January 6, 2012
2012 EHR and Health IT Noise
Written by: JohnI have to admit, I’ve really enjoyed going through and making lists looking back on EMR and Health IT in 2011 and thinking about what is going to happen in EMR and Health IT in 2012. Thanks for everyone who has joined and added to the discussion. It’s been really great!
This next list might actually be the hardest one for me to create. I call it the 2012 EHR and Health IT Noise. You know what I’m talking about. The topics that are going to get talked to death, tweeted everywhere, but won’t really have any major impact on healthcare (at least in 2012). Some would call these distractions.
HIE – Yes, we’re going to hear more and more about HIE’s and their potential. 2012 will still enjoy all that federal grant money that was given to HIE’s. What will we see from it? Maybe a couple books describing lessons learned from all the money spent on trying to set up an HIE. If one or two HIE’s are successful and start sharing patient data with doctors I’ll be really impressed.
EHR Usability – In 2012 I predict we’re going to hear story after story about the lack of usability with EHR software. The complaints will start to pile up, but I don’t think any of that noise will do much to shift the usability of EHR software. It’s a really hard task to dramatically shift the usability of EHR software after the fact. I can’t see many of the legacy EHR accomplishing that shift.
Some new EMR startups may start to come into their own in 2012 with usable EHR software, but they likely won’t be heard above the noise of the other legacy EHR software that’s practically unusable. We’re in a selling spree cycle for EHR software, maybe 2013 will change that.
Mobile Health Apps – This is a little different noise than the others above. This will be noise because there will be so many mobile health apps out there in 2012 and none of them will really consolidate market share yet. I believe that a number of mobile health apps will start to differentiate themselves in 2012, but most people won’t know the difference. They’ll just hear all the noise and try and ignore it.
Meaningful Use – Oh wait, I already wrote about that one here. If you haven’t read the comments of that post, you should. Some good discussion.
Any other things you think will make noise in EMR and Health IT in 2012? I’d love to hear your additions.
Tags: EHR Noise • EHR Usability • EMR and Health IT 2012 • EMR Noise • Health Information Exchange • Health IT Noise • HIE • Legacy EHR • Meaningful Use • mHealth Apps • Mobile Health AppsDecember 28, 2011
Top Health Industry Issues of 2011 – “Top 10″ Health IT List Series
Written by: John- ARRA
- Certified EHR
- EHR
- Electronic Health Record
- Electronic Medical Record
- EMR
- Healthcare
- HealthCare IT
- HITECH
- Hospital EHR
- ICD-10
- Meaningful Use
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Next up in our evaluation of the various end of 2011 Health IT lists series is one that takes a bit of a look back at 2011. In this list, PwC lists what they consider the Top Health Industry Issues of 2011. The list starts with an interesting comment about the health IT spending in 2011:
More than $88.6 billion was spent by providers in 2010 on developing and implementing electronic health records (EHRs), health information exchanges (HIEs) and other initiatives. This surge is a sign of technology’s critical place in health system improvement.
$88.6 billion is a lot of health IT spending and larger than most numbers I’ve seen. Although, most numbers I’ve seen are only the EMR and EHR market and doesn’t include HIE spending and other healthcare IT initiatives. It’s quite clear that the health IT spending is up, and up Big!
Their list of top Health issues isn’t that surprising, except possibly one of them:
Meaningful Use – This has to be topic number one for health IT in 2011. It’s had a trans formative effect on healthcare IT and EMR and EHR as we know them. Pretty much every EHR vendor I’ve talked to basically had to take an entire software development life cycle to meet the meaningful use and certified EHR requirements. This is the dramatic effect of meaningful use on EHR development.
PwC actually focuses on how meaningful use will encourage patient participation in their healthcare or “shared medical decision-making.” To be honest, I’m not sure meaningful use has done much to help this goal, yet(?). Possibly meaningful use stage 2 and meaningful use stage 3 will help to further these goals. MU stage 1 has done little to encourage this. Regardless of the impact of meaningful use, shared medical decision-making is going forward fast and furious.
