february 11, 2013 monday memo health reform update · february 11, 2013 monday memo health reform...
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Deloitte Center for Health Solutions
February 11, 2013
Monday memo
Health reform update
This week’s headlines: My take
Implementation update - CBO budget and economic outlook—new health care projections:
spending, coverage assumptions, and cost of ACA - Report: IRS did not receive adequate funding to implement ACA - Commission on long-term care appointed - Costs of ACA calculated - Basic health plan implementation delayed to 2015 - Rate review rule in final review at OMB
Legislative/regulatory update
- Permanent SGR fix proposed - CMS proposes rule to reduce regulatory burdens for providers - Tavenner nominated to top CMS post - CMMI announces bundled payment program for kidney dialysis
State update
- CMS guidance to states: Medicaid cost sharing for newly eligible
- State round-up: HIX
- Medicaid expansion update
- State round-up
Industry update - Survey: ACA’s major impact on how larger employers handle part-time
employees - Three updates on information-driven health care
VA and DOD will not use a single EHR system AHRQ, CMS launch EHR for pediatrics Survey: implementation deadlines, infrastructure major
challenges for CIOs - FDA releases guidance on Alzheimer’s trial designs
Research snapshots
- Alzheimer’s projected to triple in U.S. by 2050 - Death rates in acute care decreasing
Quotable
Fact file
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My take
From Paul Keckley, Executive Director, Deloitte Center for Health Solutions
State of the health care union
Tomorrow, the President will deliver the State of the Union (SOTU) address
highlighting his goals and legislative priorities for 2013 and beyond. The choice of
Lincoln’s birthdate punctuates the gravity of the nation’s situation due to complicated
world events and enormous fiscal challenges at home.
SOTU is a time-honored tradition of our Republic. Article II, Section 3 of the U.S.
Constitution, requires that the President “shall from time to time give to Congress
information of the State of the Union and recommend to their Consideration such
measures as he shall judge necessary and expedient.” George Washington was first
to give the “Annual Address to Congress” on January 8, 1790, FDR gave it a new
name—“State of the Union”—in 1934, and since 1947 it’s been SOTU officially.
No doubt, economic recovery, jobs, gun control, immigration reform, and national
defense will be prominent themes in the President’s comments tomorrow. And, we
expect, health care!
As an industry, we’re one-fourth of the federal budget, one-fifth of the average
household budget, and approaching one-third of the average state’s budget. One-fifth
of our population lack coverage of any kind, their cost is borne by taxpayers, and
across the nation, care is uneven and highly variable in cost and quality.
In his inaugural address last month, the President called out health care costs in
tandem with deficit reduction as interdependent, trans-generational challenges that
must be addressed:
“We must make the hard choices to reduce the cost of health care and the size of our
deficit. But we reject the belief that America must choose between caring for the
generation that built this country and investing in the generation that will build its
future.”—President Obama, January 21, 2013
It’s about Medicare and Medicaid for sure, but health care is more than these two
programs and its transformation a necessary part of overall economic recovery and
deficit reduction.
Here’s my state of the health care union assessment as the nation addresses the
fiscal cliff, grand bargain, debt ceiling, and continuing resolution in the next eight
weeks:
Factor Key indicators Grade1
Incentives to do the right
things: to reward results,
not volume, and encourage
team-based care delivery
that balances preventive,
chronic, and episodic acute
and long-term care
Financial incentives that reward safety,
outcomes, and efficient delivery of care
that’s evidence-based and appropriate
Rewards, recognition, and penalties
aligned with financial incentives
Balance of full range of health services
in scope: preventive, chronic, acute,
long-term
C+
Anticipated trending to B as
value-based care becomes
mainstream in purchasing
relationships between payers
and providers
Tools to measure and
monitor the right things:
valid and reliable
measures of efficiency,
effectiveness, and value
Online tools that permit individuals and
their care teams to customize diagnosis
and treatments based on unique signs,
symptoms, risk factors, and co-
morbidities
Mobile applications that equip
consumers to engage in treatment
decisions at the point of care, with full
access to their complete medical history
and clinical decision support tools that
provide guidance about accuracy of
diagnosis and appropriateness of
treatments
Standardized forms and procedures for
eligibility, claims adjudication, and
administrative functions across all
private plans including Medicaid and
Medicare
Clinical and cost data that’s structured
for optimal use by individuals to know
what treatment options they have at
what cost to them in teachable
moments when decisions are made
B-
Anticipated trending to B+,
may be reachable when
privacy and security, among
other issues, are settled
Accountability for doing
right things: readily
accessible transparent
measures that recognize
exemplary performance
and underperformance
Transparency of performance: safety,
outcomes, patient/member
experiences, coverage and denial
decisions, scientific support for
innovations, conflicts of interest (plans,
biopharma, device)
Penalties for poor performance
(providers)
Penalties for unhealthy behaviors
(consumers)
Balanced funding for the entire
continuum of care (policy-makers)
C-
Uncertain trend line as
medical liability reforms are
missing in current reforms and
individual accountability for
healthier lifestyle not
prominent in current policies
Funding to accommodate
finding and accelerating
access to diagnostics and
therapeutics that allow
discovery of the right
things inside and outside
allopathic models of care
across the population
without regard to insurance
coverage, health status,
ethnicity, or income
Public funding for access to needed
services and basic research to fuel
innovation in the diagnosis and
treatment of medical problems
Private funding for innovations,
research and development, growth
Private funding for elective services
Individual/household funding from
discretionary resources adequate to
health care needs
B+
Anticipated trending to B- as
fiscal pressures are expected
to reduce public resources
allocation, and household
incomes require trade-offs
between health and other
essential services; funding
levels are considered
adequate today, but are
expected to be increasingly
scarce tomorrow
Structure that makes it
efficient to do the right
things without unnecessary
paperwork, regulatory
confusion, and shared
responsibilities for results
Seamlessness in the system of finance
and delivery
Balanced approach to preventive,
chronic, acute, and long-term care
services
Synergy bridging gaps between human
D
Anticipated trending to B as
industry consolidation, clinical
integration, and technologies
for care coordination are
expected to become
services and health
Consistency between state and federal
regulatory/legislative framework
mainstream
Market demand to do the
right things among
consumers, policy-makers,
and industry stakeholders
who set aside
sectarian/provincial
interests to consistently
transform the system of
care
Consumer demand for improved value
Employer demand for improved value
Stakeholder demand for improved value
Bipartisan efforts to balance care and
costs, access, and innovation, public
oversight and private interests
B-
Anticipated trending to B as
growing numbers of
individuals and purchasers are
expected to demand improved
service, transparency, and
payments linked to results
Affordability to provide
goods and services at
prices that are reasonable
and transparent
Price transparency
Understandable relationship between
costs and price
Costs that are aggressively managed to
achieve competitive advantage
Consistent operational focus on radical
cost reduction
D
No near-term trending
obvious; costs and pricing
unrelated; cost and price
transparency suboptimal
The state of the health
care union
Seamless delivery of services and
resources that are evidence-based,
highly valued, and cost effective across
the continuum of care. There is no
“health care union,” it is still a system of
sectarian special interests.
