ANN ARBOR, MI – The College of Healthcare Information Management Executives, with more than 1,400 CIO members, is urging the Centers for Medicare & Medicaid Services to rethink the government’s rulemaking proposals on accountable care organizations. At issue is a provision that would give individuals the option to restrict access to data.
CHIME’s view is that the rules, as proposed, “would restrict the flow of information and create significant pressures on accountable care organizations.”
“If beneficiary claims data are withheld, the ACO’s ability to improve individual beneficiary health, as well as achieve the desired shared savings, could be compromised,” CHIME stated in its comments to CMS. “We believe that allowing ACO patients to opt out of data-sharing, while maintaining their ability to see the primary care physician participating in an ACO, contraindicates efforts to provide accountable care.”
CHIME recommends that patients who want to opt out of sharing claims data be required to see a primary care physician not affiliated with an ACO, or that healthcare expenditures for these patients not be included for calculations to determine whether an ACO is eligible for payments for shared savings.
CHIME filed its comments with CMS on May 10 in response to the CMS Notice of Proposed Rulemaking for governing ACOs. The deadline for comments was June 6.
CIOs see data sharing as critical
As CHIME sees it, an optimized approach to information technology is important for ACOs because this new delivery model will have the best chance to succeed if patient and population data can be shared across the continuum of care.
“Technology will no doubt play a prominent role in the success of any ACO,” said William Spooner, senior vice president and CIO at San Diego-based Sharp HealthCare. “The amount of data and information exchange between ACO participants will be enormous. But as the person responsible for lining up those data points, CIOs are really worried about patient data opt-out provisions. We think the simplest answer is to remove patients from ACO participation if they refuse to share their data.”
CHIME also notes that the proposed ACO rule tries to encourage the meaningful use of EHRs, but it takes issue with a requirement that stipulates that 50 percent of an ACO’s primary care physicians (PCPs) meet all MU standards by the beginning of the second year of the ACO’s agreement with CMS.
“From both patient management and business perspectives, CHIME feels it would not be necessary for an ACO’s PCPs to meet all MU requirements. Similarly, CHIME sees no need for CMS to specify some minimum level of EHR MU performance for the hospitals participating in an ACO,” CHIME said.
“Our comments speak to the complex technical implications of CMS’ Shared Savings Program,” said Pam McNutt, senior vice president and CIO of the Methodist Health System in Dallas and chairwoman of CHIME’s Policy Steering Committee. “As hospitals look to participate, they will depend on CIOs to understand how ACOs meet the data collection and reporting requirements. We urged CMS in our comments to avoid prescribing technology, such as requiring meaningful use, instead allowing ACOs to make determinations based off their business needs and patient populations.”
CHIME also is concerned about the proposed use of 65 performance measures in the first year of the ACO program.
“CHIME is concerned that too many measures are being proposed for the start of the Medicare Shared Savings Program, and we urge CMS to reconsider,” its comments said. “CHIME also believes that CMS is underestimating the difficulty of the proposed data validation process.”
CHIME recommends that CMS seek to align performance measures across similar or related programs and outline a more consistent approach for measuring quality improvement for the parts of other programs that overlap.
“We’re all working hard to develop and monitor the right performance measures to make needed improvements to our healthcare system,” said David Muntz, senior vice president and CIO at the Dallas-based Baylor Health Care System and chairman of CHIME’s Advocacy Leadership Team. “But some of the proposed performance measures for ACOs seem to be duplicative or unrelated to broader ACO tenets.”
Finally, CHIME is urging CMS to scale back expectations for the use of health information exchange to give healthcare organizations more time to enter HIE organizations and gain experience with the use of exchanged patient data in care delivery.
“These proposed regulations portend a level of functional health information exchange and technology adoption that may be too aggressive for deployments in January 2012 and not yet ready for effective deployment,” CHIME’s comments said. “We believe this issue could be better handled by allowing ACOs to determine their own technology needs, given their market and their patient population.”