Killing Kennedy’s Spirit

I am proud to have shared life on this earth with Jack Kennedy: sad to accept that it was but for a much briefer overlap than should have been; yet happy I grew up in a country that was influenced by his wisdom, reflective of his spirit of determination and embedded with his sense of compassion.

I chose this picture because it is the same one I used to have framed and hanging in my room when I was in high school and had with me through college. It was a gift from my parents that – regrettably as with too many other things from my young life – somehow got lost between my ideological youth and responsible adulthood.

Just last month I was in Dallas, and for the first time I looked down upon Dealey Plaza from the Hyatt Regency’s Reunion Tower. Whether because of timing – being as it was so close to today’s 50th anniversary of the assassination – or not, there is no way of knowing, but that image was beyond compelling. I have had the misfortune of having experienced my fair share of blow-to-the-stomach moments of emotional pain, so I am not so easily moved. Yet in that moment I felt a deep sadness that was hard to shake – as if I were witnessing at the same time the tragedy of what was along with the pain of knowing what might have been.

I have written before and hold fast to my belief today that it is never wise to set a human being upon a pedestal. If not their flaws then certainly their death ultimately proves their humanity. Jack Kennedy was human on both scores. But unlike many political heroes before, he carried above him an ideological beacon that alighted upon a generation with renewed hope and energy for what a country might accomplish through collective effort – rather than  individual pursuits.

Sadly, that message from his 1961 inaugural address has been lost. Perhaps it went the way of adult responsibilities too. Or perhaps it has gone the way of greed and avarice – envy, jealousy and spite. Whatever the causes, we only have ourselves to blame for its absence: we have killed that spirit of Jack Kennedy as surely as Oswald killed the man himself.

  ~ Sparky

The Racial Tipping Point?

This past Friday Rush Limbaugh took marked exception – yes, even for him – to Oprah Winfrey’s comments made during an interview with BBC Arts Editor Will Gompertz discussing a new film she stars in: The Butler. Oprah was responding to a line of questioning that was seeking to understand from her perspective whether and to what extent the race issues addressed in the movie were historic versus contemporary (that’s a bit of context that most of the popular media has left out of this story from what I’ve read).

Within this context, and in response to Gompertz’s question regarding whether or not President Obama has faced race-related challenges, Winfrey made the assertion that the president is disrespected in “many cases” because of his race. She said that, “just the level of disrespect, when the senator <sic> yelled out, ‘You’re a liar!’ Remember that? Yeah, I think that there’s a level of disrespect for the office that occurs, and that occurs in some cases and maybe even many cases because he’s African-American … there’s no question about that. And it’s the kind of thing that nobody ever says but everybody’s thinking it.”

Well, love him or hate him, Mr. Limbaugh has never been in the camp of not saying what he’s thinking. And so he did, rhetorically asking of Oprah on his radio show, “then how the hell did you become who you are?” and, “why hasn’t anybody in your audience, Oprah, ever said, ‘You lie!’? Because you have. It wasn’t a senator, Oprah. It was a congressman by the name of Joe Wilson, and he was right. Obama was lying.”

Limbaugh admitted that he had to be “really careful” because Oprah is seen as a “goddess to a lot of people,” but went on to add that, “these people are not nearly as smart as they think they are, and they don’t know nearly what they think they know,” he continued. “They are embarrassingly ignorant. It wasn’t a senator. It was a congressman. And it’s not because he was black. It’s because he was lying, Oprah! He’s lying now!”

As often happens, Rush Limbaugh seized upon a particular aspect of a news story that he could effectively carve out of and away from a much more complex issue – and in so doing make it appear that his ability to attack that aspect is the same as attacking the broader issue. Of course it is not, but then I think his remarks regarding Oprah’s audience could just as easily be applied to his own.

The underlying point that I think Limbaugh could have made – maybe really wanted to make – is becoming an increasingly relevant and legitimate question: are we nearing, or have we reached, the tipping point where our collective sensibilities to racism are doing more to hinder the advancement of civil rights than help? Let me put it another, more direct way. Is the fear of being called a racist – and everything that entails – becoming an albatross around the neck of society to the point where there is today more concern about being called a racist than being racist?