B-
1 The grades included in this assessment are based solely on the author’s knowledge
and experience and are not intended to indicate an objective analysis of the state of
health care in the U.S.
The current debt of the U.S. is approaching 72.5% of our gross domestic product
(GDP)—up from 36% in 2007 and fast-moving toward 77% by the end of the decade
per the U.S. Congressional Budget Office (CBO) report last week. For the current
fiscal year (FY 2013) which ends September 30, the CBO projects a deficit of $845
billion, or 5.3% of GDP—below the peak in 2012 of $1.1 trillion, but the fifth
consecutive year of deficits approaching or above $1 trillion. The report did note that
Medicare and Medicaid increased “only” 3%, however, it is nonetheless daunting
when contrasted to overall GDP—the CBO estimates that Medicare, Medicaid, and
the Children’s Health Insurance Program (CHIP), and other federal health care
subsidies enacted by the Affordable Care Act (ACA) will amount to almost 5% of the
GDP this year and 6.2% in 2023.
So here’s the bottom line: the government is spending more than it can afford if the
economy is to thrive and achieve full employment (95%) and a rate of growth that
rewards innovators and risk takers in the world’s strongest economy. Health care
spending—at 5.7% year-over-year growth for the next decade per the CBO—is a
major contributor to the government’s spending problem. And dollars spent on health
care—whether appropriately or not—compete with dollars for defense, education, and
infrastructure. They’re not secure in a lock box where competing priorities have no
keys. Our system of health has failed to deliver optimal value to its customers—
employers, individuals. The data’s clear:
Note: figures are rounded and may not total; where applicable, ‘don’t know/no opinion’
values are not shown.
Sources:
1. 2012 Deloitte Survey of U.S. Employers: Opinions about the U.S. health
system and plans for employee health benefits, Deloitte Center for Health
Solutions and Deloitte Consulting LLP, June 2012
2. 2012 Survey of Health Care Consumers in the United States, Deloitte Center
for Health Solutions, June 2012
3. Physician perspectives about health care reform and the future of the
medical profession, Deloitte Center for Health Solutions, December 2011
There’s plenty of money in the system, but even more plentiful the strong opinions of
its stakeholders about how it should be spent. And too frequently, each has a view
that’s noticeably assertive about of its own efficiency while pointing fingers at others
portrayed as wasteful or fraudulent.
Let’s have that discussion. Let’s create a national blue ribbon panel to come up with
fresh solutions that the legislative process is unable to tackle due to the realities of
politics and lawmaking. It would include employers, providers (including physicians,
long-term care providers, nurses, and technicians), scientists, device manufacturers,
plans, retailers, food manufacturers, and consumers; its agenda straightforward—to
develop meaningful solutions that can be implemented within the context of the law
(it’s not going away) that accelerate better care at lower cost while building on a
private system favored by the majority of Americans—young and old.
I teach in the health policy program at Georgetown. The students are given the task of
probing a targeted solution focusing on what needs to be done, then how and who. It
impresses me how quickly they identify solutions—their “WHAT.”
But “how” is the students’ greater challenge and what makes the difference in their
grade. Unlike much of the recent debate about reform that pits sector against sector,
the Millennials’ “how” always seem to embrace new technologies and innovative
processes. They progress from WHAT, to HOW, then WHO in that order. Too
frequently in the health reform journey of the past four years, the discussion has
started with WHO and progressed no further.
I believe we’re at the tipping point: it’s worth the effort. It starts with agreement about
“what,” then “how”—“who” comes last. The health care system state of the union is
not strong. It can do better. And we can afford to do no less and we have little time to
waste.
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Implementation update
CBO budget and economic outlook—new health care projections:
spending, coverage assumptions, and cost of ACA Last week, the CBO released its budget and economic outlook for FY 2013 to FY
2023, updating its August 2012 forecast. Highlights:
Health care spending (from CBO unless otherwise noted)
National health expenditures grew at an annual rate of 4.3% in 2012 vs. 3.9%
annually from 2009 to 2011. (Source: Centers for Medicare & Medicaid Services
[CMS])
Medicare spending increased 3%, or $16 billion, in FY 2012—a slower rate of
growth than any seen since 2000. CBO predicts Medicare outlays will increase
4% or $21 billion, in FY 2013 inclusive of a 2% reduction in Medicare spending
per sequestration (unless Congress intervenes).
Health care prices in December 2012 increased 1.7% vs. December 2011—the
lowest year-over-year growth since February 1998. The 12-month moving
average at 2.0% was the lowest since December 1998. (Source: U.S. Bureau of
Labor Statistics [BLS] data, Altarum Institute)
Health care employment increased by 23,000 in January 2013—similar to the
24-month average of 24,000. Totals for 2011-2012 health care jobs added were
598,000. (Source: BLS data, Altarum Institute)
Major health care programs (i.e., Medicare, Medicaid, and CHIP) will represent
6.2% of GDP in 2023, up from 5% in 2013.
A ten-year freeze on the sustainable growth rate (SGR) would raise Medicare
spending by $138 billion, down from the November projection of $243.7 billion.
