keeping health care ahead of the curve with the latest innovations is our specialty and has been for...
TRANSCRIPT
Keeping health care ahead of the curve with the latest innovations is our specialty and has been for nearly 50 years.
Core Business• EMS Sales• Hospital Sales• Product Development
and Engineering• Biomedical Clinical
Services• Mercury Manufactured
Products• Medical Gas Certification• Home Care
Medical Device Industry
Current Challenges
• Federal Mandate• Electronic Medical Records by 2014.• Hospitals face penalties of 1% in 2015, incrementing each year up to 5% as Medicare/Medicaid reimbursement reductions.• Federal grants and funding, Medicare incentive payments, to assist with implementation, from American Recovery Reinvestment Act.
• Connectivity• With EMR implementation process, customers are now demanding new electronic devices have ‘connectivity’.
U.S. HOSPITALS ALSO FACING• NRP (Neonatal Resuscitation Program).
– 2012 Guidelines* Laryngeal Masks * Blender* Medical Air / Compressor * SP02
• JCAHO– 10/24/11 – Laryngoscope blades can no longer lay
in drawers or on towels. Must be wrapped
• SCIP (Surgical Care Improvement Project)• ASA Sedation Standard 3.2.4; AHA, ERC, Joint
Commission guidelines.– CO2 Monitoring
“Vendor Credentialing” for hospital access - no
common standard.
Capital Funding
Access challenges for hospitals.
New ‘Sunshine Law’ disclosure regulation for financial
relationship reporting with physicians. NPI information at registration so if the exhibitor
gives away anything (food, beverage, etc.) the vendor will
have the details for reporting to HHS.
Many device companies developing consumables with chip recognition to
limit competition, allowing them to maintain a
foreseeable revenue stream.
The product sale cycle in a typical hospital has greatly lengthened and involves a variety of other
players beyond clinicians, legal, VAC/VAT, procurement, finance.
One recent comment which appeared in the Grey Sheet,
stated “all products are considered commodities, unless
proven otherwise”.
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Reimbursement Coding Change
• ICD-9 to ICD-10 (International Classification of Diseases). U.S. is behind the rest of the world.• This change would replace the current set of 14,000 diagnosis codes to approximately 69,000 codes.• Implementation date October 1, 2013, was delayed on 2/16/12 by HHS for unspecified time.
Centers for Medicare & Medical
Services (CMS) reimbursement cutbacks, including additional percentage reduction for missing EMR/EHR implementation.
(UDI) Unique Device Identifier• Passed by congress in 2007. Implementation
date 2013. • FDA still has not issued final rules to industry.
Initial proposed regulation 60-70 pages after a 200 page preamble.
• The senior FDA advisor once stated “It’s not written in a way that’s easy to understand. It’s a legal document, written by our lawyers, reviewed by our lawyers, I don’t understand most of it”
Continued next page…..
•EU drafting guidelines
•UDID (Global Database)•Include GMDN (Global Medical Device Nomenclature)
• While these UDI labeling changes are in process, FDA is proposing to poll healthcare providers on “how to best standardize medical device labeling”, which is to take place in 2012.
FDA plans for “on-line” labeling repository for all devices, as part of FDA reform plan.
FDA just announced plans to survey industry for comments related to it’s “Emergency Shortages Data Collection System”. System is available only to CDRH Emergency Shortage Team and Senior management. Separate from this system, U.S. Department of Commerce Bureau of Industry and Security conducted a similar mandatory survey in 2011.
Global Location Number (GLN)
as a common numbering system to identify any legal entity/trading
partner.
•
Two bar code standards: GS–1 (formerly UCC) Uniform Code
Counsel HIBC – Health Industry Business
Council
Outside U.S., some countries ignore; mandating use of another format
Global Medical Device Nomenclature
Pending addition to labeling rule changes
Healthcare Bill
In 2013 most medical devices will be subject to 2.3% Medical Device Tax unless congress intervenes. IRS has published a draft “Proposed Rule Making Regulation” on February 3, 2012. Supreme Court hears arguments week of March 26, 2012, with ruling by June, 2012.•First Excise tax payment due January 29, 2013.
FDA Reforms (MDUFA III)
Review and possible rewrite of the entire device approval process including IOM (Institute of Medicine) recommendation to scrap current 510k process and start over.
• 510k statute review time (90 days) missed• 510k costs to double by 2017• Establishment registration fees to increase 50% by 2017.
• European Union (CE) requirement changes.
Increasing individual country requirements (not harmonized).
Underwriters Laboratories (UL)
New and Updated Electrical Standard for Medical
Devices: IEC 60601-1 (800 pages)
New Outside Entity• Hospitals contracting with outside entities
(i.e. MedApproved) for prescreening new technologies before introduction into system.
http://www.medapproved.com• Hospitals contracting with outside parties
for recall management i.e. (RASMAS (Risk and Safety Management Alert System)).
http://www.rasmas.noblis.org
Patent Reform Law
• First to file vs. previous first to invent. • May impact how industry interfaces “discloses” with developers.
FDA “PREDICT” IMPACT
Introduction of new importation clearing system “PREDICT” dramatically affecting all companies importing materials
___________Mandatory
CO2 Monitoring
SCIPNRP 2012
JCAHO
DEC 212012
MyanCalendarRuns Out
(Doomsday?)
JAN 1 2013
Medical DeviceTax
(PRICES WILL GO UP!)
JAN 292013
1ST medical device excise tax payment
due
MAR 162013
Patent Law Reform
takes effect
SEP 302013
UDI Implementation
Date from CDRH
OCT 12013
ICD10 Implementation (NOW DELAYED)
2014
EMR/EHR Takes effect
National Strategy for Global Supply Chain Security
FDA Poll to standardize
medical device labeling.
Questions?
Thank You