CMS Sets the I.T. Bar Very High for Medicare ACOs

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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 "may" involve a range of strategies which "may" include:

* Use of predictive modeling to anticipate likely care needs,

* Remote monitoring of patients,

* Telehealth,

* Comparative benchmarking, and

* "The establishment and use of health information technology, including electronic health records and an electronic health information exchange to enable the provision of a beneficiary's summary of care record during transitions of care both within and outside of the ACO," according to the proposed rule, issued today and available here.

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."

Other requirements that could or will involve specific I.T. capabilities include:

* Having a process in place for communicating clinical knowledge/evidence-based medicine to beneficiaries in a way that is 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.

"An ACO will be innovative in the service of the three-part aim of better care for individuals, better health for populations, and lower growth in expenditures," according to the proposed rule. "It will draw upon the best, most advanced models of care, using modern technologies, including telehealth and electronic health records, and other tools to continually reinvent care in the modern age. It will monitor and compare its performance to other ACOs, identify and examine new processes for care improvement, and adopt those approaches that are demonstrated to be effective."

Finally, there's one more big I.T. requirement: CMS is 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 in the rule indicates some fudging is possible. "For instance, 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 way, 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."

Health Data Management at 1:00 p.m. Eastern Time on April 5 will host a Web seminar with health law attorneys Bruce Fried and Robert Slavkin examining provisions of the Shared Savings Program proposed rule. Click here for more information.

--Joseph Goedert


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