I imagine Ms. Winfrey would respond that as long as racism exists – which most certainly it still does – the risk of her offending those who are not racist is far outweighed by the need to continue communicating its prevalence. I have no way of knowing whether or not that would be her perspective, but I would find it hard to argue with. I’m not sure Mr. Limbaugh looks at the world that way because if he did, I think he might not have taken such vociferous exception to Oprah’s comments. He might instead have asked the questions that I have above.

What do you think?

Cheers,
  Sparky

 

People Don’t Come in Boxes . . .

… so why put them there? In this 21st century age of political correctness we bend over backwards in fear of causing an affront to any group that can call itself a group by virtue of having two or more like-minded people. And yet turn on any major news outlet and the jargon is awash with political stereotypes: the left, the right, the Dem’s, the Pub’s, the moderates, the Tea Party, etc., etc.

It might be more palatable if those were just partial or contributing descriptions, but quite often that’s all the effort that goes into providing someone’s background. They will say, “well, you know, he’s a conservative, so . . .” as if that should embody the sum total of a person’s intellectual existence. I am reminded of a scene from Good Will Hunting. Robin Williams and Matt Damon are seated in front of the Boston Public Park, and Robin Williams’ character, Sean Maguire, takes the young genius Will Hunting (played by Damon) to the intellectual woodshed while helping him understand that both facts and life’s experiences contribute equally to one’s vantage point. Key moment from that script:

Sean: You’re an orphan, right?
Will nods quietly.
Sean: Do you think I know the first thing about how hard your life has been … how you feel … who you are, because I read Oliver Twist!? Does that encapsulate you?

But that’s exactly what we do when we insist on putting people into ideological boxes. We presume to know how they think, their beliefs, their feelings, what motivates them, how they will react in different situations.

I realize that it’s often just innocent and convenient expediency to categorize people as part and parcel of making sense of our chaotic political environment. But if you stop and think about it, that really adds very little to intelligent discourse. To the contrary, it risks the creation of stereotypical dispositions that are manifested as filters of arrogance and ignorance. Recall habit 5 of Steven Covey’s Seven Habits of Highly Successful People (as borrowed from the Prayer of St. Francis):  Seek first to understand – then to be understood.

That’s not a lesson in humility or self deference. It’s a basic tenet of effective communication. Those who take the time and make the effort to understand the views of others are much more effective in communicating their own ideas – and doing so in a way where those ideas can lead to actionable outcomes.

A final point. When we place individuals into ideological boxes – for example as we do with politicians – we should not be surprised when those individuals interpret their station much like an actor on stage: they act to the audience. They perform consistent with the audience’s expectations. So when we as the body politic lament the polarization of Washington perhaps we should stop to consider our role in building the stage upon which those players act.

Cheers,
  Sparky

NSA ~ “For That Day . . .”

One of my all-time favorite movies is Three Days of the Condor. Directed by Syndey Pollack, it stars Cliff Robertson as the antagonist Deputy Director of the CIA’s New York division, Robert Redford as the protagonist CIA agent, code name Condor, Faye Dunaway  – and Max von Sydow, who plays the character of Joubert, an international hired assassin whose affable yet cold and calculating indifference to life and politics serves as artistic imagery for the story’s thematic conflict.

Produced almost four decades ago, there is an epic scene at the end of the movie (see below) that, except for changes in fashion design, is as relevant and timely today as it was in the mid 70s. At issue is the value and role that secret intelligence plays in national security. More particularly, it is about the conflicting interests of national security versus individual privacy. Does that sound familiar? Wikileaks . . . Eric Snowden . . . Prism . . . Google . . . Benghazi . . . Angela Merkel . . .

“Ask them”

In an age of electronic media acceleration, knowledge and information that becomes available under the auspices of national security can almost instantaneously be perverted into intellectual weaponry. And once individuals with access to that intelligence who are also seeking positions of political power recognize the value of such weaponry it creates an addiction that goes well beyond the original intent. I think it would be nearly impossible today to determine how much intelligence gathered in the name of national security is primarily used for political security.

