as sources that propose major Medicaid reforms. At the state level, we can anticipate that investments will mirror party lines evident in last Tuesday's election. From an #equity perspective, we need to remember that in the U.S., 47% of the country's total Medicaid/Children's Health Insurance Program plans are children; more than 37M children, to be precise (https://lnkd.in/gRhJgdGM). I wonder how the ACA will be impacted and initiatives for supporting family access to care/coverage. Data tells us access to care directly relates to health outcomes. Given cost is a significant barrier to care, we can expect to see increasing rates of non-adherence to screening guidelines, ultimately impacting quality and increasing costs that must be absorbed somewhere (medical debt? health system margins?) I have also been wondering why we still operate Medicaid at the state level but Medicare at the Federal level (soon to be increasingly privatized with a push for Medicare Advantage). Would love to understand why folks believe this model persists.   So, what will the future bring? I'm open to your predictions for the future of Medicaid and Medicare. Share them below. If you are curious about where Medicaid numbers lie today, read Giuliana's piece with the latest data: Lessons Learned From Medicaid Unwinding as States Tackle Eligibility Checks.

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Loper and #Medicare #Reimbursement: What Does the Future Hold? Ganny A Belloni from Bloomberg News wades in (in a terrific article) on the implications of #Chevron and the rise of #Loper on Medicare reimbursement issues. I'm quoted. My take? I think, as I say in the article, Loper will have less impact than people think. Loper eliminates Chevron “deference” by a court to an agency’s interpretation of a federal statute, where that law is “ambiguous”, meaning it can reasonably be read in different ways. Congress can (and will) significantly reduce the risk of litigation challenges in a Looer world by, as Ganny summarizes the point, defining statutory terms more precisely and "more clearly and explicitly giv[ing] the agency the discretion to decide issues". Further, many potential challenges can be avoided by CMS, as I say in the article, by framing "more ... [agency] decisions as ‘factual determinations’ or ‘adjudicative’ questions, where it still is entitled to deference, even after Loper.” To those of you who are fans of the administrative state, take heart. The sky, truth be told, is not falling. #healthcare Centers for Medicare & Medicaid ServicesU.S. Department of Health and Human Services (HHS) #CMS #HHS #APA #administrativestate #agencydiscretion #rulemaking #agencies #administrativelaw

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Natural Language Processing (NLP) enhances mental health care by analyzing text and speech to detect emotional states and mental health issues. It can identify suicidal ideation, depression, and anxiety, often more accurately than traditional methods. This allows for timely interventions and personalized care, improving patient outcomes. Summery: In 2020, Clarigent Health, a spinout from Cincinnati Children’s, launched an app that uses NLP to analyze speech and identify vocal biomarkers of suicidal risk. The HIPAA-compliant listening tool is designed to provide clinical decision support to mental health professionals. That project was built on work by John Pestian, neuropsychiatric AI scientist who runs a research lab at Cincinnati Children’s. Pestian has been developing machine learning methods for identifying patients at risk of suicide for more than two decades. Using speech samples from therapy sessions and notes from people who died by suicide, Pestian and colleagues demonstrated in 2020 that AI algorithms could detect suicidality with up to 90% accuracy. Also at that time, Talkspace was publishing its own research with NYU Grossman School of Medicine researchers. The feature was officially rolled out in 2019. The analysis runs in real time on messages sent by patients in their encrypted virtual therapy room and triggers an alert to the therapist, allowing them to respond with the appropriate intervention. The key is having a human in the loop. #unitedseniorassociation #USA #eldercare #FDA #seniorliving #ADA #AI #NIH #patientcare #compliance #hospitals #OIG #healthcare #HHSOIG #digitalhealth #HSS #CMS #assistedliving #nursinghomes #seniorcare #medicare #seniorcitizen #homehealthcare #caregiver #dementia #inhomecare #seniorhealth #kloekorby #alzheimers #mentalhealth

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https://lnkd.in/gywCYUvv AMAs continued advocacy to help #FixPriorAuth targeting ERISA plans.  Although very welcomed, part of the practical workflow challenge is keeping track of what federal/state regulations apply to which plans based on a specific services.  Not so easy to do in today’s legacy EMRs. #Valer can help keep track of payer rules as regulatory requirement for prior auth ramp up on an individual payer and service level basis. www.valer.health 

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I get Dr. Yang's concern about large, wealthier health systems adopting AI sooner than smaller, poorer organizations, but this is actually a good thing...unless your time horizon is myopically short. Big organizations, with much larger budgets and sophisticated IT teams, can afford to take risks, make mistakes, and test out exciting (but still unproven) emerging tech while smaller organizations certainly can't (for the most part). So let the behemoths take all the risk, do the heavy lifting first, and then smaller organizations get to adopt truly proven solutions at lower risks/prices...once these have run the Kaiser, Mayo, Intermountain, etc., gauntlet. It's all part of the plan... #healthcare #startups #startup #ai #generativeai #digitalhealth #emergingtech Kaiser Permanente Cleveland Clinic Mayo Clinic Risant Health Intermountain Health https://lnkd.in/gckgQB_q

