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183 posts categorized "Medicare"

April 11, 2013

PQRS: Alphabet soup with little meaning

Bartolomeu_Velho_1568I'm quoted in the current issue of Medical Economics, on the subject of the Medicare PQRS: Physician Quality Reporting System. I'm not a big fan of PQRS, since it rewards reporting of process measures, not outcomes, and the amounts at stake (up to a 2% bonus or, soon, penalty) have not been enough to move most docs to bother.

Here are my 5 PQRS tips, as reported in the article:

1. EHRs will help with data collection and processing. “You just have to keep your records properly. It’s a little bit of easy money for collecting information you should be collecting anyway,” Harlow says.  

2. The PQRS is a way to keep track of a set of measures that the Medicare program has deemed important. “Personally, I would prefer they would focus on six that would be the most predictive of outcomes,” he says, suggesting that the program could be a little bit more focused so that, after 5 or 10 years, it could be determined what measures are most predictive of good outcomes. “The danger is, physicians could focus on just the things that are being measured and the other things fall off the table.” 

3. A greater “bang for the buck” will occur as the private sector jumps on board, he says. Practices could make significantly more money on the private-payer side for reporting these measures. The more people get comfortable with reporting on and meeting these measures now, the easier it will be to incorporate doing so later.

4. “It’s not just about collecting the data, but to focus on [improvement] from one year to the next,” he says. “The focus on tracking [data trends] will enable you to take the next step.”

5. It’s better for providers to be ready for the shift to pay-for-performance sooner rather than later. Being able to show you aren’t just collecting data, but that you also are using those data to improve outcomes from year-to-year, will be increasingly important.

Bottom line: Look to the future, to reimbursement and care systems that leave behind FFS and all its add-ons like PQRS, like the ACO model (Accountable Care Organizations) and other innovations

The old system, with all of its adjustments and recalibrations, looks more and more like pre-Copernican astronomy, with the outrageous adjustments to a geocentric model that had to be made to explain behavior of a heliocentric solar system. I think we're all ready for a breath of fresh air.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting  

March 01, 2013

OIG review finds about 1/3 of all Medicare nursing home stays had inadequate care, care planning or discharge planning

OIGAs part of the US Department of Health and Human Services Office of Inspector General's current focus on nursing facilities, the OIG recently released a report entitled: Skilled Nursing Facilities Often Fail To Meet Care Planning and Discharge Planning Requirements.

From the OIG summary:

Skilled nursing facilities (SNF) are required to develop a care plan for each beneficiary and provide services in accordance with the care plan, as well as to plan for each beneficiary's discharge. These requirements are essential to ensuring that beneficiaries receive appropriate care and safely transition from one care setting to another. Several OIG studies and investigations found that SNFs had deficiencies in quality of care, did not develop appropriate care plans, and failed to provide adequate care to beneficiaries. In fiscal year 2012, Medicare paid $32.2 billion for SNF services. This study is part of a larger body of work about SNF payments and quality of care.


For 37 percent of stays, SNFs did not develop care plans that met requirements or did not provide services in accordance with care plans. For 31 percent of stays, SNFs did not meet discharge planning requirements. Medicare paid approximately $5.1 billion for stays in which SNFs did not meet these quality-of-care requirements. Additionally, reviewers found examples of poor quality care related to wound care, medication management, and therapy. These findings raise concerns about what Medicare is paying for. They also demonstrate that SNF oversight needs to be strengthened to ensure that SNFs perform appropriate care planning and discharge planning.

(Emphasis added.)

The OIG found, and CMS agreed, that CMS administrative enforcement efforts need to be beefed up on care planning and discharge planning, and that payment for services needed to be more closely tied to quality of services.

The negative findings implicate about 1/3 of skilled nursing facility stays, and over 15% of Medicare payment for skilled nursing facility stays.