For decades we have somehow been able to muddle through a balance between protecting national security and providing the masses at least the illusion their private lives are just that – private. That balance is now in serious peril in a way that it never has been. As Robertson’s character argues in the final scene of Three Days, it’s way too late to discuss the appropriate balance between intelligence gathering and personal privacy when a national threat has been manifested in a way that threatens lives (watch the video).

In lieu of such threats from terrorism and WMD, we discount the value of intelligence protecting our national security at our own peril. But at what point does the cost of gathering that intelligence – in terms of privacy and personal liberty – no longer justify the reduction in risk to our lives? Invoke Patrick Henry here. That is a discussion that we have to have in this country, independent of political interests, and the sooner the better.

Cheers,
  Sparky

What’s Next for the Tea Party?

What’s Next for the Tea Party?

550px-Remove-a-Stuck-Tongue-from-a-Frozen-Surface-Step-3One might think the graphic accompanying this post was leaked from Sen. Ted Cruz’s political strategy playbook: the next chapter in The Tea Party’s Fight to Repeal the Affordable Care Act. It’s not. Could be though, right? The metaphor holds of doing something foolish to gain popular attention and then suffering the individual consequences of that foolishness.

Of course, Tea Party advocates will no doubt claim I am being foolishly satirical and hypocritical for not recognizing my own ignorance in understanding the dramatic importance of standing up for liberty, fiscal responsibility and apple pie. If they truly believe those were Senator Cruz’s motivations, well then what can I say – they must see a political reality in this country different than the one I see.

Even if we were to believe the efforts of Senator Cruz and other Tea Party congressional enthusiasts – to hold the country fiscally hostage for over two weeks in an effort to defund the ACA – were nonpolitically motivated, the overall reaction of the American public can hardly be what they were hoping for. According to a Pew Research Center poll released yesterday, the Tea Party is less popular than ever, even among many Republicans, with nearly half (49%) of survey respondents having an unfavorable opinion. This is up from 37% in June of this year.

On the other hand, Senator Cruz’s popularity among Tea Party respondents has risen from 47% to 74% since July. I’m not sure how well that bodes for his future political aspirations (at least outside of Texas, if that was of interest), but I am being sincere when I say that I respect the all-in approach of any elected official because it represents a refreshing departure from governing by opinion polls.

My view of the Tea Party, for better or worse, is largely based on the individuals I know personally who are either sympathetic to, intellectually aligned with or proud to be members. I find them to be generally well informed on political issues and passionate about protecting individual liberties. Things go downhill when we start debating who gets to define which liberties should be protected and by whom, which I interpret as the Tea Party being discerningly different than many Libertarian viewpoints.

They are very concerned – and I think rightly so – with the economic future of our country and seem to understand more than most that both political parties are guilty of sustaining special-interest budgeting despite whatever expressions of concern we may hear to the contrary. That’s where a large part of the inherent challenge to the Tea Party’s future lies. As shown in the Pew Research poll, there is a lot of confusion, disagreement and debate over whether and how well the Tea Party “fits” within the Republican Party.

I personally hope it finds its national voice apart from the GOP. If it has something meaningful to offer in the nation’s political discourse – it could hardly do worse – then it should seek to do so through the existing construct of our democracy and not by resorting to Machiavellian tactics whereby it seeks to bend the will of a majority to its beliefs (again, I refer you to the Pew Research poll).

I admit, there is a real attraction to a grass roots political movement in an age where electoral helplessness – whether learned or systemic – has become anathema to a democratic form of government. But waxing nostalgic for the 18th century and expecting that same apathetic electorate to embrace the social and cultural norms of men in wigs and women in hoops is a very tough sell.

And that’s where I find the greatest difficulty in accepting my Tea Party colleagues’ personal political platform. To me it feels like hidden below the surface of, “strike a blow for liberty,” “defend the Constitution” and “balance the budget” is an observable pattern in their logic and debate that belies a commiserate longing for the good old days.