HIPAA 5010 and ICD-10 – The interesting issue for 5010 and ICD-10 is that they’ve basically been overwhelmed by meaningful use and EHR incentive money. Either of these changes alone would have been a reasonable challenge for a normal year. However, clinical organizations are battling through 5010, ICD-10 and meaningful use all at the same time. Are there any other IT projects going on that don’t involved these three things? I’d say probably very few.
Electronic medical device reporting (eMDR) – I found this point quite interesting. There’s been a lot of movement in 2011 in regards to what constitutes a medical device and who should take care of tracking and collecting the adverse events that occur on these devices. I don’t think we’ve come to a final conclusion on what will be considered a medical device and how we’re going to deal with reporting adverse events, but finally getting electronic reporting of adverse events is a good step in the right direction.
Be sure to read the rest of my Health IT Top 10 as they’re posted.
Tags: 5010 • Adverse Events • Adverse Events Reporting • EHR Market • eMDR • EMR Market • FDA • Health IT Market • Health IT Spending • Health IT Top 10 • HIE • HIPAA 5010 • ICD-10 • Meaningful Use • Meaningful Use Stage 1 • Meaningful Use Stage 2 • Meaningful Use Stage 3 • PwCDecember 13, 2011
The New Healthcare Team: GE & Microsoft
Written by: JohnEditor’s Note: The following is a guest post by Jeremy Bikman. You can read more about the GE and Microsoft Venture on EMR and EHR.

Guest Post: Jeremy Bikman is Chairman at KATALUS Advisors, a strategic consulting firm focused on the healthcare vertical. We help vendors grow, guide hospitals into the future, and advise private equity groups on their investments. Our clients are found in North America, Europe, and Asia. www.KATALUSadvisors.com
Healthcare is being held hostage and it doesn’t even know it.
It is held hostage by burdensome regulations, by archaic practices, and (oddly enough) by technology itself. In this age of Facebook, Twitter, and LinkedIn, an age where anybody with internet access can connect to somebody else on the other side of the globe and share personal information and other data with the click of a mouse, it is impossible that you could visit a hospital in the next town over and they would be able to procure your personal health information as easily or as quickly.
Healthcare, globally and locally, is utterly huge and mind-blowingly complex, and thus absolutely needs the very best innovation of everybody involved. Yet, healthcare technology companies almost universally deliver products which are built on closed-minded concepts. They lock down their platforms, creating real barriers to interoperability, patient data exchange, and actual innovation. This is the present reality within, and across, practically every hospital on earth. The recently announced joint venture between GE and Microsoft offers hope of an alternate reality, one where hospitals can bring together data streams from all over the enterprise, while utilizing new innovations and technology as they see fit, including different best-of-breed sources.
Giving Hospitals a New Choice
There are huge flaws in how technology is delivered in healthcare today, flaws which impact quality of care within a hospital and across the entire industry irrespective of country or region. While the rest of the tech world is moving towards open platforms and collaborative delivery models, healthcare seems to be stuck in the dark ages of single-source solutions which compel all-or-nothing investments to the tune of millions and millions of dollars. Too often those investments fail. But, the more important question is why must hospitals be forced into all-or-nothing decisions in the first place? Why must they choose between integration and functionality, between a single platform, however mediocre, and a best-of-breed mix? We believe those are questions of the antiquated past and that brave new innovation can deliver a new avenue for hospitals who refuse to be painted into a corner. Hospitals shouldn’t have to choose between apples and oranges. They want, and should be able to get, both.
The Basics of the Joint Venture
Selected product lines from both companies’ health groups will be part of the new company. These products were chosen for their specific focus on “empowering connected patient-centric care.”

