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by terryjsmith 1835 days ago
I did some research into this for my current employer and the challenges are pretty well laid out here: the penalties are minimal ($300 / day or $~110,000 per year), the data is kept in the invoice or billing systems, which are complex, and the hospitals do not want to share the truly groundbreaking data, which is the per-provider costs.

In addition, when you Google for competitors you don't find a lot of them, but once you start looking at hospital websites you find that quite a few of them (about 50% of the ones I looked at) have at least a partial solution, often provided by their analytics company as an add-on or footnote.

It does not appear there is a great market opportunity here unless the penalties increase (which the CMS has talked about vaguely, but hospitals are already asking for relief until after the pandemic).

2 comments

I worked in health care IT (insurance / provider side) during ACA's implementation.

My takeaway is that Congress is technically ignorant of how ossified these backend systems are, but the enforcement agencies (e.g. CMS) are the grease between law and implementation.

F.ex. ACA language and guidance being tweaked right up until the supposed "must be compliant by" date.

Generally speaking, it works about as well as one might hope. All the stakeholders get together, hash out a reasonable schedule for actual implementation, and then everyone generally works towards that.

It helps that the relationships are generally interdependent, and there's enough money sloshing through the system to fund change. So all parties generally do a fair job at converging on the requested changes, quicker than they'd like, but slower than the government would prefer. And then the few trailing insincere implementers start getting beat with fine sticks once the majority of their peers have successfully implemented.

But agile, it ain't.

I agree with everything you said. We're in the ACA space, so this should been right up our alley (government puts new legislation in with penalties to force employers to do something they don't really want to), but the ACA had a much bigger stick and a much longer runway.

Starting January 2023, insurance companies and plan providers need to publish similar data, so to your point that might be the interdependency required for compliance.

Obligatory these views are my own, not my company's.

Based on what you know about the system and all parties, curious on any ideas you'd have to speed compliance (without bankrupting anyone).

Would increased fines do it? Compliance bonuses [0]? Something else?

[0] Showing a few of my cards, I was really impressed with the inner workings of the FEP program, from a management perspective. They seemed to have landed on an effective system of fine + incentive that strongly encouraged good behavior and positive results.

TBH I didn't dig all that deep. Once you look at the size of the market (~6000 US hospitals, most of them in groups [0]), annual subscription (would need to be some fraction of what they would pay in penalties), percentage of market share you could capture (say 25%), discounts for groups, level of support, investment and unknown source systems, etc., I didn't evaluate it as a viable / likely opportunity, especially outside of our existing market.

All of that said, if you knew the space and backend systems and could figure out a way to make it easy, one thing I did hear is that hospitals don't like to be non-compliant, so I think they want a solution (or this to just go away), it just needs to be a really minimal investment for them in cost and time to implement and maintain. The provider data coming into play in 2023 may be the main driver to "normalize" some of this being out in the open.

Usual disclaimers again: my views, not my company's.

[0] https://www.aha.org/statistics/fast-facts-us-hospitals

Edit: add source.

$110k per year seems like a no-brainer for the hospital to just pay rather than comply, assuming they are just purely acting in their own self interest and not for the common good.