I think all of us over a certain age find ourselves quite often reflecting on a past that was less stressful, less fearful, less threatening and certainly less complicated. Today we live in a world of constant change that just one generation removed couldn’t possibly have imagined. In his book, Managing at the Speed of Change, Daryl Conner talks about the Beast: a metaphor of the challenge each of us faces in adapting to constant change in our environment. It takes incredible resiliency to maintain good mental health in the 21st century.

I do not believe effective public policy – including Healthcare policy – can or should be based on what worked in the good old days. As Don Henley wrote, “those days are gone forever – [we] should just let ‘em go but…” Today we live in a society that is aging at an accelerated rate, that is growing in ethnic and cultural diversity and is inundated on a 24-7 basis with technological advancements that introduce hope and terror in equal measures.

With that understanding of reality, my primary concern with the Tea Party is the perceived sense of moral intransigence and impractical political dogma that transcends their beliefs. We should be focusing our efforts on how best to practically adapt a constitutional style of government to the world we live in today – not expecting today’s society to mirror that of the 1700s. I think I share just as much angst and anxiety over our nation’s future as do my Tea Party colleagues. I just don’t believe that going backwards offers much hope in addressing the problems we face today and tomorrow.

Cheers,
  Sparky

We ARE The Media: Entertain US

We ARE The Media: Entertain US

Screen-Shot-2017-03-26-at-4.25.06-PMOriginally published in October of 2013
With the already caustic and demoralizing rhetoric that is coming out of Washington being elevated to (hard to believe) new levels via the Shutdown, a short departure from healthcare policy discussion seemed like it could be in order.   I
copied the video below off of the Michael Smerconish
web site. If you haven’t caught Michael’s program on Sirius/XM’s POTUS channel, it’s definitely worth a listen.

I don’t know who compiled the video, but it’s a short and poignant demonstration of the role media plays today in perverting the exercise of constructive and productive political dialogue and debate in the interest of entertaining us (i.e., the nature of their business model).

We could argue until the cows come home whether election campaigns drove media toward spiteful irreverence or the media has been driven by candidates’ inherent egos and desire for power – but either way the result has been manifested in the most threatening domestic scourge this country has faced since slavery. I know that’s a bold statement, but watch the video and just watch what’s happening right now in Washington – that’s right, nothing!

What makes the media threat especially troubling is that it is like a cancer: you can’t just start hacking away at the parts you don’t like without risking a primary tenet of democracy, that being of course the freedom of speech. But in what I think is a sardonic twist of irony, we seem to have the same culpability empowering the media that we have in empowering stagnant governance: in both cases way too many of us are too damn lazy to exert the personal effort needed to make a difference.  We complain about government but don’t take the time to be informed voters – or don’t vote at all (roughly 4 in 10 eligible voters didn’t vote in the 2012 election).  And we complain about media programming, but somebody must be watching and/or listening to warrant advertising expenditures supporting that business model, right?

So here’s what I would like to offer. Regardless of what side of the aisle your allegiance lies – or wherever your political beliefs may fall along the ideological spectrum – I believe just about all of us are sincerely interested in the truth. And I think most of us agree as well that modern media programming in the name of entertaining us has done more to obfuscate the truth than help us find it.

Part of the blame lies with the media because they seek to package facts in entertaining sound bites. I am reminded of a quote by the late author, Shelby Foote, who once said that, “people make a grievous error thinking that a list of facts is the truth – facts are just the bare bones out of which truth is made.” If you seek the truth, don’t ever assume that it can be given to you even if you ask in the nicest way possible.

A good part of the blame we want to put on the media belongs to us. We need to take ownership for defining the truth and not abdicate that responsibility to broadcast journalism because we prefer to be entertained.  Without wanting to wax metaphysically, truth only exists because of the individual’s desire and willingness to find it – not because someone else has already created it for us.

Cheers,
  Sparky

Extremist Outtakes

It’s About Value, Stupid

The title of this post is a reminder to myself and not intended to offend the millions of other participants in healthcare to whom its application may or may not apply. I remind myself of this assertion quite often – primarily because I believe it provides the singular most important connection between the practice of healthcare and the business of healthcare. It also has the theoretical advantage of transcending many of the political realities of public policy because it reinforces commonly held beliefs regarding individual liberties, morality, as well as social consciousness.