Impact of CBO update on the ACA (from CBO)
Changes in coverage assumptions:
Medicaid and CHIP: 12 million will be added to the program by 2022—an
increase of 1 million from August 2012 baseline projections but below original
16 million projected in March 2010 before Supreme Court ruling that expansion
is optional for states (results in lower Medicaid outlays by federal government of
$93 billion)
Employment-based: 7 million fewer will be covered by an employer in 2022 vs.
4 million less projected in August 2012
Health insurance exchanges (HIXs): 25 to 26 million will be enrolled in the HIXs
by 2022 vs. 24 million projected in August 2012 (results in increased subsidies
through HIXs of $32 billion)
Uninsured: 27 million will gain health insurance by 2022, down from 30 million
projected in August 2012
Changes in revenues associated with ACA:
Revenues from penalties: net cost of the ACA provisions: $1.165 trillion
between 2013 and 2022—same as the August 2012 baseline estimate
Penalty payment changes: penalty payments by employers projected to be $13
billion higher than 2012 baseline estimates, and penalty payments by
individuals projected to be $10 billion lower
Revenues from excise taxes: the excise tax on high premium health insurance
plans is projected to be $9 billion less than 2012 baseline estimates
10-year effect on the federal deficit, FYs 2013-2022 (billions of dollars)
ACA provision
August
2012
February
2013 Difference
Medicaid and CHIP outlays $ 643 $ 550 $ (93)
Exchange subsidies $ 1,015 $ 1,047 $ 32
Small-employer tax credits $ 22 $ 23 $ 1
Gross cost of provisions $ 1,680 $ 1,620 $ (60)
Penalty payments by uninsured individuals $ (55) $ (45) $ 10
Penalty payments by employers $ (117) $ (130) $ (13)
Excise tax on high premium insurance plans $ (111) $ (102) $ 9
Other effects on tax revenues and outlays $ (231) $ (178) $ 53
Net cost of coverage provisions $ 1,165 $ 1,165 $ -
(Source: CBO, “The Budget and Economic Outlook: Fiscal Years 2013 to 2023,”
Table A-2, February 2013)
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Report: IRS did not receive adequate funding to implement ACA According to a recent report from the U.S. Department of Treasury (DOT) Inspector
General for Tax Administration, the U.S. Internal Revenue Service (IRS) did not
receive adequate funding from the U.S. Department of Health and Human Services
(HHS) to pay for the additional full-time employees needed to implement the ACA.
The FY 2013 IRS budget included no additional workers vs. the 856 full-time
employees (FTEs) funded by HHS dedicated to the ACA implementation in FY 2012.
Other findings:
The IRS FY 2012 budget totaled $11.8 billion, which is a 2.1% decrease from
FY 2011—second consecutive budget reduction.
The total IRS workforce fell 9% (5,000 employees) from FY 2010 to FY 2012.
40% of IRS employees will be retirement eligible by FY 2017; more than a third
of its senior management and nearly 20% of nonexecutive managers are
currently eligible for retirement.
Background: more than 40 provisions of the ACA pertain to IRS relating to tax
reporting responsibilities, intermediaries (i.e., employers and insurers who help
administer), and administrators (i.e., HHS, other federal agencies, and states). The
FY 2012 budget request for IRS included $473 million and more than 1,200 FTE staff
for ACA implementation.
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Commission on long-term care appointed In the American Taxpayer Relief Act (ATRA) of 2012 (H.R. 8), the fiscal cliff deal
passed January 1, 2013, the Community Living Assistance Services and Support
(CLASS) Act (Sections 8001 and 8002 of the ACA) was replaced with a new 15-
member Commission on Long-Term Care tasked to create a national plan to address
long-term care services in the U.S. Three Commissioners were to be appointed by
President Obama and 12 by the House and Senate (50/50 Republican/Democrat
appointees made by leadership). President Obama, U.S. Senate Minority Leader
Mitch McConnell (R-KY), and U.S. House Majority Leader John Boehner (R-OH) have
not yet announced nominations.
U.S. Senate Majority Leader Harry Reid (D-NV) nominated Judy Feder,
Georgetown Professor; Laphonza Butler, Service Employees International
Union (SEIU) United Long-Term Care Workers’ Union President; and Javaid
Anwar, M.D., Nevada.
U.S. House of Representative’s Minority Leader Nancy Pelosi (D-CA)
nominated Bruce Allen Chernof, M.D., SCAN Foundation; Judith Stein, Center
for Medicare Advocacy, Inc.; George Vradenburg, Alzheimer’s activist.
return to top
Costs of ACA calculated Last week, staff from the U.S. House Ways and Means, Education and the Workforce,
and Energy and Commerce committees released a 16-page report outlining costs
associated with ACA implementation in 157 areas. Per the 16-page “ObamaCare
Burden Tracker” the total burden associated is 127.6 million hours. Highlights:
Credit for small employer health insurance premiums: 40.2 million hours. Note:
per the ACA, certain small employers are eligible to receive tax credits to
supplement the cost of health insurance premiums.
340B drug pricing program forms: 14,504 hours. Note: the ACA expanded the
340B drug pricing program to make more safety-net providers eligible for drug
discounts.
Application for coverage in the pre-existing condition insurance plan: 59,833
hours. Note: the ACA created a program for individuals who could not access
health insurance because of a pre-existing condition. The program serves as a
gap until 2014 insurance market regulations go into effect that prohibit health
insurance issuers from discriminating against individuals based on health
status.
Background: the hours cited in the tracker were collected from the OMB website; by
law, agencies must calculate the paper burden associated with certain regulations
impacting providers, administrators, consumers, etc.
(Source: House Ways and Means, Energy and Commerce, Education and Welfare
Committees’ “ObamaCare Burden Tracker,” released February 6, 2013)
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Basic health plan implementation delayed to 2015 Last week, CMS announced the implementation of basic health program (BHP) will be
delayed until January 2015—one year after its original start date. Reasoning: states
have enough on their plates beginning January 1, 2014 and CMS expects there to be
a learning curve in 2014 that will inform the BHP federal regulatory process and
state’s decisions about whether to participate in the BHP.