GE is contributing an interoperable clinical data model and decision support system via Qualibria. GE’s eHealth is an HIE solution in use at a large number of sites in North America. Microsoft is bringing Amalga to the table, which is a data aggregation platform which facilitates interoperability and a host of other advanced capabilities. Vergence and expreSSO come through Microsoft’s acquisition of Sentillion and provide strong context management and single sign-on solutions. The strategy appears to be one of leveraging Microsoft’s platform technology (Amalga) to underpin GE’s clinical depth (Qualibria, eHealth). Additionally, this model will allow hospitals and vendors to integrate best-of-breed 3rd party products into the ecosystem as they see fit. This mix of products and capabilities will enable a true best-of-breed environment emerge while still having the core elements of integration as well. This ecosystem will be powered by the partnership’s own applications and those built by ISVs. No other major vendor offers this unique model and set of abilities, although Allscripts is the one traditional EMR vendor that is building a strategy of accepting of 3rd party solutions.

Tackling the Big Problems
No one is saying that this joint venture is guaranteed to be a resounding success. However, we applaud the visionary model and risks this new team is taking. It looks like they want to address all the big hairy obstacles that every provider organization, region, and nation is facing. Big data? Absolutely. Enterprise analytics and business intelligence? Yes. Clinical decision support? For sure. Population management? You bet. Nobody else in the industry has shown they can tackle these issues even though every hospital is clamoring for this type of model. So why not this joint venture between GE and Microsoft? We say good luck, and more power to them.
The principals of KATALUS Advisors have worked with hundreds of healthcare organizations, vendors, and other consulting firms across the globe. The opinions expressed here are our own and are not intended to promote any specific vendor and do not reflect those of any other organization or individual.
Tags: Amalga • Business Intelligence • Clinical Decision Support • Enterprise Analytics • GE • GE eHealth • HIE • Jeremy Bikman • KATALUS Advisors • Microsoft • Population Management • QualibriaNovember 30, 2011
The Marvels of Technology Missing in Health IT
Written by: John- ARRA
- EHR
- EHR Stimulus
- Electronic Health Record
- Electronic Medical Record
- EMR
- EMR Technology
- HealthCare IT
- HITECH
- Meaningful Use
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I’m currently on the long flight from Las Vegas to New York City. The early flight time and long flight remind me why I prefer to just stay in Las Vegas with the occasional west coast trip, but I digress. In order to not lose an entire day of work on the airplane, I spent far too much for the overpriced internet service on my flight. As I’m traveling at 30,000 feet, it’s amazing to me that I’m connected nearly as good as when I’m sitting at home. Sure, in flight internet has been around for quite a while, but it still amazes me. What will amaze me even more is when the internet is free on every flight. Maybe pharma ads could pay for this too.
While experiencing this amazing connectivity, I can’t help but think of how poor so much of the connectivity in healthcare is. That’s right. We can find a way to offer internet connectivity at 30,000 feet in an aircraft moving hundreds of miles per hour and yet we can’t get connectivity to rural hospitals and other healthcare locations?
Plus, even speaking more broadly, I can access all of my normal services from an airplane, but for some reason I have no way to connect all of my healthcare data together.
Those in the industry realize the problems. The challenge of connecting all of our healthcare data from the various EHR (or maybe in this case EMR is appropriate) data silos is an academic exercise that’s easily accomplished. Hit any of the interoperability showcases at HIMSS or other healthcare IT events and you’ll see EHR software vendors communicating with each other and sharing data. Why then can’t we make this a reality?
The challenges are still the same they’ve been for a long time now: funding and politics.
I still cringe to think of the missed opportunity that ARRA and the HITECH Act could have provided in this regard. Instead of incentivizing use of an EMR, they should have and could have incentivized interoperability of healthcare data. The great part is that you’re not going to start exchanging data in healthcare without an EHR so you’d be getting more EHR software adopted and interoperability. Water under a bridge now I guess, but it keeps eating at me.
My biggest hope now is that a grass roots movement will form that will drive what we should be doing anyway. Everyone knows and understands the benefits to healthcare and the patient of exchanging healthcare data. It’s easy to make the case for how patient care improves and how duplicate costs are avoided. We need more people that are willing to hop on board interoperability of healthcare data cause it’s the right thing to do. Sure, we need to do it in a smart and reasonable way, but the ROI of healthcare data exchange goes well beyond dollars and cents. This ROI can’t be put on a spreadsheet, but instead will help us all sleep better at night.
