CHIME pans proposed ACO rules
The Centers for Medicare & Medicaid Services (CMS) should go back to the accountable care organization (ACO) drawing board, according to the College of Healthcare Information Management Executives (CHIME).
In a letter to CMS Administrator Don Berwick, MD, the Ann Arbor, Mich.-based health IT organization requested that CMS re-examine the proposed rules that it stated would restrict the flow of information and create significant pressures on ACOs.
“CHIME believes that further policy examination is needed in several key areas. Specifically, proposals regarding data sharing provisions, meaningful use alignment and assumptions about health information exchange (HIE) capacities have the potential to undermine CMS goals and ACO effectiveness,” stated the letter, which was prepared in response to CMS' notice of proposed rulemaking (NPRM) for governing ACOs.
ACOs, as proposed by CMS, will test a new healthcare delivery model meant to achieve better care for individuals and improved care for populations, while reducing the growth of healthcare expenditures.
A proposed rule by CMS that would give patients enrolled in an ACO the ability to restrict access to their health information is of great concern, according to CHIME. “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,” the letter states. “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 recommended 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.
The proposed ACO rule attempts to encourage the meaningful use of EHRs, according to CHIME, but the organization took issue with a requirement that stipulates that 50 percent of an ACO’s primary care physicians (PCPs) meet all meaningful use 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,” the letter stated.
The proposed use of 65 performance measures in the first year of the ACO program is excessive, stated CHIME. “[T]oo many measures are being proposed for the start of the Medicare Shared Savings Program, and we urge CMS to reconsider,” the organization said. “[We believe] CMS is underestimating the difficulty of the proposed data validation process.”
CHIME recommended 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.
Finally, CHIME urged CMS to scale back expectations for the use of HIE 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 HIE and technology adoption that may be too aggressive for deployments in January 2012 and not yet ready for effective deployment,” CHIME concluded. “We believe this issue could be better handled by allowing ACOs to determine their own technology needs, given their market and their patient population.”
Comments on the proposed rule are due by June 6.
In a letter to CMS Administrator Don Berwick, MD, the Ann Arbor, Mich.-based health IT organization requested that CMS re-examine the proposed rules that it stated would restrict the flow of information and create significant pressures on ACOs.
“CHIME believes that further policy examination is needed in several key areas. Specifically, proposals regarding data sharing provisions, meaningful use alignment and assumptions about health information exchange (HIE) capacities have the potential to undermine CMS goals and ACO effectiveness,” stated the letter, which was prepared in response to CMS' notice of proposed rulemaking (NPRM) for governing ACOs.
ACOs, as proposed by CMS, will test a new healthcare delivery model meant to achieve better care for individuals and improved care for populations, while reducing the growth of healthcare expenditures.
A proposed rule by CMS that would give patients enrolled in an ACO the ability to restrict access to their health information is of great concern, according to CHIME. “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,” the letter states. “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 recommended 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.
The proposed ACO rule attempts to encourage the meaningful use of EHRs, according to CHIME, but the organization took issue with a requirement that stipulates that 50 percent of an ACO’s primary care physicians (PCPs) meet all meaningful use 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,” the letter stated.
The proposed use of 65 performance measures in the first year of the ACO program is excessive, stated CHIME. “[T]oo many measures are being proposed for the start of the Medicare Shared Savings Program, and we urge CMS to reconsider,” the organization said. “[We believe] CMS is underestimating the difficulty of the proposed data validation process.”
CHIME recommended 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.
Finally, CHIME urged CMS to scale back expectations for the use of HIE 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 HIE and technology adoption that may be too aggressive for deployments in January 2012 and not yet ready for effective deployment,” CHIME concluded. “We believe this issue could be better handled by allowing ACOs to determine their own technology needs, given their market and their patient population.”
Comments on the proposed rule are due by June 6.