Background: the BHP was enacted by Section 1311 of the ACA and will allow states
to administer a public health insurance program for individuals between 133% and
200% of the federal poverty level (FPL) who would otherwise be eligible to purchase
health insurance coverage through a HIX. States will receive 95% of the federal
subsidy that the individual would have received if they had purchased coverage
through a HIX. Proponents of the program believe that the BHP will reduce the cost of
insurance for low-income uninsured individuals; opponents argue that the BHP will
undermine the HIX market.
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Rate review rule in final review at OMB The U.S. Office of Management and Budget (OMB) is reviewing a final rule from HHS
that will provide guidance on provisions in the ACA related to the health insurance
market, including amendments to the requirements for states to operate rate review
programs.
Background: the rate review program was enacted by Section 1001 of the ACA and
implemented in 2011 to monitor health insurance premium rate increases above 10%.
If the rate of increase is greater than 10%, the health insurance issuer must seek
approval from the state in which the plan is being administered or from HHS if the
state does not have a rate review program in place. According to HHS, nine states
have passed legislation to enhance rate review, 17 states have proposed rate review
legislation, and 40 states have enhanced consumer protections.
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Legislative/regulatory update
Permanent SGR fix proposed Wednesday, Representatives Allyson Schwartz (D-PA) and Joe Heck (R-NV)
introduced the Medicare Physician Payment Innovation Act (H.R. 574) to change the
way Medicare providers are paid by eliminating the SGR system and replacing it with a new payment delivery model. (Note: similar legislation was introduced last year but
was not passed.) Thursday, House Republicans also released their proposal to repeal
the SGR.
Background: the ACA cuts Medicare spending $716 billion for FY 2010 to FY 2019.
As part of ATRA, Congress canceled a 26.5% Medicare pay cut for doctors scheduled
to be implemented January 1 and replaced it with a one-year payment freeze. CBO
said the legislation sets up a 25% cut in January 2014, unless lawmakers again
intervene. In last Tuesday’s CBO update, the cost of Medicare pay cuts to physicians
was lowered from $243.7 billion to $138 billion for FY 2013 though FY 2023. It said its
lower cost estimate is primarily due to lower spending for physicians’ services in
recent years with Medicare spending increasing at 3% in FY 2012—the lowest annual
rate since 2000.
The net result of the decrease: opportunistic legislative proposals to permanently fix
the SGR:
Concept
SGR Repeal and Reform proposal, by
House Ways & Means and Energy &
Commerce Committees1
Medicare Physician Payment
Innovation Act (H.R. 574), introduced
by Representatives Allyson Schwartz
(D-PA) and Joe Heck (R-NV)2
Repeal the SGR Fully repeal, eliminating the 25% rate cut
to physicians in 2014 and any future cuts
called for under the formula
Proposal includes three phases of
reform:
Phase I: repeal SGR and provide a
period of predictable, statutorily-
defined payment rates
Phase II: reform Medicare’s fee-for-service (FFS) payment system to
better reflect the quality of care
provided
Phase III: further reform Medicare’s FFS payment system to also account
for the efficiency of care provided
Fully repeal, eliminating $300 billion debt
to the Medicare program
Includes 5-year transition period to
replace scheduled cuts before the new
payment system is in place in 2018
Replacement
formula
Establishes a period of payment rates
that are predictable and statutorily-
defined
Provides positive annual payment
updates of 0.5%
Years 2014 to 2017, provides 2.5%
annual increase for primary care,
prevention, and care coordination
services provided by clinicians for whom 60% of their Medicare allowable charges
are for those same services
Reimbursement Provides options from which physicians
can choose to fit their practice
Requires CMS to issue a menu of no
fewer than four health care delivery and
payment model options by October 1,
2016
CMS will also be allowed to select from
models in development outside of the
agency
Measures Allows physicians to determine clinically
meaningful quality and efficiency
measures
Provides two options for physicians who
demonstrate a commitment to quality
and efficiency to participate in a new
alternative FFS system; physicians must
either:
1. Adhere to list of cost, quality, and
outcome measures defined in
conjunction with medical societies
2. Be exceptional clinicians who
demonstrate achievements as
measured by the Value-Based
Modifier relative to their peers
Incentives Rewards physicians in the program who
deliver high-quality and efficient care
Beginning January 1, 2018, physicians
who practice within an approved model
will be able to earn higher
reimbursements for achieving gains in
quality, effectiveness, and gains
Those who remain in the traditional FFS
model will be subject to reduced updates in both primary and non-primary care
services
Oversight Requires CMS to provide timely
feedback and data to physicians
Directs the Secretary of the HHS to
update payments between 1% and the
Medicare Economic Index (MEI) annually
beginning 2023
Sources: 1Overview of SGR Repeal and Reform Proposal
2Medicare Physician Payment Act of 2012
My take: as noted in prior Monday Memos, the SGR is a fundamentally flawed
method of payment for physicians, and as such deserves re-thinking and a fresh start.
But the discussion should not be limited to physicians only: the health care workforce
supply-demand imbalance is particularly acute in primary care. To address the
shortage, expansion of scope of practice for nurse practitioners and advanced
practice nurses; inclusion of dental, nutritional, and psychological care; expanded use
of technologies that facilitate coordination and patient monitoring; and a precise focus
on consumer self-care should be added to the discussion. It’s not just about physician
pay; it’s about the care and caring processes of health care professionals working in
tandem with consumers.
For more information about the SGR, download Understanding the SGR: Analyzing
the “Doc Fix” from the Deloitte Center for Health Solutions.
In addition to the SGR, other health care legislative activities last week:
Medical device: Representative Erik Paulsen (R-MN) introduced the Protect
Medical Innovation Act (H.R. 523) to repeal the 2.3% excise tax on medical
devices that went into effect January 1, 2013 per the ACA.
Medicaid: Representative Gerry Connolly (D-VA) introduced H.R. 467 to
redistribute federal funds declined by states opting out of Medicaid expansion
(Section 2001 of the ACA) to states choosing to provide those Medicaid
benefits.