That is why I am very excited about a new initiative I wanted to share with Pub visitors: last week, the New England Journal of Medicine announced a new collaborative publishing initiative with Harvard Business Review. Beginning on September 17th, new articles are being shared daily via the Insight Center for Leading Health Care Innovation.  Over an eight-week pilot period new articles will be posted daily, “from numerous experts across health care and business communities.” The content shared will be free during this pilot phase, so I strongly encourage you to at least take a few minutes to peruse the variety of information and insights offered there.

One of the most prominent initial contributors, Michael Porter, has written and spoken at length on Value in Healthcare. In fact, he and his coauthor, Elizabeth Olmsted Tiesberg, published Redefining Healthcare in 2006, in which they argued that historically health care systems have competed to shift costs, accumulate bargaining power and restrict services – rather than create value for patients. To address this shortfall Porter and Tiesberg have offered specific policy recommendations they believe can help reposition the potentially positive effects of market competition from between health plans, networks and hospitals to where it would be a lot more effective in producing value: i.e., at the level of diagnosis, treatment and prevention of high cost illness and conditions.

I should also note (and recommend) Porter’s latest article featured in the October issue of HBR and coauthored by Dr. Thomas Lee (CMO at Press Ganey), The Strategy That Will Fix Health Care. Porter and Lee rightly argue that healthcare providers are the only ones who can ultimately reframe the US healthcare delivery system into one that delivers high value. They discuss six interdependent components:

1. Organizing around patients’ medical condition
     rather than  physicians’ medical specialties
2. measuring costs and outcomes for each patient
3. developing bundled prices for the full care
    cycle
4. integrating care across separate facilities
5. expanding geographic reach and
6. building an enabling IT platform

I think they purposely left off #7, pushing the camel through the eye of a needle. Please don’t take my sarcasm for lack of interest and support, but I am of an age where I tend to be a realistic chap. Between the theory espoused on the pages of HBR and the practice that is often manifested in care providers’ growing frustration with the obstacles they face in caring for their patients lies the enormous ball of yarn, which has been healthcare public policy in the US for the past 50 years.

I do believe, however, the value paradigm offers great promise in building a healthcare system where lower cost and higher quality are not viewed as a diametric choice but rather complimentary results of market competition. But there are indeed miles to travel before any such paradigm shift can be realized.

Value is not a foreign concept to healthcare, so I want to be wary of conveying the sense that a silver bullet exists, just waiting to be found so that in a single shot our delivery system can be cured. But value – whether seen through the prism of a patient’s ability to assess a surgical procedure, an insurer’s ability to assess the quality of an outcome or a nurse’s ability to assess the fairness of his or her employment contract – is way too often obfuscated to the point where it cannot serve the purpose of driving competitive performance.

I am hopeful the contributors to the new Center will be mindful of this observation as they seek to promote the potential benefits of a value-driven healthcare system.

Cheers,
  Sparky

LTC Mainly About Dementia Care

LTC Mainly About Dementia Care

Today is World Alzheimer’s Action Day. And this past week Alzheimer’s Disease International issued, World Alzheimer Report 2013 ~ Journey of Caring: An Analysis of Long-term care for Dementia. As noted there, “ Long-term care for older people is, mainly, about care for people with dementia. Dementia and cognitive impairment are by far the most important contributors, among chronic diseases, to disability, dependence, and, in high income countries, transition into residential and nursing home care.”

Recognizing how integral dementia care is to developing public policy that address the needs of seniors in need, I thought this was a good opportunity to make available again the webinar my Artower colleague Dr. Lori Stevic-Rust did a little over a year ago.

Organizations that are interested in getting out ahead of the curve on developing care programs for individuals with Alzheimer’s/dementia that bring high value to integrated care delivery models under Healthcare Reform will benefit from watching this presentation.

