John’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.