Pharmaceuticals: Representative Bill Keating (D-MA) introduced H.R. 486 to
incentivize the development of abuse-deterrent drugs. Senator Amy Klobuchar
(D-MN) introduced S. 214 to prohibit brand name drug companies from
compensating generic drug companies to delay entry of a generic drug into the
market, known as “pay-for-delay.” Representative David McKinley (R-WV)
introduced the Patients’ Access to Treatments Act of 2013 (H.R. 460) to limit
cost-sharing requirements applied to prescription drugs in a specialty drug tier
to the dollar amount associated with prescription drugs in a non-preferred brand
drug tier.
Medicare: Representative Alan Grayson (D-FL) introduced H.R. 500 to allow
any citizen or permanent resident of the U.S. to buy into Medicare.
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CMS proposes rule to reduce regulatory burdens for providers Last week, CMS issued a proposed rule to eliminate “excessively burdensome,
obsolete, or unnecessary” regulations placed on providers participating in Medicare.
This rule would impact Ambulatory Surgical Centers (ASCs), Critical Access Hospitals
(CAHs), transplant centers, etc. Highlights:
To be eligible to provide radiology services, ASCs would no longer be subject to
the requirements of full hospitals
Qualified dietitians would be eligible to order patient diets in a hospital setting
Transplant centers would no longer have to report certain types of data to CMS,
as CMS receives the information from other sources
CAHs would no longer be required to develop patient care policies with
members of the community ( i.e., non-staff members)
Background: President Obama issued an Executive Order requiring all federal
agencies to conduct retrospective reviews of existing regulations to determine which
regulations are no longer necessary.
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Tavenner nominated to top CMS post Friday, the White House re-nominated Marilyn Tavenner to be administrator of CMS.
The move was expected, as Tavenner’s nomination expired at the end of the last
Congress.
My take: a number of trade associations—the American Medical Association (AMA),
Federation of American Hospitals (FAH), American Hospital Association (AHA), and
others—quickly affirmed her nomination. I suspect she will be confirmed by the
Senate.
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CMMI announces bundled payment program for kidney dialysis Last week, the Center for Medicare and Medicaid Innovation (CMMI) began accepting
applications from Medicare providers to participate in a new shared savings program
to treat end-stage renal disease (ESRD). The program would run from 2013 to 2016.
Letters of intent will be accepted until March 15 and applications until May 1.
Background: through the Comprehensive ESRD Care Model, CMMI seeks to identify
ways to improve the coordination and quality of care for beneficiaries in this
population, while lowering total per-capita expenditures to the Medicare program.
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State update
CMS guidance to states: Medicaid cost sharing for newly eligible
Last Wednesday, CMS clarified how increased federal matching rates would apply to
Medicaid expansion populations starting in 2014 and how Medicaid expansion applies
to pregnant women.
Background: ACA allows states, beginning in 2014, to extend Medicaid coverage to
single adults younger than 64 with income of up to 133% of the FPL (effectively 138%
because of a 5% income disregard allowed in ACA). In Medicaid expansion, two types
of increased federal medical assistance percentages (FMAPs) will be available to
states:
1. A “newly eligible FMAP” will be available to states that decide to participate in
Medicaid expansion. This FMAP will cover all state expansion costs (100%
match) from 2014 through 2016; provide a 95% match in 2017; 94% match in
2018; 93% match in 2019; and 90% match in 2020 and beyond.
2. “Expansion state FMAP”: before Congress enacted ACA in March 2010, some
states had already expanded their Medicaid coverage to adults with higher
incomes. For Medicaid enrollees that fell in this group, CMS said another FMAP
(“expansion state FMAP”) will be available: the regular (non-newly eligible)
FMAP rate increased by a “transition percentage,” which will result in a lower
FMAP than the newly eligible FMAP. The transition percentage will increase
gradually, however, so that by 2019 it will equal the newly eligible FMAP.
A key feature of the Medicaid expansion in the ACA was the eligibility of childless,
non-pregnant adults. The CMS guidance also addressed whether states need to track
women enrolled in the Medicaid expansion group who become pregnant. Per CMS
guidance, if a woman indicates on an initial application that she is pregnant, she
would be enrolled in a state's pre-existing Medicaid coverage as a pregnant woman
rather than in the newly eligible group. States are not required to track the pregnancy
status of women already enrolled in the newly eligible group.
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State round-up: HIX States that do not plan to operate their own exchange must submit their plans to
operate a state-partnership exchange by February 15, 2013 or default to a federally-
facilitated exchange. To date, 17 states—13 led by Democratic Governors, three led
by Republicans, and one Independent—and the Democratic mayor of D.C. have
announced plans to operate state-based exchanges:
State-based exchange State-partnership
exchange
Undecided/Federally-
facilitated exchange
CA, CO, CT, DC, HI, ID, KY,
MA, MD, MN, NM, NV, NY,
OR, RI, UT, VT, WA
AR, DE, IA, IL, MI, NC, WV AK, AL, AZ, FL, GA, IN, LA, KS,
ME, MO, MS, MT, ND, NE, NH,
NJ, OH, OK, PA, SC, SD, TN, TX,
VA, WI, WY
Note: updated February 10, 2013.
Mississippi will not implement a state-based exchange. CMS officially denied the state's proposal Friday because the state's application was not signed by Governor Phil Bryant (R). In a letter to the state, Gary Cohen, Director of the Center for Consumer Information & Insurance Oversight (CCIIO), encourages Mississippi to submit an application on February 15, 2013 to participate in a state-partnership exchange.
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Medicaid expansion update Twenty-three states and D.C. have said they will expand or are in support of
expanding their Medicaid programs; 15 states have indicated they are highly unlikely
to expand their program:
Announced or Governor
in support of expansion
Not participating or
highly unlikely to
participate
Undecided or undeclared
AR, AZ, CA, CO, CT, DC,
DE, HI, IL, MA, MD, MI,
MN, MO, MT, ND, NH, NM,
NV, OH, OR, RI, VT, WA
AL, GA, IA, ID, IN, LA, ME,
MS, NE, OK, SC, SD, TX,
UT, VA
AK, FL, KS, KY, PA, NC,
NJ, NY, TN, WI, WV, WY
Sources: PoliticoPro, February 10, 2013 and State Reform, February 7, 2013
Note: states do not have a deadline to make a decision on Medicaid expansion and
may opt in or out of participation at any time. This chart was compiled using publicly
available information (as of February 10, 2013) and is subject to change.
