Health information management (HIM) professionals that have been paying attention to the news and regulations coming out of Washington, DC, likely won’t be surprised by the changes coming in 2019. Code set updates occur every year and the fact that the government is due to release interoperability guidelines promised by the 21st Century Cures Act isn’t new information. However, provider and stakeholder response to these developments will shape the year to come. Hot topics for 2019 will be the implementation and enforcement of MACRA’s payment models, efforts to modernize HIPAA, and likely advancements in interoperability and health information exchange. Below industry HIM experts weigh in on important 2019 topics that will shape the HIM and healthcare industries.
Coding and CDI Grapple with New Payment Models
New coding regulations go into effect almost every year on January 1, and this year is no exception. Dipak Patel, chief growth officer of Himagine Solutions, says coding and clinical documentation improvement teams are keeping their eyes on the following changes this year:
- Evaluation and management (E/M codes) level changes.
- New technology codes in PCS coding. High reimbursement rates are attached to each specific code and healthcare facilities will not get reimbursed if they are not coded. These codes can be easy to miss and are creating a lot of buzz currently in the industry as a high-dollar missed coding opportunity.
- New, specific ICD-10-CM history codes for metastatic sites. Coders need to be aware and begin capturing these when reporting codes for cancer patients.
- In CPT coding there are a number of changes and revisions to skin biopsy codes. This could be challenging even for experienced coding professionals.
- The removal of the “no device” option for all spinal fusions in PCS codes.
Melanie Endicott, MBA/HCM, RHIA, CDIP, CHDA, CPHI, CCS, CCS-P, FAHIMA, vice president of HIM practice excellence at AHIMA, says this year coding professionals working for physician practices are going to be concentrating on complying with quality metrics and getting paid for the value provided rather than the number of patients seen. Endicott also notes that 2019 is the year that the Centers for Medicare and Medicaid Services (CMS) gets picky about ICD-10 coding in skilled nursing facilities (SNFs).
“The other thing in coding that we’re hearing about for the SNFs is October 1, 2019 they’re having a whole new payment model coming out and it’s requiring the use of ICD-10-CM codes. They’ve always had to use them before, but it was more like ‘Just pick one and put it on there, it’s no big deal, no one cares,’” Endicott said. “But starting October 1, 2019 they’re going to start caring. CMS is going to look at them more specifically and see if they’re [the codes] right on the patient’s chart and it needs to match up with the care provided to them. AHIMA’s actually doing a big training on this for that setting to get up to speed in the next few months.”
HIPAA Modernization Will Continue
Both AHIMA and the government will be building on existing efforts to update and modernize HIPAA in 2019. In mid-December, the Department of Health and Human Services Office for Civil Rights (OCR) issued a request for information (RFI) seeking input from the public on how the Health Insurance Portability and Accountability Act (HIPAA) Rules, especially the HIPAA Privacy Rule, could be modified to further the HHS Secretary’s goal of promoting coordinated, value-based healthcare. In their request, federal officials expressed concern that certain aspects of the HIPAA Privacy Rule impede the kind of information sharing needed to fight the opioid epidemic.
AHIMA has been working with American Medical Informatics Association (AMIA) to advance the modernization of elements of HIPAA, including advocating for expanding the law’s record access provisions to non-covered entities and better defining HIPAA’s “designated record set” (DRS). AHIMA and AMIA held a Capitol Hill briefing on this subject in December.
Lauren Riplinger, JD, AHIMA’s senior director for federal relations, says AHIMA will continue to monitor these efforts in 2019. She said AHIMA and AMIA will work to develop a policy brief explaining why changes to HIPAA are needed.
“From a top line perspective, [we are] looking at ways we can modernize [HIPAA]. Patient matching and aligning of privacy laws at the federal and state level is definitely a priority,” Riplinger said.
Riplinger also noted that AHIMA continues to advocate for interoperability efforts, including patient matching, which it did during a White House briefing also in December.
“The White House said last week they will continue to seek private industry solutions to the patient matching challenge,” Riplinger said. “Our perspective is that government needs to at least be at the table to have these discussions with private stakeholders at large.”
More to Come on 21st Century Cures and Interoperability
Congress overwhelmingly passed the 21st Century Cures Act in 2016. This year, the industry anxiously awaits the second draft of the Trusted Exchange Framework and Common Agreement (TEFCA) from the Office of the National Coordinator for Health IT (ONC), which is one of the deliverables required by the Cures Act that’s supposed to help create a common set of principles for trusted exchange of electronic health information, as well as minimum terms and conditions that healthcare providers must meet when exchanging health information.
“Last year we had the draft come out early in the year. AHIMA commented. Now we’re waiting for the second draft to come out. After that the anticipation is that it will potentially be finalized. They really had to go back to the drawing board after their first draft and make sure they’re creating TEFCA in the right way to enhance interoperability,” Riplinger said.
Senator Lamar Alexander (R-TN) says Congress will continue to have oversight over the law’s implementation, and Riplinger predicts more conversations between ONC and stakeholders.
“Since the passage of the 21st Century Cures, ONC has laid the groundwork to release information blocking regulations, improve patient health data access, and promote interoperability,” Patel said . “With that said, we are still waiting on the details of several components of the 21st Century Cures Act including information blocking, TEFCA, and the strategy to reduce regulatory and administrative burden. Each of these areas will greatly influence the future of HIM.”
ONC chief Donald Rucker, MD, in Congressional testimony in December, rated the country’s overall interoperability at a C-, according to Health Data Management, while noting that ONC will help address this with the forthcoming release of the updated version of TEFCA.
Mariann Yeager, MBA, CEO of the Sequoia Project, however, has a much more optimistic outlook. “For me, I don’t look at grading where we are in terms of the ideal because there’s so much opportunity, it’s like grading an unending scale. For me it’s measuring progress. I think we get an A+ in terms of progress,” Yeager said. “Are we where we need to be? No, but it’s got to be an iterative progress over time. I’ve always said we know interoperability is starting to take root when the providers start complaining about the data. That means connections exist and they want to rely on it which is really valuable. So I think we get an A+ for connectivity, maybe a B for content.”
Yeager says information exchanges helped during the catastrophic wild fires in California this fall, and will play a part in any future natural disasters that occur in 2019. Though health information exchanges (HIEs) didn’t provide information for every single evacuee, it did help provide critical information for hundreds of others.
“They were cared for properly. That’s something we can’t discount. We’ve built national infrastructure—we just need to continue to advance and modernize—but not discount the hard work to date. We need to celebrate our successes along the way,” Yeager noted.