Enjoy,
  
Sparky

                                            
      Click to                              Click to
   Play Webinar                     Download Slides

The Realities of Defunding

The Realities of Defunding

obamacarefingerbitingLG-300x158Last week the once relevant political operative of right wing influences, Karl Rove, wrote an editorial in the Wall Street Journal, Republicans Do Have Ideas for Health Care. In case you were concerned that defunding the Affordable Care Act would leave the country’s healthcare system in chaos and peril you can now rest easy – the Party of No has a plan. Except they don’t if you go by Mr. Rove’s article.

Before I continue I should note that high hopes of defunding the ACA may reflect a personal perception of authentic patriotism but for most those hopes belie an understanding of our healthcare delivery system, the Affordable Care Act – and most pragmatically, political realities. At the request of Tom Coburn (R-OK), the Congressional Research Service recently published Potential Effects of a Government Shutdown on Implementation of the Patient Protection and Affordable Care Act.

As discussed in that memorandum, defunding of the ACA via government shutdown would not have the intended consequence of stopping much of its implementation while risking the consternation of various constituencies that the Republican party has yet to alienate. Of course, that won’t stop Senators Cruz (R-TX), Lee (R-UT) and Rubio (R-FL) from making political hay out of an issue that strikes a harmonious chord with their conservative bases, and why should it. Those who look for sincerity in the motivations of either (any) political party fail to accept the realities of campaigning and democratic elections in the 21st century.

I should also note that Mr. Rove is on record of disagreeing with these senators. He believes defunding the Affordable Care Act through a government shutdown would give the President, "a gigantic stick with which to beat [Republicans]." I tend to agree and would hope the Republican party could spend more time on developing new ideas that reflect the realities of our current delivery system instead of just being against the ideas of others (and sometimes their own).

In his editorial, Mr. Rove points out several Republican policy initiatives that taken one by one have some merit – both within the context of ACA implementation and under the unlikely hypothetical assumption of its outright repeal. But it is beyond a stretch to suggest that even taken together those several examples he cites constitute a legitimate alternative to the comprehensive approach of the ACA. And therein lies the challenge that many (most?) political wonks, talking heads and sound bite artisans face when discussing healthcare policy. Our healthcare delivery system is complicated and complex beyond reason, and certainly way beyond necessity. But you have to play the game on the field you’re given not on a chalkboard.

Several of the policy initiatives Mr. Rove cites deal with health insurance: portability of policies, employer risk pooling and selling premiums across state lines. I think these are plausible modifications and/or addendums to the ACA approach that are worth circumstantial testing.  But part of the recognized challenge up front is that these approaches are dependent upon employer-based insurance, which most policy experts agree was never a good idea to begin with. And they leave out a wide swath of the population that doesn’t receive employer-based health insurance. If we didn’t think there was merit in providing healthcare benefits to those unable to afford such coverage, then these would be top of mind ideas.

Another initiative cited, medical liability (or tort) reform is a bit like the weather: everyone complains about it but nobody really ever does anything to change it. Perhaps that’s because of the preponderance of Congress who are also lawyers. But there is another line of thought that believes increasing quality and safety might also be a pragmatic approach to lowering malpractice liability. What would we rather have: the forbearance of frivolous suits that also risk restricting justice to individuals – or the reduction in the basis upon which such suits are brought. In reality, we probably need both.

Of the several reform initiatives Mr. Rove shared transparency has to be the weakest example of meaningful policy. Pulling the cover off of the Invisible Man won’t change your view of him. And mandating that meaningless provider charge rates (prices) be published won’t enable better decision making by consumers (patients). I addressed this back in February in a post I entitled, Pick a Price.

Moving on, allowing Medicaid patients to apply their governmental benefits toward private insurance sounds reasonable enough. Unfortunately, it would be bad policy. Although there are already a number of states seeking to leverage private insurance capitation models as a hybrid compromise to Medicaid expansion within the context of the ACA, those models still maintain control over risk pooling so as to address adverse selection.  While allowing funds to be indiscriminately repurposed may sound like an idea promising to partner individual choice with market efficiencies, as Naomi Freundlich addressed in her Healthcare Blog post, the reality of implementing such an idea is another matter entirely.