Ohio Governor John Kasich (R) included Medicaid expansion funding in his budget proposal released last week. The Governor has requested the Obama administration allow his state to provide coverage via the subsidized exchange market for the highest income portion of the eligible population, 100% to 133% of the FPL. Expansion of the program is expected to provide insurance for an additional 456,000 Ohioans and generate a $1.4 billion net gain for the state budget by 2022.
Wednesday, Governor of Michigan, Rick Snyder (R) announced his support for Medicaid expansion.
Friday, the Florida Hospital Association released a poll of 600 registered voters finding that that more than six of ten Florida voters support the expansion of Medicaid eligibility in the state.
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State round-up Mississippi House members passed legislation allowing insurers to
compensate specialists who use telemedicine to provide long-distance consultation to rural doctors.
Texas recovered $1.01 billion in Medicaid fraud over the past ten years; 60% was returned to the federal government.
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Industry update
Survey: ACA’s major impact on how larger employers handle part-time
employees The ADP Research Institute survey of larger employers (companies with 1,000 or
more employees) concluded that the ACA will have the biggest impact on how
employers structure health care benefits for part-time employees. Findings:
Part-time employees make up 23% of the total workforce; 15% of these part-time employees are eligible for benefits with slightly more than half (53%) choosing to participate.
68% of the total full-time workforce is covered by their employers’ health plan vs. 8% of part-time employees.
Purchasing behavior is significantly different among part-time workers who are single vs. married. Single employees make up 52% of the part-time associates who are eligible for benefits. Only 46% of those, however, elect health coverage.
Very large employers (>5,000 lives) paid 14% less for coverage on average than employers with 1,000 to 2,499 lives.
Employers in manufacturing incurred health premiums that were 13% higher than average. Professional services and health care and social assistance industries also incurred health premiums well above average. By contrast, the accommodation and food services industry reported premiums 25% lower than the average.
(Source: ADP Research Institute, “ADP’s 2012 Study of Large Employer Health
Benefits: Benchmarks for Companies with 1,000+ Employees,” 2013)
My take: in our 2012 Survey of U.S. Employers, cost was the major issue. Most
employers were not clear on how the ACA reduces health costs, and unfamiliar with
its elements that move the delivery system’s incentives away from FFS to value. Most
want to keep coverage for their employees: 9% (representing 3% of the civilian work
force) said they would consider dropping coverage in the next one to three years. But
they also express strong interest in the potential role HIXs might play as a channel for
coverage. For more information, download the 2012 Deloitte Survey of U.S.
Employers: Opinions about the U.S. health care system and plans for employee health benefits from the Deloitte Center for Health Solutions.
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Three updates on information-driven health care
VA and DOD will not use a single EHR system The U.S. Department of Veteran Affairs (VA) and U.S. Department of Defense (DOD)
announced last week they would not pursue a plan to create a single integrated
electronic health record (EHR) system, estimated to cost between $1.4 and $5.2
billion, and will focus on a more affordable immediate solution to share health data.
Background: in October 2012, the U.S. Government Accountability Office (GAO)
released a report concluding that collaboration in the provision of health care services
between the DOD and VA was ineffective, and recommended that the departments
develop performance measures related to access, quality, and costs; implement
information technologies to enhance administrative and clinical coordination; and
address policy and workforce barriers hindering collaboration. The VA and the DOD
serve over 15 million individuals (including 1.1 million who receive care from both
departments), approximately 100 hospitals, and 1,000 clinics.
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AHRQ, CMS launch EHR for pediatrics Last week, the Agency for Healthcare Research and Quality (AHRQ) and CMS
announced a new EHR format for processing health information about children—an
EHR format that tracks child-specific data elements and recommendations including:
prenatal and newborn screening tests, vaccines, growth data, special needs, and
child abuse reporting. The proposed EHR format provides guidance on structures that
permit interoperable exchange of data, including data collected in school-based,
primary, and inpatient care settings. Pennsylvania and North Carolina will participate
in a pilot demonstration to test the format, and CMS plans to integrate the format into
future EHR Standards and Meaningful Use certification requirements.
Background: the 2009 Children’s Health Insurance Program Reauthorization Act
(CHIPRA) authorized the children’s EHR format to improve care for children,
especially those enrolled in Medicaid and CHIP. The format is designed for EHR
developers and providers who wish to augment existing systems with additional
features or to build new EHR systems.
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Survey: implementation deadlines, infrastructure major challenges for
CIOs A survey of 100 CIOs in provider settings concluded that network security issues,
infrastructure upgrades, and Meaningful Use implementation top their list of concerns:
56% were “somewhat confident” in their ability to prevent a privacy or security breach on their network
76% of respondents are planning to upgrade their network infrastructure in the next two years
24% reported using cloud-based computing, much lower than other industries
17% believe mobile health (mHealth) will have a significant impact on the health care industry
80% of respondents agree that EHR-based systems will improve patient care
More than 60% suggested that EHR and Meaningful Use mandates are a “good idea” to support better quality patient care
(Source: Level 3 Communications, “CIO Outlook on Healthcare IT for 2013,” February
2013)
Note: next week the Center for Health Solutions will release “Health System Chief
Information Officers: juggling responsibilities, managing expectations, building the
future.” In this study, Senior Advisor for Health Care Transformation and Technology
Harry Greenspun, M.D., explores the issues that keep CIOs awake at night, looking at
both near- and long-term issues and challenges ahead.
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FDA releases guidance on Alzheimer’s trial designs The U.S. Food and Drug Administration (FDA) issued draft guidance for
pharmaceutical manufacturers who plan to develop drugs for treatment of early stage
Alzheimer’s, outlining clinical outcome measures for various stages, potential
strategies for demonstrating clinical efficacy, and how disease modification might be
demonstrated for these populations. Comments will be accepted until April 9, 2013.