Are there any movements like this out there? I can’t say I’ve seen any, but I’d love to see one. Then, we’d have a real beacon community that’s set on a hill because it earned and deserved the recognition as opposed to beacon communities paid for by tax payers.
Side Note: I’ll be in NYC this week at the Digital Health Conference and at the mHealth Summit in DC next week. I’m already planning to meet a number of my readers at these events, but I’d love to meet more.
Tags: ARRA • Digital Health Conference • EHR Incentive • EHR Stimulus • EMR Stimulus • Healthcare Data Exchange • Healthcare Data Interoperability • HIE • HITECH • mHealth SummitNovember 22, 2011
Does EHR Choice Matter for ACO’s?
Written by: JohnThere’s a really interesting article on Nextgov that talks about a CSC report that looks at the role of health IT and EHR software in Accountable Care Organizations (ACOs). The most valuable part of the article is this list of items that an EHR must enable or allow to support an ACO:
- Clinical information and point-of-care automation, with integrated ambulatory and inpatient records and a central repository for clinical data.
- Enterprise master data management and integration, with a population management repository, a master person index and a master provider index.
- Tools to enable participation in a health information exchange.
- Patient engagement tools, including secure messaging, e-visits and tele-visits, social media, patient portals and mobile health applications.
- Care management and coordination tools, including referral and request tracking, provider-to-provider communication, medication reconciliation and case- and disease-management applications.
- Performance management tools, including integrated business and clinical intelligence and analytics.
To be honest, as I look through this list of EHR items, I can’t say that any of them really stick out to me as impossible for any EHR to achieve. In fact, I’d say that they’re quite achievable by almost all EHR software vendors.
The only partial fear I have reading through the list is that some of the points depend on an EHR vendor working with other EHR software vendors. In most of the cases, these are large hospital EHR vendors that have often worked in very closed environments.
The reason this is a cause for concern is that even the best EHR software in the world won’t be an effective ACO and won’t meet the above requirements if the large EHR software vendors don’t work with them to connect their system.
Maybe this isn’t something we should be too concerned about since the hospital client will be motivated to get their EHR vendor to work with the other even small EHR vendors in order to make the ACO happen and get access to the extra reimbursement. However, my gut tells me that this won’t be the case and there will be stories where EHR software is basically shut out of the ACO based on the large EHR vendors decision to not work with them.
Tags: Accountable Care Organizations • ACO • ACOs • e-Visits • EHR Items • EHR Software • EMR Software • HIE • Master Patient Index • Master Person Index • Medication Reconcilliation • Mobile Health • Patient Portals • Point-of-Care Automation • Population Management Repository • Tele-visitsNovember 18, 2011
The Arizona REC and HIE at EHR Summit
Written by: John- ARRA
- EHR
- EHR Stimulus
- Electronic Health Record
- Electronic Medical Record
- EMR
- EMR Implementation
- EMR Selection
- HealthCare IT
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While attending the EHR Summit by HBMA, I got the chance to learn more about the AZ REC and HIE. Here are some tweets about the things they said that worth noting with my own comments:
Arizona REC
AZ REC had trouble getting vendors to take their free EHR interns. #EHRSummit11
This was pretty interesting since they said that doctors were more than willing to take on their student interns, but vendors were reticent to take them on. I do love the education program that the AZ REC put together. Internships like this are valuable.
Biggest complaint the HIT students had was access to actual EHR software. AZ REC created a EHR software lab to solve it. #EHRSummit11
This is a really common complaint by the RECs. In fact, I just helped a REC get access to some EHR software to solve this problem. It’s amazing to me that more EHR vendors aren’t happy to provide their software for these education programs.
AZ REC has a list serv of 2500 doctors and a list for vendors. See: http://www.arizonarec.org/? #EHRSummit11
I found it interesting that they had a doctor list and a vendor list. Makes sense.
AZ REC looking at optimizing health IT for ACO’s to be sustainable. I think this will be a common strategy. #EHRSummit11
The idea of REC sustainability is an important one. I think many are looking towards the ACO requirements as one pathway to sustainability. Of course, how stable are ACO’s? One thing seems certain, the relationships the RECs create with doctors could be leveraged for good if done right.
