Clinical Decision Support for Regulatory Compliance
By Shannon O’Brien
Clinical decision support (CDS) is a broad term that can have many definitions depending on who you ask. To some, CDS is a black box of algorithms that detect complex, esoteric medical conditions that would have otherwise been missed without the help of software to connect the dots. Others think of CDS as a path to automating routine diagnosis so that clinicians can focus on more nuanced patient assessments. While both of these are great examples of applications of CDS, an area that is not generally thought of is using CDS to help streamline administrative functions, primarily in the areas of regulatory compliance.
The American Hospital Association (AHA) released a study in October 2017 quantifying the burden placed on health care systems, hospitals, and post-acute care (PAC) providers related to regulation. They found that these providers spent nearly $39 billion a year solely on the administrative activities related to regulatory compliance[i]. Their study was limited to four federal agencies and did not include the cost associated with regulations imposed by state, local or payer organizations. Additionally, they found that an average size hospital with 161 beds dedicates 59 full time equivalents (FTE) to regulatory compliance and of those 59 FTEs, over one-quarter are doctors and nurses.[ii]
Regulatory Compliance Complexity
To get a sense of the complexity related to regulatory compliance, hospitals that provide PAC services are required to comply with 629 discrete regulatory requirements according to the AHA study. Major pain points related to these regulations include duplicative documentation requirements, excessive training due to changing regulations, and varying reporting requirements that often require manual data extraction[iii].
Key Advantages of CDS Systems
CDS systems are well positioned to help alleviate some of this overhead, both from a training and reporting perspective. These systems are designed to aggregate and normalize information from disparate data sources, reconcile overlaps and conflicts, and derive individualized insights regarding patient needs. CDS can be used to reconcile regulations across multiple agencies to ensure that data collected in one context can be reused when possible to feed other regulatory requirements. It can expose conflicts in overlapping guidance so they can be thoughtfully resolved before broad distribution to clinical staff, avoiding unnecessary confusion. Physicians can be provided with intuitive electronic checklists that distill down which regulations apply to which patients and what actions must be taken for those patients in order to meet compliance requirements. As these actions are taken and recorded in existing IT systems, the CDS platform can be used to automatically build reports in varying formats required for submission to the governing agency.
The other key advantage to using CDS to offset regulatory overhead is that best-in-breed CDS systems are designed to abstract clinical knowledge from the IT infrastructure so that algorithms can evolve independently from the IT systems that power them. This is perfect in the world of constantly changing regulations. As new regulations are mandated, algorithms can be switched out resulting in updated checklists but not necessarily new workflows. Existing data connections and data elements can be repurposed in real-time.
Clinical decision support platforms still have a long road ahead to widespread implementation and adoption. The clinical community needs time to familiarize themselves with these platforms and to begin trusting the insights they provide. Regulatory compliance is an excellent place to start because the challenge is less about making complex clinical assessments and more about tracking countless pieces of disparate and changing information. Physicians are likely more willing to hand this off to technology so they can spend more time focusing on their patients. Over time as CDS proves itself to be a dependable asset to clinicians, CDS companies can build on that trust and footprint to begin addressing more complex and nuanced clinical problems at scale.
Shannon O’Brien has over 10 years delivering mobile and web products in a variety of health care arenas including clinical decision support, home health and population health. Cognitive Medical Systems is a fast-growing company helping public and private organizations make the most of clinical decision support tools. They draw from decades of operational experience in health delivery, informatics, and enterprise software development, specializing in complex infrastructure, workflows and CDS systems integrations.
[i] American Hospital Association. (2017, Oct). Regulatory Overload – Assessing the Regulatory Burden on Health Systems, Hospitals and Post-acute Case Providers. Accessed Mar 5, 2018, https://www.aha.org/system/files/2018-02/regulatory-overload-report.pdf.