Background: the 2011 National Alzheimer's Project Act established a National Plan
for Alzheimer's disease and related dementias (ADRD). With input from a public-
private Advisory Council on Alzheimer's Research, Care and Services, it provides
recommendations to HHS for priority actions to expand, coordinate, and condense
programs to improve the health outcomes of people with ADRD and reduce the
financial burden of these conditions on those with the diseases, their families, and
society. It is projected the Alzheimer’s population will triple to 13.8 million in the next
40 years (see research summary below).
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Research snapshots New industry and peer-reviewed studies of note to health system transformers…
Alzheimer’s projected to triple in U.S. by 2050 Objective: “To provide updated estimates of Alzheimer disease (AD) dementia
prevalence in the U.S. from 2010 through 2050.”
Methodology: “Probabilities of AD dementia incidence were calculated from a
longitudinal, population-based study including substantial numbers of both black and
white participants. Incidence probabilities for single year of age, race, and level of
education were calculated using weighted logistic regression and AD dementia
diagnosis from 2,577 detailed clinical evaluations of 1,913 people obtained from
stratified random samples of previously disease-free individuals in a population of
10,800. These were combined with U.S. mortality, education, and new U.S. Census
Bureau estimates of current and future population to estimate current and future
numbers of people with AD dementia in the U.S.”
Key findings: “In 2010, there were 4.7 million individuals aged 65 years or older with
AD dementia, 0.7 million were between 65 and 74 years, 2.3 million were between 75
and 84 years, and 1.8 million were 85 years or older. The total number of people with
AD dementia in 2050 is projected to be 13.8 million, with 7 million aged 85 years or
older. The number of people in the U.S. with AD dementia will increase dramatically in
the next 40 years unless preventive measures are developed.”
(Source: Hebert, et al, American Academy of Neurology, “Alzheimer disease in the
United States [2010-2050] estimated using the 2010 census,” February 6, 2013)
My take: among the most challenging issues in our society is the balance of caring for
our seniors while addressing coming younger generations. Advances in the diagnosis
and treatment of dementia will no doubt be a key focus, as will hospice care that’s still
used less than half the time at the time of death. (A recent study found that 42% of
Medicare patients were using hospice care at the time of death in 2009—up from 22%
in 2000.) Medicare already spends 27% of its budget in the last year of a senior’s life,
so it’s time for a national discussion about care and caring for seniors and their
children and grandchildren. It’s not just about the seniors themselves.
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Death rates in acute care decreasing Objective: “To describe changes in site of death, place of care, and health care
transitions between 2000, 2005, and 2009.”
Methodology: “A retrospective cohort study of a random 20% sample of FFS
Medicare beneficiaries, aged 66 years and older, who died in 2000 (n = 270,202),
2005 (n = 291,819), or 2009 (n = 286,282). A multivariable regression model
examined outcomes in 2000 and 2009 after adjustment for sociodemographic
characteristics. Based on billing data, patients were classified as having a medical
diagnosis of cancer, chronic obstructive pulmonary disease, or dementia in the last
180 days of life.”
Key findings: “Among Medicare beneficiaries who died in 2000 and 2005 compared
with 2009, a lower proportion died in an acute care hospital, although both ICU use
and the rate of health care transitions increased in the last month of life. The
proportion of deaths in acute care hospitals decreased from 32.6% to 26.9% to 24.6%
respectively. However, intensive care unit (ICU) use in the last month of life increased
from 24.3% to 26.3% to 29.2%. Hospice use at the time of death increased from
21.6% to 32.3% to 42.2%, with 28.4% using a hospice for 3 days or less in 2009. Of
these late hospice referrals, 40.3% were preceded by hospitalization with an ICU stay.
The mean number of health care transitions in the last 90 days of life increased from
2.1 to 2.8 to 3.1 per decedent .The percentage of patients experiencing transitions in
the last 3 days of life increased from 10.3% to 12.4% to 14.2%.”
(Source: Teno et al, “Change in end-of-life care for Medicare beneficiaries site of
death, place of care, and health care transitions in 2000, 2005, and 2009,” JAMA,
February, 2013)
My take: end of life care is a sensitive subject in today’s social and political
environment. The ACA did not address end of life care directly, other than through the
CLASS Act provision that’s been taken out. A discussion about long-term care
inclusive of end of life is a necessary part of health reform and timely.
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Quotable “While some people will find registering for health insurance as easy as booking a
flight online, vast numbers who are confused by the myriad choices will need to sit
down with someone who can walk them through the process. Enter the navigators, an
enormous new workforce of helpers required under the law (ACA). In large measure,
the success of the law and its overriding aim of making sure that virtually all
Americans have health insurance depends on these people. But the challenge of
hiring and paying for a new class of workers is immense and is one of the most
pressing issues as the Obama administration and state governments implement the
law.”—N.C. Aizenman, The Washington Post, “For insurance exchanges, states need
navigators,” February 6, 2013
“If you ask me to describe the rising philosophy of the day, I’d say it is data-ism. We
now have the ability to gather huge amounts of data. This ability seems to carry with it
certain cultural assumptions—that everything that can be measured should be
measured; that data is a transparent and reliable lens that allows us to filter out
emotionalism and ideology; that data will help us do remarkable things—like foretell
the future….In sum, the data revolution is giving us wonderful ways to understand the
present and the past. Will it transform our ability to predict and make decisions about the future? We’ll see.”—David Brooks, The New York Times, “The Philosophy of
Data,” February 5, 2013
“At this level of debt relative to our GDP, our country would be incurring costs and
bearing risks of a sort that we have not had in our history except for a few years
around the end of the second World War. At the same time, bringing debt down
relative to GDP requires reductions in services that we are getting from the government, or higher taxes paid to the government.”—Douglas Elmendorf, Director,
CBO, February 5, 2013
“[Conservatives warn that] the IPAB (Independent Payment Advisory Board) is really
a `death panel’ that will sit in judgment over Americans’ health claims, denying costly
care to the old and weak...Sounds scary. Except the IPAB doesn’t have anything
close to that power. The law (ACA) says it (IPAB) has no authority to ration care or cut
benefits for Medicare recipients. It can’t touch reimbursements to hospitals until 2020.
