Showing posts with label NHTSA. Show all posts
Showing posts with label NHTSA. Show all posts

Wednesday, August 14, 2013

Another White Paper

Another White Paper

By Alan Perry
August 18, 2013

In case you missed it, the two government bodies that are most affected by proposed changes to the delivery of emergency medical services (EMS) have recently weighed in with their joint assessment of the situation. On July 15, 2013 the National Highway Traffic Safety Administration (NHTSA) and offices of Health and Human Services (HHS) released a joint statement in the form of a draft white paper entitled Innovation Opportunities for Emergency Medical Services. The document does not contain any new data, but expresses the desire of these two organizations to promote their vision of health care reform as it pertains to EMS, and proffers a generic model of cost savings that can be realized by making a few changes that have already been identified in other publications by the Institutes of Medicine (IOM) and NHTSA. While the paper certainly focuses on the cost savings and the strategies required obtaining them, it leaves the process in the vague hands of a number of “possibilities”. As we have seen from the activity following the previous attempts at reforming healthcare, and EMS in particular, this falls short and. The final conclusion being that Americans deserve a better system that saves money improves care and creates less of a burden on critical resources…. Duh.

As an industry, EMS recognized over a decade ago that our delivery model is inefficient; this is confirmed in this white paper and identifies by name the root source of the problem which we have known for years, it’s the federal government. Medicare and Medicaid reimbursement schedules are driving the inefficient allocation of EMS resources by only paying for patients who get transported to a hospital, which is not always a reasonable or cost effective choice. The paper goes on to address the specifics of the potential cost savings in what it characterizes as a conservative methodology, identifying the potential savings to be somewhere in the range of half a billion dollars. Since we live in a democratic capitalistic society it should come as no surprise that the biggest incentive for change will always be a monetary one. From my perspective of relative ignorance, I must conclude that the quickest and most effective way to change the system would be to change the way it is paid for.

Unfortunately individual EMS systems lack the clout to confront the Centers for Medicaid and Medicare Services (CMS) and challenge the current fee for service schedule. This process is typically worked out between CMS, physician and large healthcare organizations. Equally unfortunate is the Patient Protection and Affordable Care Act (Obamacare) which does not acknowledge the fee for service  problem directly, but instead offers incentives based on cost savings to encourage larger healthcare systems to prove a different model works better. The combination of these two circumstances favors large for-profit healthcare organizations with the clout and money to have their preferences considered. I fear it will leave many public safety organizations at a disadvantage in having their concerns heard since few have the resources to effectively form and fund an Accountable Care Organization (ACO) that can deliver the required savings to get paid. We will be left to work out whatever deal we can with a much larger organization if we are to survive at all. The Federal Government, through Obamacare and CMS, has effectively shut out all small and moderate size public, private and non-profit EMS providers out of the process and the discussion.

Our best hope at this point is the Field EMS Quality, Innovation, and Cost Effectiveness Improvements Act of 2013. This bill is currently in committee with 10 sponsors, it will move the national office for EMS to Health and Human services, which more accurately reflects the realm in which we operate, it acknowledges and incorporates the concepts and goals of the EMS agenda for the future, addresses the concerns of the IOM report EMS at the crossroads, provides funding for study and implementation of new delivery models, and directs CMS to include field EMS models in their testing. This bill will provide the needed framework, funding and focus needed to move EMS forward in a logical and responsible way without depending on Obamacare, ACO’s or some other magic pill. This bill will achieve many of the goals of Obamacare and healthcare reform in general as they pertain to EMS functions, but it will also add the stability needed for 911 EMS systems to plan and sustain operations while making these needed changes without selling them out. The draft white paper produced by NHTSA & HHS does not articulate a strong desire to maintain 911 EMS capabilities or identify how to accurately account for its cost although other NHTSA publications, such as the EMS System Performance-based Funding and Reimbursement Model by the National EMS Advisory Council do. Perhaps once all realize that EMS is both public safety and public health we can realize some progress.

Be Safe,



References;

EMS Agenda for the Future, NHTSA 1996

EMS Agenda for the Future- Implementation Guide, NHTSA 2010

EMS at the Crossroads, National Institutes of Medicine 2006

Innovation Opportunities in EMS- A Draft White Paper, NHTSA/HHS 2013

H.R.809 - Field EMS Quality, Innovation, and Cost Effectiveness Improvements Act of 2013, 113th U.S. Congress 2013

EMS System Performance-based Funding and Reimbursement Model, NHTSA, National EMS Advisory Council 2012

Wednesday, July 24, 2013

A Squirrels Perspective -revisited

A Squirrels Perspective
of Legislation Affecting EMS and Good Decision Making

By Alan Perry 7/24/2013


Introduction
I have been trying to understand the pushes in EMS toward Mobile Integrated Healthcare Practice (MIHP), Community Paramedicine and the function of Accountable Care Organizations (ACO’s). It appears I have been looking at it from the wrong perspective, assuming that it has been driven internally by the healthcare community delivering on recommendations made by the National Highway Traffic Safety Administration (NHTSA), the Institutes of Medicine (IOM) and others which have spelled out clearly what steps need to be taken to integrate our healthcare system and move pre-hospital EMS into full partnership with other healthcare fields. While the power of these recommendations has moved many organizations and systems forward, they have failed to garner widespread adoption in the years since they were written. What is pushing the change now, at this late hour?

Methodology
I proceeded to work backward studying applicable portions of various programs, exploring the contents of pending legislation and healthcare law. I will admit that this process was not very methodical; I focused my attention on pieces that were overtly related to EMS and limited that material to what was most applicable to daily pre-hospital EMS operations, financing and coordination with other healthcare organizations. I compare my actions, and that of many EMS systems, to that of the squirrel finding itself in the middle of the road and not being able to decide which way to run, therefore my focus has jumped around quite a bit and I still see the vehicle of healthcare system reform coming at me! I hope I can illustrate for my own benefit, and others, what the options and potential consequences are before we simply get plowed over by the changes before we can react. My opinions here are by no means “expert” and I encourage everyone to read the actual documents before taking any action or embarking on a substantial project.

The Patient Protection and Affordable Care Act
Enter Obamacare; Section 5101(d)(2) of the Patient Protection and Affordable Care Act (Affordable Care act) Titles III & V provide the impetus for change in payment strategies, development of ACO’s, community healthcare teams and coordinated care. The mandates are very broad and do not specify the “how” or “who” just the desired outcome, leaving the whole process up to substantial interpretation, funding is achieved through costs savings to successful participants. The intended effects of the Affordable Care Act are sweeping change to business as usual in the healthcare arena; Emergency Medical Services (EMS) is no exception. The mandated changes will occur by adoption of new and more effective delivery methods by the existing providers within each region, or their replacement by new ones. This is not a suggestion; it is a flat out requirement. The federal government is using a carrot/stick approach, with financial rewards for performers and penalties for failure, such an approach will be game changing, spelling financial ruin for those who cannot adapt and creating much more competition, EMS systems will be no exception. This has created renewed interest in the ancient texts written by NHTSA and IOM, leaving me personally wondering if we may have waited too long. I can see control of EMS systems and organizations being slowly taken away and replaced with something we will have no hand in developing, unless we act quickly, deliberately and intelligently.






References:
HR 3590, Patient Protection and Affordable Care Act

HR 809, Field EMS Quality, Innovation, and Cost Effectiveness Improvements Act of 2013
GovTrack website

National Academies Press, Best Healthcare at Lower Cost

National Academies Press, EMS at the crossroads

National Highway Traffic Safety Administration, EMS Agenda for the Future: A Systems Approach

University of Exeter School of Psychology, Animal Cognition