In other arenas where health care providers are found to be out of compliance with Medicare conditions of participation, the Department of Justice tends to initiate actions under the False Claims Act to recover Medicare payments. (One example that leaps to mind involves the physician supervision requirements for diagnostic imaging under the OPPS rule.) Clearly, recoupment of $5.1 billion per year would be disastrous for the nursing facility sector, and since the OIG's recommendations included a mandate to clarify the regulations it is an unlikely result of this report. However, nursing facility operators should take note of this report and begin to address these areas of concern sooner rather than later.

The current report comes on the heels of a report issued late last year highlighting Medicare billing errors by nursing facilities that resulted in overpayments of $1.5 billion in 2009.  CMS committed to take appropriate action following receipt of that report, which could include recoupment of overpayments.

The OIG is currently looking at adverse events in skilled nursing facilities, which will be the subject of an upcoming report.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting 

December 12, 2012

Can Patient-Centered Care Reduce Hospital Readmissions?

A new Press Ganey white paper highlights an association between HCAHPS performance -- patient experience scores -- and lower rates of readmission. (Performance Insights - The Relationship Between HCAHPS Performance and Readmission Penalties.)

With Medicare payment penalties for excess readmissions now in effect, reducing readmissions has become a top priority for hospitals and other stakeholders. The Centers for Medicare and Medicaid Services (CMS) publicly reports risk-adjusted readmission rates for heart attack, heart failure and pneumonia. The data show significant variation in performance across hospitals, indicating that some hospitals are more successful than others at addressing the causes of readmissions. A new study by Press Ganey suggests that performance on readmission metrics is associated with performance on patient experience of care measures.

This study is an interesting look at the relationship between two value-based purchasing programs used by CMS to calculate Medicare payments to hospitals -- the Hospital Value-Based Purchasing Program and the Readmissions Reduction Program.

The key learning from this study is this:  

Effective communications is fundamental to ensuring that patients become engaged in their care and, consequently, better equipped to follow discharge instructions and self-monitor after leaving the acute care setting.

Coupled with patient-centered practices supported by past studies which have shown that "the single most effective strategy for improving patient satisfaction is purposeful hourly rounding by nursing staff," a "sustainable discharge" strategy is highlighted as a key predictor of avoided readmissions.

A sustainable discharge strategy comprises identifying and addressing patient-specific factors that could lead to readmission, strategic patient education, developing a patient-focused after-care plan and ensuring a smooth transition to a post-acute setting. Tactics that drive success in achieving sustainable discharges include: dedicated patient transition coaches, proactive planning for non-medical barrier to treatment adherence, post-discharge phone calls, scheduled follow-up care, and use of cross-setting discharge planning tools and teams.

In other words, a patient-centered discharge planning process, built on clear communications with the patient, is likely to reduce readmissions.

With more than 20% of Medicare beneficiaries discharged from an acute care hospital being readmitted within 30 days, at a cost of over $15 billion a year, and with over 2000 hospitals looking at readmissions reduction program Medicare payment penalties in FFY 2013 totaling $280 million, this is a significant issue -- but one where a potential solution is clearly at hand.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting

December 05, 2012

David Harlow featured in Becker's ASC Review: 6 Steps for ASCs to Participate in New Payment Models

Here's an excerpt from a piece in Becker's ASC Review quoting me on the effect ACO development and other health reform environmental changes are likely to have on ambulatory surgery centers, and how ASCs can position themsleves for future success

Here are six steps for surgery centers to participate in new payment models.

1. Figure out how to participate in ACOs productively. ACOs are becoming more common in different healthcare markets across the country and ambulatory surgery centers need to figure out how they can most productively participate. First and foremost, they should leverage the relationships they have with hospitals and physician groups for a seat at the table during the ACO formation.