Instead, it’s expected to find savings by eliminating fraud and reducing payments to
private insurance companies that work with Medicare and prescription drug
providers…”—Devin Leonard, Bloomberg Business Week, “The Boring Awful Life of a
Death Panelist,” January 27, 2013
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Fact file OTC flu season sales: for week ended January 26, 2013, sales of over-the-
counter products to treat upper respiratory illness increased 24% to $189.1
million vs. $152.4 million a year earlier; sales of cold and flu medicines
increased 42%, sales of drops and sprays 31% and cold medication 23%. (Source: The Wall Street Journal, “Flu is Tonic for Drugstore Sales,” February
6, 2013)
Restaurants and obesity: restaurants that increased lower calorie servings
experienced a 5.5% increase in same store sales based on data from 21 fast
food and sit down restaurant chains monitored 2006-2011. (Source: The Wall
Street Journal, “Low-Cal Items Fuel Restaurant Sales,” February 7, 2013)
2012 Congressional vote: Democrats won the popular vote by 1.4 million in
House races, and Republicans won control of the House by 234-201. (Source:
The New York Times, “The Great Gerrymander of 2012,” February 10, 2013)
College graduation: 52% of students with a Bachelor of Arts/Bachelor of
Science are in jobs requiring a degree or higher; 37% a high school degree,
and 11% some college. (Source: John J. Heldrich Center for Workforce
Development, May 2011)
Smoking and mental illness: people with mental illnesses are 70% more
likely to smoke than those without; 36.1% of adults with mental health
disorders smoke vs. 21.4% without a mental health disorder; adults with mental
health issues smoke one-third of all cigarettes in the U.S.; 46 million adults
have a mental illness—20% of population. (Sources: CDC; Substance Abuse
and Mental Health Administration; “Vital Signs: Current Cigarette Smoking
Among Adults Aged ≥ 18 Years with Mental Illness–United States, 2009-2011,”
February 5, 2013)
Retail health insurance: Florida Blue operates 11 retail sites in
malls/shopping areas. (Source: The New York Times, “Health Insurance
Companies Get in Shape for 2014,” February 1, 2013)
Retirement happiness: major factors in happiness—physical health 55%,
financial independence 23%, other factors 22%. (Source: ING survey of 1011
adults 18 and older)
Anxiety by age group: 39% of Millennials (age 18-33) say their stress level is
up this year over last—the highest age cohort. The average stress level for all
adults is 4.9 on a 10-point scale: 20% of Americans report extreme stress, and
44% moderate; 63% tried to reduce their level of stress in the last year, top stressors are money (69%), work (65%) and economy (61%). (Source:
American Psychological Association survey of 2020 adults 18+ in 2012)
Alzheimer’s: the numbers of Alzheimer’s patients will triple by 2050 from 4.7
million to 13.8 million: 1 in 3 adults older than 85 (7 million), 1 in 6 75-84 (5.4
million) and 1 in 77 65-74 (1.3 million). (Source: Neurology, February 6, 2013,
based on analysis of 10,802 Chicago residents from 1993-2011) Note: the
population 65+ will double between 2010 and 2050 from 40.3 million to 88.5
million)
U.S. birth rate: 2.07 vs. replacement rate of 2.1—falling since 1980; China
1.64, Japan 1.32, Germany 1.36, France 1.97, India 2.73, Russia 1.44.
(Source: United Nations)
Snack foods in schools: $2.3 billion spent annually. (Source: National
Academy of Sciences)
Physician social networking: 82% of physicians interact with other
physicians via social networking; only 8% use it to engage with patients.
(Source: The Wall Street Journal, “Should Doctors and Patients be Facebook
Friends,” February 4, 2013)
Long-term care insurance: average age of individual buyers was 59 years in
2010, down from 68 years in 1990. (Source: AHIP)
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University Press at www.DUPress.com.
Coming soon: Health System Chief Information Officers: Juggling responsibilities, managing
expectations, building the future
Currently available: Unlocking value in health plan M&A: Sometimes the deals don’t deliver—
January 2013. Available online at www.deloitte.com/us/2013planconsolidation
2012 Survey of U.S. Health Care Consumers: Segmentation INFOBrief—
January 2013. Available online at www.deloitte.com/us/2012segmentation
Deloitte 2012 Survey of U.S. Health Care Consumers: supplemental reports—
December 2012. Access a library of resources including an INFOBrief series, an
infographic, and a Five-Year Look Back report. Available online at
www.deloitte.com/us/consumerstudies
The hidden costs of U.S. health care: Consumer discretionary health care
spending—December 2012. Available online at
www.deloitte.com/us/2012hiddencosts
mHealth in an mWorld: How mobile technology is transforming health care—
December 2012. Available online at www.deloitte.com/us/mobileandtechnology
Understanding the SGR: Analyzing the “Doc Fix”—October 2012. Available
online at www.deloitte.com/us/2012sustainablegrowth
Impact of Health Care Reform on Insurance Coverage: Projection Scenarios
Over 10 Years – Update 2012—October 2012. Available online at
www.deloitte.com/us/2012coveragemodel
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Read the blog
To stay up-to-date, check out the Center for Health Solutions’ blog: A view from the Center—where policy, innovation, and industry meet
http://blogs.deloitte.com/centerforhealthsolutions/
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Deloitte contacts
Paul H. Keckley, Ph.D., Executive Director, Deloitte Center for Health Solutions
Jessica Blume, U.S. Public Sector National Industry Leader, Deloitte LLP
Bill Copeland, U.S. Life Sciences and Health Care National Industry Leader, Deloitte
LLP ([email protected])
Jason Girzadas, National Managing Director, Life Sciences & Health Care, Deloitte
Consulting LLP ([email protected])
Harry Greenspun, M.D., Senior Advisor, Health Care Transformation and
Technology, Deloitte Center for Health Solutions ([email protected])
Mitch Morris, M.D., National Leader, Health Information Technology, Deloitte
Consulting LLP ([email protected])
George Serafin, Managing Director, Health Sciences Governance Regulatory & Risk
Strategies, Deloitte & Touche LLP ([email protected])
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