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The information technology capabilities that accountable care organizations will need under the proposed rule establishing a Medicare Shared Savings Program could go far beyond what's necessary to prove Stage 1 electronic health records meaningful use. And the Shared Savings Program starts Jan. 1, 2012, during Stage 1 of meaningful use.

Compliance with coordination of care requirements in the proposed rule, released March 31, involve a range of strategies that may include: use of predictive modeling to anticipate likely care needs, remote monitoring of patients, telehealth, and comparative benchmarking, among others.

Further, an ACO would be expected to develop and implement evidence-based best practices. "The ACO would have an infrastructure, such as information technology, that enables the ACO to collect and evaluate data and provide feedback to the ACO providers/suppliers across the entire organization, including providing information to influence care at the point of care via, for example, shared clinical decision support, feedback from patient experience of care surveys, or other internal or external quality and utilization assessments," according to the proposed rule. Other requirements that could or will involve specific I.T. capabilities include:

* Having a process for communicating clinical knowledge/evidence-based medicine to beneficiaries in a way understandable to them,

* Reaching out to patients with treatment reminders and advice to staying healthy, and

* Collecting, evaluating and using data on health care processes and outcomes to measure achievements over time for beneficiaries and communities, and to use the data to improve care delivery and outcomes.

Finally, there's one more big I.T. requirement: CMS in the rule proposes that at least 50 percent of an ACO's primary care physicians be meaningful EHR users by the start of the second year of the Shared Savings Program to continue participation in the program.

The Jan. 1, 2012, start date is prescribed in the health care reform law. However, CMS indicates some fudging is possible. "We could allow ACOs to apply on a 'rolling' basis in which applications are accepted and evaluated any time of year and the ACO's agreement period would begin after a determination that the eligibility requirements had been met. In this ay, applicants could apply throughout the course of the year as they become ready and we could review and approve applications and begin performance periods on a rolling basis," the proposed rule states.