Finally, Mr. Rove writes that, “the president and his liberal posse have a fundamental, philosophical objection to conservative ideas on health care. They oppose reforms that put the patient in charge rather than government, that rely on competition rather than regulation, and that strengthen market forces rather than weaken them.”

Disingenuous assertions like this do little to advance meaningful healthcare policy discussion. This is no different than liberal talking heads claiming that conservatives seek to advance healthcare policies that benefit (or are structurally biased toward) the wealthy at the expense of the poor. More generally, asserting that the ACA’s hidden agenda is to abscond personal liberty in favor of governmental control misses the point of the real debate entirely. Both the theoretical and practical debate is not over whether the government knows better than the individual what is best for the individual. The debate is in how public policy can best balance the protection of personal liberties while morally advocating for the rights of those individuals with far less ability to secure affordable, quality healthcare. Some feel healthcare is a basic right secured by the Constitution. Others do not. What do you believe?

Cheers,
  Sparky

QAPI ~ Ready (or Not?)

QAPI ~ Ready (or Not?)

2013-01-09_14251sI have been receiving a fair amount of anecdotal intelligence that many post-acute/long-term care providers are not at all prepared to implement the Affordable Care Act’s QAPI when (still waiting . . . ) those regulations ultimately get published. So I thought sharing this post again might be useful.

Section 6102(c) of the Affordable Care Act – Quality Assurance and Performance Improvement Program (or QAPI) requires the Secretary of Health and Human Services (as delegated to CMS) to, “establish and implement a quality assurance and performance improvement program …” and to, “…establish standards relating to quality assurance and performance improvement with respect to [nursing] facilities and provide technical assistance to facilities on the development of best practices in order to meet such standards.“

Last Friday CMS released a memorandum to state survey agency directors announcing the rollout of electronic assistance and compliance-oriented materials on the QAPI website. HHS/CMS has still not yet published the condition of participation regulation that will provide nursing facilities with compliance guidance (facilities were to have already been compliant in March of this year), but there already exists comparable regulations for other healthcare provider types that will serve as a template. Once that regulation is finally published nursing care providers will have one year to develop an acceptable QAPI plan.

QAPI compliance for nursing facilities is not entirely new. The nursing facility QAPI is based in part on existing Quality Assessment and Assurance (QA&A) regulations. However, the new planning and reporting provision significantly expands the level and scope of QAPI activities that nursing facilities must enact in order to ensure they continually identify and correct quality deficiencies as well as sustain performance improvement.

It is a tad ironic that in promoting a key differentiator between historic, traditional quality assurance – now being coupled with performance improvement – that while quality assurance is to be viewed as a requirement and reactive, performance improvement should be viewed as discretionary and proactive. Never mind that performance improvement is being mandated as part of the QAPI program. Sort of like being able to choose any whole number between zero and two, right?

Anyway, I really fear that for a lot of nursing facilities – particularly smaller and/or single site organizations – this requirement is going to sneak up on them. And the true impact of that reality will not just be the regulatory and economic consequences but the lost opportunity to utilize the QAPI process to drive better quality, higher safety and better outcomes – while lowering the overall cost of care.

There are two ways to view the new QAPI requirement: another onerous regulation designed to burden caregivers with unnecessary compliance requirements at additional cost; or an opportunity to sponsor and embrace a process that – if done strategically and conscientiously – should improve productivity and efficiency while strengthening market position based on quality and outcome characteristics.

So my counsel is don’t wait for the regulation to be promulgated. Start now to learn and understand the tools that have already been made available. CMS has stated that, once provided, the QAPI formal regulation will not contradict the materials that have already been developed and provided.

And for those organizations that are truly interested in taking a strategic approach to developing a continuous quality improvement system that has the complimentary advantage of combining regulatory compliance with value-driven financial performance, please review the white paper that I drafted with colleague Nathan Ives of StraegyDriven Consulting, Aligning Healthcare Organizations: Lessons in Improved Quality and Efficiency from the Nuclear Power Industry.

Cheers,
  Sparky