The College of Healthcare Information Management Executives is asking the Centers for Medicare & Medicaid Services to re-examine proposals that would restrict the flow of information and create significant pressure on accountable care organizations.
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. CHIME challenged 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 CHIME member Bill Spooner, senior vice president and CIO at San Diego-based Sharp HealthCare, in a statement. “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 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’s comment letter noted.
“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 Dallas and chair of CHIME’s Policy Steering Committee, in a statement. “As hospitals look to participate, they will depend on CIOs to understand how ACOs meet the data collection and reporting requirements. We urged CMS in our comments to avoid prescribing technology, such as requiring meaningful use, instead allowing ACOs to make determinations based off their business needs and patient populations.”
Ann Arbor, Mich.-based CHIME filed its comments this week with CMS in response to its Notice of Proposed Rulemaking for governing ACOs. To read CHIME’s full comments on the ACO rule, click here.
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