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The Centers for Medicare & Medicaid Services (CMS) announced last month that it was rebranding its familiar electronic health record (EHR) Incentive Programs from “meaningful use” to “Promoting Interoperability.”

Among the proposed changes are welcome simplifications in reporting protocols, as well as new requirements surrounding EHR capabilities. Specifically, these new requirements seek to improve pricing transparency, facilitate the sharing of patient information between providers, and further engage patients in managing their care. To accomplish this, all eligible providers will be required to demonstrate compliance with 2015 Edition of CEHRT by next year.

Which is great – these are excellent and important changes, and I am anxious to see how they could positively impact my patients. On the other hand, I worry that in focusing on external interoperability, healthcare providers will ignore the value of internal interoperability.

External Interoperability

To clarify, when I say external interoperability, I’m referring to the type of interoperability that CMS is currently emphasizing. Specifically, a hospital or health facility’s ability to communicate clearly and securely with external EHR systems and their patients.

There is significant room for improvement in external interoperability. According to Black Book Research, 36% of medical record administrators report struggling to exchanging patient health records with other providers, particularly physicians not on the same EHR platform. A further 24% report that they are still unable to access meaningful patient information received electronically from external sources.

These types of provider to provider communication is extremely important. Sharing patient data across providers and EHRs results in better care coordination, with fewer redundancies in testing and treatment that play a large role in the patient experience. Similarly, giving patients access to their health data significantly improves patient-provider communications, which can in turn affect health outcomes.

So yes, external interoperability is extremely important. But I worry that focusing exclusively on these capabilities will pull the focus away from something most EHRs still struggle with today – internal interoperability.


A recent report by Standard & Poor offers a bleaker outlook: “We expect a material portion of the approximately 435 LTACH facilities nationwide to close over the next few years amid the phase-in of lower reimbursement.” With the second phase of payment changes still on schedule to roll out in 2018/2019, we must begin asking ourselves if we are truly prepared.

Futureproofing the LTACH Industry

There are many strategies LTACHs could employ to offset the effects of the recent Medicare reform, such as

  • Changing year-end reporting dates
  • Diversifying through acquisitions
  • Portfolio optimization
  • Cutting costs
  • Shutting down unprofitable facilities
  • Attracting patients still eligible for the attractive LTAC-specific rate.

These strategies help optimize your census to maximize profitability.

Another strategy that can positively affect the survival of LTACHs is one you’ve likely already heard of: dedicated care coordination from pre-admission to post-discharge.

Historically, LTACHs have been slow to improve care coordination and reduce readmissions, content to wait for the emergence of third-party companies that will specialize in care coordination… for a hefty fee. This is a mistake. Only aggressive action towards in-house care coordination will ensure the long-term survival of your business while significantly improving outcomes for your patients.