Commentary on CMS' Medicare Shared Savings Program: Accountable Care Organizations notice of proposed rulemaking (NPRM) by Justin Barnes, chairman emeritus, Electronic Health Record Association (EHR Association) and vice president of marketing, corporate development and government affairs, Greenway Medical Technologies.

Anticipated for publication as far back as December, and with a prescribed start date of Jan. 1, 2012, what is now the most far-reaching, and maybe the most hopeful, healthcare delivery and cost-containment proposal in decades arrived on the eve of April Fools' Day.

But it's no joke that among some 47 million U.S. Medicare patients, one in five who are hospitalized are readmitted within 30 days, and most suffer from more than one chronic ailment, contributing to annual healthcare costs approaching $2.5 trillion.

The proposed shared savings program forming accountable care organizations (ACOs) seeks voluntary three-year commitments from primary care and/or multi-specialty physician groups, hospitals, home health services, rehabilitation centers and other institutions to form communities of health committed to serving at least 5,000 patients for an initial three-year period.

Essentially, the ACO model takes a logical approach by building upon the physician quality reporting system (PQRS), hospital inpatient quality reporting (IQR) and the meaningful-use program — all established initiatives to improve patient care through quality reporting, namely the electronic health record (EHR). It also proposes establishing 65 quality measures, grouped in five categories, that align with meaningful use.

The proposal also offers risk and reward choices so that ACO participants can find their own levels of confidence, allowing care providers already using EHRs at the point of care to take on greater reward and risk throughout the three-year commitment. Or they can take on smaller rewards in years one and two, and then assume more risk of below-benchmark penalties only in year three.

Though ambitious in its current scope, the proposal hints at the ability for rolling start dates beginning in 2012, and initially it would allow for reporting of quality measures, followed by proof of performance, much like what transpired with the original meaningful-use proposal. I expect that the provision that 50 percent of primary care ACO providers be meaningful EHR users by year two will incur much commentary between now and June 6.
I hope that providers closely study the success their peers have had with PQRS and meaningful use to date. Shared savings is a quality reporting system with a delivery, reporting, coordination and health IT structure that is already in place and has been shown to succeed in several arenas.

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