"There is clearly a place for physician led ACOs because we are talking about developing systems to control costs that are ultimately directed by physician order," says David Harlow, principal at The Harlow Group, a healthcare law and consulting firm. "There is an opportunity for physician-led ASCs to participate in ACOs and benefit from the payment incentives that are included in the program simply because of the ability to improve quality and reduce costs over a baseline period, and that could fall to the ASC's bottom line."

Integration will be easier if the ACO is physician-led. Hospital-led ACOs may focus on filling hospital ORs; however, surgery centers also have partnership options if the ACO is hospital-led.

Follow the link to read about the other five.

For related information, check out the 2013 Medicare rate regulation for ASCs and my recent post on accountable care organizations and health reform after the election.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting


November 12, 2012

Health Reform After the Election: Accountable Care Organizations and Population Health

Much has been written and said about the effect of the election on the implementation of federal health reform initiatives.  The commentariat, including the blogerati and twitterati wings, have focused on the budget battles of the future to come from Capitol Hill, the flurry of regulations to come from HHS, and the last stand of the boys in red in certain state capitals around the country against implementation of health insurance exchanges and Medicaid expansion under the ACA.

I spoke recently about the importance of the Accountable Care Organization law and regulations, and related initiatives being undertaken by the Center for Medicare and Medicaid Innovation (CMMI) at CMS, and the ways in which these initiatives are likely to affect the next phase in the development of the health care system in this country.  I thought I'd share a few of the highlights here.

We have built a system of sick care in the USA, not health care, and the disruptive forces contained in the Affordable Care Act, including the ACO provisions, have the potential power to change our system to a system of health care – by changing the focus, by changing the incentives, by changing the behaviors of both patients and providers.

The goal for all of us in health care these days is to be better integrated with other parts of the system, so that we can do more with less in the future. We all know -- or should know by now -- that we will have to do more with less. The key to future success will be managing patients’ care and its attendant costs over the long term, managing an episode of care that extends beyond an inpatient surgery to encompass pre-admission and post-discharge services, managing a chronic condition with a multidisciplinary approach using medicine, nursing and even social media and game theory to motivate patient behavior modification. We need to move from reimbursement-based medicine to evidence-based medicine.

When the ACA was enacted, folks likened the ACO to the unicorn: Nobody's ever seen one, but everyone knows exactly what it looks like.  Once the ACO regulations were finalized, I called it as I saw it: the ACO is a camel -- a horse designed by committee. And now I see the ACO and related initiatives under the ACA as a camel with its nose in the tent: a disruptive force beginning to change the world as we know it.

When the final ACO rules came out about a year ago, CMS actuaries predicted that there would eventually be about 270 Medicare ACOs -- including large and small organizations and urban and rural organizations -- by the end of three years (we are less than one year in at this point), providing care to up to 2 million Medicare beneficiaries.  We're on track to get there and beyond, with over 150 Medicare ACOs already approved and several hundred more applications queued up for the future. (Keep in mind there are approximately 150 commercial ACOs out there as well – according to an inventory updated this spring by Leavitt Partners.) 

In addition to the estimated 270 Medicare ACOs, HHS estimates up to $1 billion in savings to Medicare over four years, and the Congressional Budget Office estimates $5 billion in savings over eight years.  At first blush, these look like impressive figures, until we recall that there are 6000 hospitals in the US, nearly 50 million Medicare beneficiaries, and that Medicare is a $500 billion line item in FFY 2013 alone. The ACO initiative is a drop in the bucket.

The ACO initiative is generating a lot more interest than perhaps they should, based on these numbers – but this is legitimate, for a couple of reasons.  ACOs really form the conceptual building blocks for a new approach to achieving the Triple Aim – which is now the mission of CMMI: Better Healthcare, Better Health and Lower Costs Through Improvement. CMMI seeks to: "Encourage better health for entire populations by addressing underlying causes of poor health, such as physical inactivity, behavioral risk factors, lack of preventive care and poor nutrition."  It is using the levers of the ACO program to enlist ACOs in the execution of this element of its mission.

