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HLN Submits Comments to CMS on IPPS NPRM

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HLN Submits Comments to CMS on IPPS NPRM

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemakin ...

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program based on our earlier comments:


HLN Consulting, LLC is pleased to submit the following comments on the recently-released CMS IPPS NPRM, CMS–1694–P. HLN is a leading public health informatics consulting company. With that in mind, we read documents like the NPRM through a public health lens, and confine our comments to that important context.

Thoughts on the CMS IPPS NPRM: A Public Health Perspective

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Thoughts on the CMS IPPS NPRM: A Public Health Perspective

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rule ...

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program (one from AMIA, one from CDC). Here are just a few additional tidbits I picked out of the NPRM.

Of course, this document is written like stereo instructions so I welcome any corrections or comments to my interpretation of what’s in the rule. I put page numbers (from final FBO version referenced above which has just been released) where relevant in parenthesis.

HITAC USCDI Task Force Delivers its Recommendations

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HITAC USCDI Task Force Delivers its Recommendations

On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core D ...

On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core Data for Interoperability (USCDI) and Proposed Expansion Process which had been published for public comment back in January 2018. HITAC promptly accepted the Task Force’s recommendations.

The Task Force focused almost exclusively on the process for identifying the USCDI rather than the proposed USCDI data itself. I especially appreciated their introduction of some key concepts related to how USCDI should be organized and understood. It has always bothered me that the current Common Clinical Data Set (CCDS) upon which the current draft USCDI is based contains a variety of types of data at different levels of analysis: for instance, a single discreet data element (like date of birth or sex) sits alongside more complex data constructs (like address, which contains many discreet data elements within it) which sit alongside even more complex data types (like immunizations or procedures). The Task Force introduces a notion of hierarchy to make this more sensible: data classes (high level topic like “demographics”), data objects (a single item within a class, like “address” within the class “demographics”), and data object attributes (a specific data element within a data object, like “zip code” within “address”).

From a process standpoint, the Task Force recommended an expanded set of steps which has an emphasis on more stakeholder participation and less ONC pronouncement. This includes a recommendation for patient input as well. These are welcomed additions and I certainly hope they will be operationalized by ONC.

HLN-authored White Paper published by NYeC: The Case for Payer Participation in Health Information Exchange

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HLN-authored White Paper published by NYeC: The Case for Payer Participation in Health Information Exchange

The New York eHealth Collaborative (NYeC) recently published a new white paper authored by Dr. Noam Arzt, President of HLN, titled The Case for Payer Participation in Health Inform ...

The New York eHealth Collaborative (NYeC) recently published a new white paper authored by Dr. Noam Arzt, President of HLN, titled The Case for Payer Participation in Health Information Exchange.

Health information exchanges (HIEs) are collaborative efforts that focus on health data exchange on a community, regional, or statewide basis. HIEs are quite diverse; their services have yet to be fully leveraged by the payer community. HIE is an important tool in improving the quality of patient care and outcomes, increasing accuracy and speed of diagnosis, eliminating unnecessary or duplicative tests and procedures, and reducing healthcare expenditures. Payers who participate in HIEs can experience greater oversight and can be better equipped to manage and coordinate patient care.

HLN Participates in Stewards of Change Regional Symposium

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HLN Participates in Stewards of Change Regional Symposium

On March 27-28, 2018, Dr. Noam Arzt, President of HLN, participated by invitation in the Stewards of Change National Interoperability Collaborative Symposium on Advancing Informati ...

On March 27-28, 2018, Dr. Noam Arzt, President of HLN, participated by invitation in the Stewards of Change National Interoperability Collaborative Symposium on Advancing Information Sharing in California and Beyond on behalf of the Healthcare Information and Management Systems Society (HIMSS). In attendance was a small, but diverse set of stakeholders across the health, human services, education, and criminal justice with an interest in improving data interoperability between systems with these diverse domains, with a special emphasis on efforts in California. Sponsored by the National Interoperability Collaborative (NIC) this symposium represents a continuing expansion of the Stewards of Change focus from human services into the health domain. This expanded conversation will allow public health to participate more fully as the shift to our collective concern about wellness requires a more holistic view of people, their requirements, and their circumstances. We look forward to continuing engagement with this community and an opportunity to bring what we have learned in public health about interoperability into this new forum.