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Great commentary and details to be considered from post by Deborah Williams Too few probably understand what you've posted, the other major part of the problem. Commercial insured populations (employers & employees) pay the price for government policy failures that represent major hits on company bottom lines or lead to more individual bankruptcies today. #employeebenefits #employers #commerialinsurance #epcouncil.org

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Two new proposed rules could be a game changer for health data interoperability... In early July (published in Federal Register August 5), ASTP/ONC released all 1,067 pages of its proposed HTI-2 rule, in which it proposed expanding its Certification Program to complement CMS' FHIR APIs. This included creating criteria impacting payers and public health IT. It reminded me of a line of questioning from ONC's electronic prior authorization RFI from January 2022, where the agency asked nearly ten questions about what certification criteria should look like to facilitate electronic prior authorization processes. The thought then, and even at the publication of HTI-2, was that certified modules wouldn't help payers much because payers are not the ones implementing modules. The vendors who provide the administrative platforms are. As it stands, there are only disincentives to certifying under the program for payer health IT vendors (i.e., bringing them under the information blocking rule), so payers are really at the mercy of their vendors. This is in stark contrast to the impact the program has on EHR developers. That was until HHS' ASFR and ASTP/ONC released another proposed rule on August 9 that would require all providers and health plans (that means you, MA plans) that receive HHS funding to use certified health IT or adhere to ONC standards at a minimum. So, what does this mean? Payers who receive HHS funding could now have the regulatory support to require their vendors to be certified... If passed as written, payer health IT vendors that want to maintain their contracts with federally funded plans would not be able to "unreasonably limit" the exchange, access, or use of electronic health information - including charging an unreasonable fee. They could be penalized up to $1M per violation if they do. This is a huge deal. Luckily, the team at Maverick Health Policy summarized both proposals (linked below). If you need help navigating these changes, we're here to help. HTI-2: https://lnkd.in/g4McbwMy Acquisition Regulation: https://lnkd.in/gWY--VPb

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Suggestions on Choosing the Right Healthcare Proxy Choosing the right healthcare proxy is one of the most critical decisions you can make for your health and well-being. A healthcare proxy is someone who will make medical decisions on your behalf if you are unable to do so yourself. At Patient Advocates of Southwest FL, we understand the importance of this role. Based on first-hand and the experiences of more than a few clients, I’m here to share some key advice to help you make the best choice: 1.      Trust is Paramount: Select someone who understands your healthcare preferences and whom you trust implicitly to make decisions that reflect your wishes, not their own. 2.     Availability Matters: Your proxy should be generally available and can be present when needed, especially in urgent situations. Confirm they are willing and able to commit to this responsibility. 3.     Knowledge of Medical Matters: While they don't need to be a medical expert, choosing someone with a basic understanding of healthcare or who is willing to learn about your specific health conditions can be immensely helpful. 4.     Communication Skills: Your healthcare proxy should be a strong communicator. They will need to discuss your care with medical professionals and potentially other family members, advocating effectively on your behalf. 5.     Legally Prepared: Ensure that your healthcare proxy is legally documented. It’s always wise to consult with a legal professional to verify all paperwork accurately reflects your choices and is binding. Choosing the right healthcare proxy is about more than just fulfilling a role; it’s about ensuring that your healthcare decisions are in trusted hands. Your health deserves the utmost care and preparation. #HealthcareProxy #PatientAdvocacy #MedicalDecisions #HealthcarePlanning"

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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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"The Draining Impact of #StarkLaw Violations and the #AKS on the Healthcare System" ⚖️👨🏻‍⚖️ Stark Law violations and the Anti-Kickback Statute (AKS) pose a substantial threat to the integrity and efficiency of the healthcare system. These laws, designed to prevent fraud and abuse, are essential for protecting patients and taxpayers. However, their infringement can have far-reaching consequences. One of the most significant impacts is the inflated cost of healthcare. When providers engage in fraudulent billing practices, often facilitated by these violations, it leads to overpayments by insurers and government programs. This inflated spending ultimately burdens patients with higher premiums, deductibles, and out-of-pocket expenses. Additionally, the fear of legal repercussions can drive providers to order unnecessary tests or procedures, a practice known as defensive medicine, further exacerbating healthcare costs. Beyond the financial implications, Stark Law and AKS violations compromise the quality of patient care. When providers prioritize financial gain over patient well-being, it can lead to substandard treatment, misdiagnosis, and delayed care. Moreover, these violations can create barriers to entry for new providers, stifling competition and limiting patients' access to affordable care options. The administrative burden of compliance with these complex regulations is also a significant drain on healthcare resources. Providers must invest substantial time and money in compliance programs, diverting attention and funds away from direct patient care. Furthermore, investigations and legal proceedings associated with these violations can disrupt patient care, damage the reputation of healthcare providers, and erode public trust in the healthcare system. To address these challenges, a multifaceted approach is necessary. Stricter enforcement of these laws, coupled with clear and accessible compliance guidance, is crucial. Promoting transparency in financial relationships between providers and other entities can also help prevent conflicts of interest. Empowering patients to understand their rights and report suspected fraud is another essential component of a robust anti-fraud strategy. By implementing these measures, we can work towards a healthcare system that is both efficient and equitable. Ultimately, the eradication of Stark Law violations and AKS abuses is essential for ensuring a sustainable and patient-centered healthcare system. https://lnkd.in/ettnEKF8

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