Ann Arbor, Mich.-based CHIME filed its comments today with CMS in response to its Notice of Proposed Rulemaking for governing ACOs. Comments for the proposed rule are due by June 6. According to CMS, ACOs will test a new delivery healthcare model meant to achieve better care for individuals and improved care for populations, while reducing the growth of healthcare expenditures.
CHIME’s comments cover proposed rules that would govern the capabilities of healthcare organizations to share data, and requirements that would create linkages between ACO rules, the meaningful use of electronic health records, and health information exchange.
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.
Of great concern to CHIME is a proposed rule by CMS that gives patients enrolled in an ACO the ability to restrict access to their health information. “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 CHIME comments said. “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.
“Technology will no doubt play a prominent role in the success of any ACO. The amount of data and information exchange between ACO participants will be enormous,” said Bill Spooner, senior vice president and CIO at San Diego-based Sharp HealthCare. “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’s Shared Savings Program,” said Pam McNutt, senior vice president and CIO of Methodist Health System in
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 Dallas-based Baylor Health Care System and chair 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 urges CMS to scale back expectations for the use of health information exchange (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 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.”
To read CHIME’s full comments on the ACO rule, please visit: http://www.cio-chime.org/advocacy/CHIME_comments_on_CMS_NPRM_for_ACOs.pdf
The College of Healthcare Information Management Executives (CHIME) is an executive organization dedicated to serving chief information officers and other senior healthcare IT leaders. With more than 1,400 CIO members and over 70 healthcare IT vendors and professional services firms, CHIME provides a highly interactive, trusted environment enabling senior professional and industry leaders to collaborate; exchange best practices; address professional development needs; and advocate the effective use of information management to improve the health and healthcare in the communities they serve. For more information, please visit www.cio-chime.org.