Arizona HIE
The case for the benefits of good information from something like a HIE is easy. The problem is making it actually happen. #EHRSummit11
This was my gut response when the AZ HIE was talking about the benefits of having the information an HIE provides. I don’t think I’ve heard anyone say that exchanging information would be a bad thing and produce worse clinical outcomes. Sure, they want to ensure privacy of the data when it’s done, but the benefits of having the best information are completely apparent.
HINAz (AZ HIE) didn’t depend on grants to create the HIE. They focused on the benefits of the HIE to users. #EHRSummit11
This seems like something that’s a bit unique to AZ. Most HIE’s are so focused on the grant funding. In this sense, I think that this might give the AZ HIE a chance to be successful. Plus, I loved that they did actual research into which users benefited from the HIE.
AZ HIE, Hospitals pay 50% of costs, Plans pay 50% of costs. Physicians pay nominal fee to participate (cause nominal benefit). #EHRSummit11
This is where the real fun begins. The hospitals and plans are paying for the HIE since the AZ HIE found that they’re the ones that would benefit from it. They found that doctors received nominal benefits from using the HIE and so they shouldn’t be charged to use it. Of course, the other beneficiaries not mentioned here is the benefit to the patients. I’m sure hospitals and plans will pass the cost on to patients, so I guess that works out in the end.
Tags: AZ HIE • AZ REC • EHR Conference • EHR Implementation • EHR Selection • EHR Summit • EMR Conference • HBMA • Health Information Exchange • HIE • Phoenix • REC • Regional Extension CenterNovember 13, 2011
EHR and Encryption, Down Computers and EHR, and State Health Exchanges Might Not Be Sustainable
Written by: John- EHR
- Electronic Health Record
- Electronic Medical Record
- EMR
- EMR Security
- HealthCare IT
- Healthcare Social Media
- HIE
- RHIO
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Time again for our weekend EHR Twitter round up. Let the fun begin.
@ahier – Brian Ahier
#EHR’s need encryption says @HealthPrivacy to Senate panel bitly.com/rTnx6s
Is there an EHR software that doesn’t use encryption? Is there a doctor’s office that’s paying for an EHR that doesn’t use encryption? Certainly not all EHR encryption implementations are created equal. In fact, I wish that things like encrypting data were part of an EHR certification. Why? Cause that’s something you can actually certify in a meaningful manner.
@drmikesevilla – Mike Sevilla, MD
RT @SeattleMamaDoc Computers all down in the exam rooms today. One major limitation of an EMR/EHR (dependence on a computer)
Definitely is one challenge with an EMR/EHR. I wonder how many patients were seen without the chart, because it couldn’t be found quickly. There are always pros and cons to IT. It does highlight the need to have a well thought out plan for how you’re going to care for patients when your EHR is down.
@iWatch – iWatch News
State health exchanges might not be sustainable after $548M in stimulus money runs out: bit.ly/t9QfSl #HIE #EHR
Wait, so changing the name of them from RHIO to HIE didn’t solve any of the problems with these exchanges? Oh yes, I forgot to mention the extra $548 million to help solve the problems. I think this best illustrates that money isn’t the issue or at least there are more issues with HIE than just the money.
Tags: EHR Encryption • EHR Security • EMR Encryption • EMR Security • Health Information Exchanges • Health Privacy • HIE • iWatch • Mike Sevilla • RHIOSeptember 15, 2011
Guest Post: Overcoming EMR Integration Challenges
Written by: John- Clinical Decision Support
- EHR
- Electronic Health Record
- Electronic Medical Record
- EMR
- EMR Technology
- HealthCare IT
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Dan Neuwirth is the CEO of MedCPU, provider of the innovative MedCPUAdvisor™ platform: with applications for decision support for clinical guidelines, Meaningful Use, and care pathways, that captures the complete clinical picture in real time, including narrative text and structured data to deliver the most accurate clinical and compliance guidance.