So, the camel’s nose is in the tent – we're at the leading edge of a significant disruption built around the Affordable Care Act’s provisions on ACOs and related initiatives: a sea change in the way health care is conceptualized, and radical change in delivery and payment systems.  We’re ahead of the curve on these issues in Massachusetts, with a law passed this summer that will move us into ACOs for all -- not just Medicare beneficiaries -- and away from fee-for-service medicine, and a local Blue Cross-Blue Shield plan known as the Alternative Quality Contract that has been working on this basis -- budgeted caps with quality kickers -- for several years already. It’s the latest form of pay for performance, or value-based payment.

An ACO has to have at least 5000 Medicare beneficiaries attributed to it, but the beneficiaries cannot be forced to enroll in a closed network. Because Congress sees elimination of choice of provider as a third rail of health care, ACOs do not know for certain which patients will have more than 50% of their primary care encounters with an ACO PCP in any given year and thereby be attributed to the ACO, Thus, in order to succeed, ACOs must be focused on population health, on prevention and wellness in a population, not just on individual encounters with patients.

CMMI is also using the power of the purse -- its $10 billion budget, to be spent over ten years on experiments with the health care system.  Nearly two dozen experiments are already under way, including three flavors of ACOs. While CMMI is experimenting with a wide variety of methods to incentivize health care providers to change the way they provide care (check out the CMMI "What We're Doing" page), the health care providers participating in these innovations should be laser-focused on the 10% of chronically ill Medicare beneficiaries whose health care expenses consume 50% of the Medicare dollar. If they change their approach to managing these patients' care through patient-centered medical homes or otherwise, there are great opportunities to achieve significant savings through avoiding preventable hospitalizations and the like.

The keys to success will be clinical integration -- not just in word but in deed -- and turning data into actionable intelligence.  Health care systems that can achieve these two interim goals will be well-positioned to achieve the broader goals of improving population health and quality of care while bending the cost curve -- and not just for Medicare beneficiaries attributed to Accountable Care Organizations.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting

May 06, 2012

Nothing About Me Without Me - Participatory Medicine, Meaningful Use, and the American Hospital Association

Meaningful Use Stage 2 regulations were released in March by CMS and ONC.  Over the past month or so, I've been working with other members of the Society for Participatory Medicine (thank you, all) to prepare comments on these regulations from the patient perspective.  Last Friday, we filed two comment letters on the proposed regulations. One letter to the ONC on Meaningful Use Stage 2, and one letter to CMS on Meaningful Use Stage 2. Each letter opens like this:

The Society for Participatory Medicine applauds the work done to date in focusing on patient engagement in the proposed Stage 2 Meaningful Use regulations and the proposed Health IT Standards regulations.  It is our hope that the final requirements will be even stronger and more focused in this regard than the current drafts. As set forth in greater detail in the attached letter, we have a number of comments that we believe will improve the regulations and their use as a lever to improve patient experience, patient engagement, patient care and, ultimately, patient outcomes. We would like to highlight two in particular:

  • We favor improving the likelihood that patients will access their data by allowing for some automation of the process of accessing and downloading patient data, using existing technologies that protect patient privacy and security.
  • We also favor immediate patient access to information in the patient’s electronic health record – unless the patient has elected otherwise.

The overarching principle with respect to patient access to electronic health record data running through the entire meaningful use regulation and the health IT standards regulation should be:

    “Nothing about me without me.”

The Society for Participatory Medicine has individual and institutional members nationwide and has a governing board comprised of both clinicians and patients. It was founded to study and promote participatory medicine, which we define as being centered on networked patients shifting from being mere passengers to responsible drivers of their health, and providers who encourage and value them as full partners. For further background on the Society and its activities, we invite you to see the Society’s website (, its online journal, The Journal of Participatory Medicine ( and its blog,

Comments are being accepted through Monday May 7, 2012.

