From Tom's Desk

Bose, the world class sound equipment manufacturer, was sued this past week in Federal Court, accused of collecting information on the listening content individual users and selling it as metadata. Though some have responded with outrage and calls for boycott and new regulation, the public has most commonly responded with a shrug and a what-do-you-expect?  Overall, it seems that we, as a society, are getting used to the fact that our zone of privacy is shrinking rapidly.

 

I wonder what the reaction will be if a healthcare delivery organization (HDOs) is found selling PHI-free metadata from their electronic health record?

 

Exposing your secret Barry Manilow obsession is one thing, exposing your STD history is another. Even if you can be assured it’s not identifiable, you’re gonna be pissed.

 

I have absolutely no knowledge that such metadata sales by HDOs are going on, only that they are definitely a grey area within the impenetrable scrivenings that are HIPPA law . And I also know that, in an era when the actual delivery of healthcare services carries decreasing margins, organizations are looking for every possible revenue stream to help support their cashflow. In our current environment, based on no specific information whatever, I would be stunned if such information exchanges are not occurring—and you know you would be to.

 

If found liable, I suspect Bose was exposed by a disgruntled employee. Even though the reaction has been blasé thus far, the company’s secrecy and denials are certainly not going to enhance it’s corporate reputation.

 

It’s frightening to think what might happen to the first HDO caught with its hand in the cookie jar.

 

After all, as clinicians and HDOs, the actual product we sell is trust.

You Should Know...

Hospital owners, their administrators and consultants have been tearing through CMS’ annual Prospective Payment System Rates report  (link) https://www.regulations.gov/document?D=CMS-2017-0055-0001 released in the past week. The communication is chock full of adjustments to compensation and quality programs for FY 2018. As a former hospital owner myself, the report has always been a useful indication of healthcare trends and the deep thoughts of CMS.

This year’s was especially interesting.

 

Hidden deep in the hundreds of pages, was a call for public comment about revising regulations regarding physician ownership of hospitals.

 

The ACA dramatically restricted the ownership and expansion of physician-owned inpatient facilities—a restriction that the only physician-author of the act publicly admitted in the Wall Street Journal the biggest mistake the drafters made.. It’s unclear how much regulatory relief CMS can actually provide given that the restrictions are formerly written into law—there was certainly no real relief in the recent attempt in Congress to “repeal” the act. But the call for comments on this issue is the first I have ever seen since the ACA—and it suggests a sea change in CMS’ thinking.

 

In my travels, I have networked with several of folks at CMS who call for and review these comments. At night, in the hotel bar, after a long day of meetings and all the cynicism is shed—they will admit that indeed these comments have an impact on policymaking. And the more grass-roots, the better.

 

So whether you’re of the opinion that, even in the healthcare sector, competition reduces prices and improves services or that physicians and patients need regulatory protection from the self-dealing and cherry-picking opportunities that physician-owned health systems can allow, this is your chance to make you comment heard (link). It’s also surprisingly  easy to do so using the Federal Government’s comment portal. If you’re interested, give it a try.  

 

High-Value Insight

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Q&A with Dr. Tom

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