There’s no question that healthcare needs to adopt new technology that makes us more effective and efficient and curbs costs, like Electronic Medical Records (EMR) solutions and Clinical Decision Support (CDS) systems. In today’s world, providers of all sizes continue to find it challenging to integrate existing HIT systems with EMRs for a variety of reasons. As our industry evolves, technology solutions need to be smarter and empower seamless integration.
EMR and HIPAA guest author Susan White covers in depth how a lack of connectivity standards affects EMR integration. There are no mandated standards for EMR vendors to follow, making it hard to coordinate data sharing between medical devices and other systems (including from one EMR to another), even at the same facility. As those systems operate in disparate fashions, critical clinical information is often lost or stuck in silos. Most importantly, the information is not where clinicians need it most–at their fingertips, in an exam room, with a patient.
This lack of data sharing is a pervasive concern. One Markle report finds that roughly 80 percent of both consumers and physicians demand that hospitals and doctors be required to share information that improves coordination of care, cuts unnecessary costs, and reduces medical errors.
In 2010, more than $88 Billion were spent on developing and implementing EHRs, health information exchanges (HIEs) and other health IT initiatives. When you consider that the average 10-physician practice spends more than $137,000 per year on prior authorizations and pharmacy callbacks alone, you’ll have to agree that the lack of data integration and sharing get very costly. And although I agree with John Halamka, who recently wrote these challenges exist because healthcare is inherently more complicated than other industries, I am a strong believer that a lot of them can be overcome by the use of smart technology.
We need smart, flexible solutions, which capitalize on existing technologies and require minimal integration. Technologies that employ advanced screen extraction, for example, empower several important improvements in the clinical decision support space such as the capturing and analysis of both free and structured text. A lot of time such solutions are rendered ineffective as they either lack compatibility with leading EMR systems or are too hard to integrate.
As the industry evolves, developing robust protocols for capturing both structured and unstructured data along with standards for data integration and sharing will become increasingly important. With all the data points created on patients every day, we will need a consistent, secure, and reliable way to capture and share patient data among all systems and healthcare providers. What is your experience? What are top data capturing and integration challenges faced by your organization? Looking forward to continuing the dialog and hearing your feedback.
Tags: CDS • Clinical Decision Support • Dan Neuwirth • EHR Standards • EMR Integration • EMR Standards • Health IT • Healthcare Data Integration • HIE • John Halamka • Markle • MedCPU • MedCPUAdvisor • Susan WhiteJuly 27, 2011
EMR and Meaningful Use Books
Written by: John- ARRA
- EHR
- EHR Stimulus
- Electronic Health Record
- Electronic Medical Record
- EMR
- HealthCare IT
- HIE
- HITECH
- Meaningful Use
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I must admit that I’m not much of a book guy. Especially since there’s so much free information available on the internet about just about any subject you could want. However, I’ve been quite intrigued by the number of healthcare IT related books that I’ve seen coming out of late. Here’s a quick roundup of some of the ones I’ve seen.
Getting to Meaningful Use and Beyond: A Guide for IT Staff in Health Care by Fred Trotter and David Uhlman – I’ve been a big fan of Fred Trotter for a while. So, I’m glad he’s working on this book. Turns out the book isn’t even published, but in Fred Trotter open source style fashion, the book is available for free online right now. Of course, they’re hoping you’ll provide feedback.
The HITECH Act Made Easy: A Simple Guide to the Federal EHR Incentive Programs – I had this book sent to me. It’s a short book which I think is good. It tries to tackle not only the details of the Medicaid and Medicare stimulus program, but also has a number of sections on EHR selection and implementation as well. I love it’s question format where many of the chapters are a question and the chapter offers the answer.
Health Information Exchange Formation Guide: The Authoritative Guide for Planning and Forming an HIE in Your State, Region or Community – I haven’t really had a chance to dig into this book yet. It’s brought to you by HIMSS. It’s a pretty thick book which I think describes well the challenge that is forming an HIE. Without reading the book, I’m a little torn just by the subtitle of the book, “The Authoritative Guide for Planning and Forming an HIE in your State, Region or Community.” I guess it’s hard for me to imagine it being the “authoritative guide” when I think we’re still trying to figure out the right HIE business model. I don’t think we’ve found it yet. I guess I should read the book to find out.