I invite you to read the Society for Participatory Medicine press release, Participatory Medicine Society Urges Quick Patient Access to Medical Information, outlining the Society's stance on the issue, and the recent posts on the Society's blog,, explicating the SPM Meaningful Use Stage 2 comment letters a little further, and putting them in context -- in particular, juxtaposing them against the American Hospital Association comments calling for a 30-day delay in patient access to information once it's in their EHRs.  (The proposed rule calls for up to 36-hour and 4-business-day delays, depending on context, and the SPM comments call for immediate access.)  Technologically literate commentators, including Fred Trotter, take issue with the AHA's view that 30 days are needed to respond to a request for an EHR.  (Fred's post says a lot more -- check it out.)  

Finally, take a few moments to consider Regina Holliday's comments on the proposed rules, filed in the form of a slideshow featuring her paintings:

Long Stories: The Story Of Meaningful Use and Why the patient voice matters..

March 23, 2012

Pay For Performance and HCAHPS

"There's nothing better at incenting than money."

Setting aside for a moment the mangling of the English language in this quote (see the full article on HCAHPS and P4P), we can probably agree that financial incentives are often a reasonable way to evoke desired behavior change.

At the moment, we're talking about providing care in a way that evokes favorable responses by patients on the HCAHPS questionnaires. Hospitals that have been attentive to patient satisfaction matters -- as measured by HCAHPS -- will be the winners; others, the losers, in the Medicare zero-sum-game of value-based hospital reimbursement.

We love, love, love metrics. We think that if we dole out financial rewards based on metrics, then health care will be improved. So we've developed about 1,000 quality measures (see National Quality Forum (NQF) measure list), and we ask providers to track performance on too many of them, on the theory that you cannot manage what you do not measure -- an aphorism with truth to it, but folks, we have run amok with measures.

Since we don't track all 1,000 all at once, we end up focusing on the dozen or so metrics in front of us at any given time, and other things fall off the table. 

I would love to see six or eight ur-measures that are predictive of quality across a broad spectrum of issues. I've had the opportunity to discuss this and related P4P issues with some leaders in the field, and offer for your listening (or reading) pleasure (well, OK, it's subjective ...) interviews I've done with Leah Binder of the Leapfrog Group, Don Berwick before he went to work for Uncle Sam and Cyndy Nayer & Wayne Burton of the Center for Health Value Innovation.

So what do you think about pay for performance?

What works? What doesn't?

If you were king/queen of P4P, what would you do?

David Harlow
The Harlow Group LLC
Health Care Law and Consulting


November 08, 2011

Increasing Medicare Eligibility Age and the Law of Unintended Consequences

On my way to the annual two-day blowout health law seminar put on by Massachusetts Continuing Legal Education (MCLE) on Monday -- I was second in the lineup, speaking about post-acute care and some of the innovations in that arena for dual eligibles, among other things -- I heard a fascinating piece on NPR on one of the ideas floating around the supercommittee charged with cutting $1.2 trillion from the federal budget.  The idea: increase the minimum age for Medicare eligibility from 65 to 67, and save a bundle for Medicare in the process.

The problem with this deceptively simple idea (Social Security eligibility is migrating from 65 to 67, too, so it seems to be a sensible idea on its face), is that while it would save the federales about $6 billion, net, in 2014, it would cost purchasers of non-Medicare coverage (employers and individuals) about $8 billion, net.  Why?  The 65 and 66 year olds are the spring chickens of Medicare -- they actually bring Medicare average costs down, because they're healthier than the Medicare population as a whole. However, when compared to the working population, they are the older, sicker cohort, so they would drive costs up if insured in the commercial market.

Monday's post in this space was on the 2012 MPFS (Medicare Physician Fee Schedule) and the continuing Sustainable Growth Rate (SGR) debacle, and it prompted an email from a reader pointing to a predictable but ultimately unsympathetic plea to please not cut THAT program, because it's Important.

They're ALL important, folks.  

The cold, hard truth is that we need to figure out how to do more with less -- in every program, for every worthy cause.  We need to learn how to work collaboratively, tear down the silos, and activate every other cliche in the book.  Collaborative thinking, inspired by changes in the economic drivers -- i.e., reimbursement models -- that have led to more siloed thinking in the past, is hard to do, but actors in the health care economy need to get better at it - and fast.

The Bundled Payment Initiative, ACOs and sons of ACOs, the Medicare-Medicaid Coordination Office, and more innovations coming out of CMS, driven by the ACA, are all encouraging developments, pushing providers in the direction of collaboration, and while we may have to deal with some unintended consequences a long the way, these are some important experiments that must be conducted.  And the people are with Washington on this one: An RWJF/Harvard School of Public Health survey released this week found that most folks want the federales to grow their role in the health care system.  Not what we might have expected, but an encouraging sign that folks understand that the problem before us is a big one, requiring significant resources in working towards solutions.

David Harlow 
The Harlow Group LLC
Health Care Law and Consulting


November 07, 2011

MPFS 2012 -- The 2012 Medicare Physician Fee Schedule is Finalized issued the final MPFS -- the Medicare Physician Fee Schedule for 2012 -- this past week. The key feature of the rule, for many folks, is the Sustainable Growth Rate-(SGR)-mandated 27.4% cut in Medicare professional serivces reimbursements. We now get to watch the drama unfold over the next eight weeks, as the MedPAC proposal to replace the SGR is bandied about, and the machinations of the supercommittee tasked with brokering a budget fix either do or do not get us closer to a reasoned approach to doing more with less.  The MedPAC idea is to drop the RBRVS conversion factor for specialty care payments 5.9% per year for two years, then hold it steady for 8 years, while keeping the primary care conversion factor flat for 10 years.  The net effect: physician payments will "only" double over the next 10 years.  (One clever idea squirreled away in the MedPAC report is that savings in the Medicare Shared Savings Plan (ACO) should be measured against a baseline of what Medicare would have spent on the care absent the changes in the proposed SGR fix -- i.e., a higher baseline, with greater potential savings.  Another 50 clever ideas like this and we'll be talking about saving some real money.)

Well, the SGR will be fixed (or not) by Congress, not CMS.  The rest of the MPFS includes a variety of approaches to getting hands around the question of accuracy of the fee schedule.  For example, per the CMS presser:

  • CMS is expanding its multiple procedure payment reduction policy to the professional interpretation of advance imaging services to recognize the overlapping activities that go into valuing these services.  This policy better recognizes efficiencies that are expected when multiple imaging services are furnished to the same patient, by the same physician or group practice, in the same session on the same day.
  • CMS is adopting criteria for a health risk assessment (HRA) to be used in conjunction with Annual Wellness Visits (AWVs), for which coverage began Jan. 1, 2011 under the Affordable Care Act.  The HRA is intended to support a systematic approach to patient wellness and to provide the basis for a personalized prevention plan. CMS is increasing AWV payment modestly to reflect the additional office staff time required to administer an HRA to the Medicare population.
  • CMS is expanding the list of services that can be furnished through telehealth to include smoking cessation services.  CMS is also changing the criteria for adding services to the telehealth list to focus on the clinical benefit of making the service available through telehealth.  This change will affect services proposed for the telehealth list beginning in CY 2013.
  • The final rule updates or modifies aspects of a number of physician incentive programs including the Physician Quality Reporting System, the ePrescribing Incentive Program and the Electronic Health Records Incentive Program.
  • The final rule also finalizes quality and cost measures that will be used in establishing a new value-based modifier that would adjust physician payments based on whether they are providing higher quality and more efficient care.  The Affordable Care Act requires CMS to begin making payment adjustments to certain physicians and physician groups on Jan. 1, 2015, and to apply the modifier to all physicians by Jan. 1, 2017.  CMS intends to work closely with physicians to ensure that efforts to improve the quality, safety, and efficiency of care do not diminish patient access to care.  The rule also finalizes CY 2013 as the initial performance year for purposes of adjusting payments in CY 2015.
  • The final rule also implements the third year of a 4-year transition to new practice expense relative value units, based on data from the Physician Practice Information Survey that was adopted in the MPFS CY 2010 final rule.