Jim Tate’s EHR Incentive Roadmap – Ok, this is an e-Book, but I think it’s as good a value as any hard cover book. So, it’s worth mentioning. I wrote a whole post on Jim Tate’s EHR Incentive book before.
Any other books about EMR, Meaningful Use, and/or healthcare IT that are out that we should know about?
UPDATE: User EHR and Meaningful Use Recommendations from the comments below:
Electronic Health Records For Dummies – Recommended by Nate Osit
Electronic Health Records: Transforming Your Medical Practice, second edition – “This is a book from MGMA and was recommended to me by a coordinator from the REC (Ohio) that I have been shadowing.” – Mary Ellen Weber
April 5, 2011
Healthcare IT an Important Component of New ACO Program
Written by: JohnJohn’s Note: The following is a guest post by Mark Segal talking about the recently announced ACO program and it’s relationship to EHR, meaningful use, and healthcare IT. I also love the insider look at rule making.

The long-awaited proposed rule on Medicare’s Shared Savings Program (SSP)/Accountable Care Organization (ACO) program is out. These 429 pages outline how the Administration plans to transform U.S. health care delivery from fee-for-service to a value-based emphasis on accountability for quality and efficiency of care provided for populations. Following a final rule later this year, the program is to start January 1, 2012, with additional January 1 annual starts by ACOs, and a special optional start possible for July 1, 2012 given the tight timing this year.
CMS solicits comments on program design areas. The final rule will certainly track the proposed rule in key aspects, but there could be important changes based on comments – although revisions must be within the scope of proposed rule options because CMS cannot add new concepts in the final rule.
Care coordination, patient centeredness and evidence-based medicine are major priorities. As expected, therefore, health information technology (HIT) and electronic health records (EHRs) will be central to ACO success. In some cases, HIT is cited explicitly; for example at least 50 percent of ACO primary care physicians must be meaningful users of EHRs in an ACO’s second year.
In other cases, CMS, focusing on patient engagement, care coordination, and care transitions, highlights HIT capabilities an ACO should address in its SSP application. For example, CMS calls out using EHRs and health information exchange (HIE) to send care summaries at care transitions. In addition, CMS flags HIT areas like telehealth and remote monitoring, evidence-based medicine, and measuring physician performance across practices and using measurements to improve care and service. Also, HIT will be central to the need to report on and achieve desired levels (after year one) of many of the 65 quality measures. For example, HIT could help reduce levels of healthcare-acquired conditions.
CMS’s HIT approach is non-prescriptive. An ACO must address, in its application, how it would address such requirements as care coordination (including use of HIT) but CMS does not dictate technology tools or specific features. Fundamentally, CMS is outcomes-focused, looking at up-front plans and then focusing on ACO ability to meet quality metrics and overall efficiency goals. Such flexibility contrasts with meaningful use, which is highly prescriptive. ACOs will have flexibility to design and deploy their HIT strategies. Overall, such flexibility should also be considered as the HIT Policy Committee, ONC and CMS consider requirements for Stage 2 of meaningful use, especially for newer areas of HIT use.
Finally, of concern, and relevant also to the need for multi-year meaningful use roadmaps, CMS reserves the right to annually change the SSP during three-year ACO agreements. Although CMS excludes some areas from such annual changes, this uncertainty is worrisome given the substantial investments and organizational changes that must be made by ACOs. Three years is a blink of the eye in care transformation; ACOs need regulatory stability and predictability to plan and invest with confidence and to succeed at the change management that will underlie ACO success.
So read carefully and submit timely comments!
Mark Segal is the vice president of government and industry affairs at GE Healthcare IT.
Tags: Accountable Care Organization • ACO • ACO Final Rule • ACO Proposed Rule • CMS • GE Healthcare • HIE • Mark Segal • Meaningful Use • Shaared Savings Program • SSP