In addition, CMS is expanding the "potentially misvalued code initiative," an effort to ensure Medicare is paying accurately for physician services and more closely managing the payment system.

Finally, after struggling over time with varying requirements for lab test "requisitions" and "orders," which resulted in a CY 2010 requirement for a signed order prior to labs being drawn/done, CMS is backing off of that requirement, in response to comments detailing the ways in which this would reduce patient convenience and have the potential to negatively affect care.

Other issuances out the same day include the 2012 OPPS /ASC rule and the ESRD PPS rule.

David Harlow 
The Harlow Group LLC
Health Care Law and Consulting


October 25, 2011

David Harlow presents two webinars this week: one on health care social media, the other on accountable care organizations

I am presenting two webinars this week, one on health care social media and the other on accountable care organizations, or ACOs.


Health Care Social Media: An Introduction to Engaging Intelligently and Legally

(Title links to registration information)

Webinar: Tuesday, October 25, 2011 

Time: 12:00 p.m. to 1:30 p.m. ET

Health care organizations, professionals and patients alike are embracing the social media movement with vigor as online tools like blogs, Facebook, Twitter and YouTube grow in popularity. It is no longer a question of whether you should be using social media tools to promote your practice and institution and connect – effectively, legally and ethically -- with patients and referral sources; it is a question of when, and how.  

A skilled user of social media has the opportunity to become a trusted source, a convener, an influencer; and can effectively and efficiently utilize these tools for reputation enhancement and building strong relationships with existing patients and referral sources while “expanding the sales funnel” to attract new patients and referral sources.  However, the use of these tools requires interaction and engagement at a level that many health care organizations find uncomfortable. Balancing the inherent tension between transparency and privacy, openness and control, can be difficult. While the legal land mines are there, you can make your way through and emerge unscathed if you have a clear understanding of HIPAA and other relevant rules – and how they apply to social media initiatives.  

Learn more during this interactive 90-minute webinar about the value of social media tools, the range of issues they present, and some key strategies for using these tools effectively while steering clear of trouble by social media expert and charter member of the Advisory Board of the Mayo Clinic Center for Social Media, David Harlow.  Become comfortable with social media for your facility!

Learning Objectives:

  • Gain greater familiarity with social media tools and tactics and their value to the health care enterprise.
  • Achieve understanding of legal, regulatory and risk management issues related to the use of social media in health care.
  • High-level introduction to best practices.

Accountable Care Organizations, Bundled Payments, and the Future of Health Care

(Title links to free registration information)

Webinar: Thursday, October 27, 2011

Time:  1:00 p.m. to 2:00 p.m. ET

David Harlow previews HCPLive Webinar on ACOs

In the future (starting tomorrow!) health care providers will have to do more with less. Total reimbursement by both public and private sector payors is dropping, and the metrics for success are changing. Instead of thinking about this as a zero-sum game, payors and providers are moving away from fee-for-service payment systems to bundled payment systems. The health reform law spells out one such program in detail -- the ACO, or shared savings, program -- and created the CMS Center for Innovation, and funded it with $25 billion. The Center for Innovation’s mandate is to run experiments on how to do more with less, and to scale up successful experiments quickly.  

In this webinar, noted attorney, consultant, blogger and speaker David Harlow will describe the future contours of the health care market, defined by emerging federal and private sector programs in a post-fee-for-service environment, and identify ways in which provider organizations should be preparing themselves in order to succeed in this brave new world.

Join the simultaneous tweetchat at #ACOchat.

See you later this week.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting