Though pleased the Accountable Care Organization (ACO) Notice of Proposed Rulemaking isn’t overly prescriptive as to how entities must use health information technology, the HIMSS Electronic Health Record Association (EHRA) does want the final rule to explicitly promote bi-directional, standards-based health information exchange and interoperability, according to Leigh Burchell, chair of the organization’s Public Policy Leadership Work Group.
In describing EHRA’s comment letter to CMS on the subject, Burchell, VP of Government Affairs and Public Policy for Allscripts, said the group also addressed the program’s risk/reward ratio.
“We have heard the formulation of the program — both in terms of potential shared savings and the timing of those savings, which is delayed and, under certain circumstances, withheld — is not something that is inciting interest in participation,” she explained. “One example would be the program is fairly focused on the ambulatory environment and primary care, but the capital required to invest in getting an ACO up and running, which includes potential technology investments, is significant. For the savings distribution to be a year or two later is not feasible for those who would otherwise be interested.”
EHRA, Burchell said, also made clear to CMS that the Department of Health and Human Services would do well to harmonize its many quality improvement programs.
“When the final rules comes out, and even in advance of that, the software development community is pretty quickly at work trying to identify what new functionality is going to be needed in our products, where preexisting functionality can be maximized versus where something net new will be required, and very quickly following that dissemination of information from CMS or ONC we all begin immediately working to develop against that criteria. Often, the direction for clinical quality measures historically has not been as clear as it might be, which can cause the need for double checking with CMS to ensure clarity so we do the appropriate work. Then, of course, quality assurance steps must be taken and the products disseminated to clients so they can learn how to use the new functionality,” she said.
“In the current environment, there are a multitude of programs that contain quality measurement requirements but are not aligned, and you can see that from the e-prescribing program to Meaningful Use and the PQRS (Physician Quality Reporting System) program — hospital reporting does not align with Meaningful Use proposals under the ACO rule, and there’s more to come. What we have requested of CMS — and the provider community has echoed — is that we see an effort across the organizations in HHS to align what they require. This would minimize the need for software developers to create an entirely new set of measures and allow providers to avoid administratively burdensome processes in complying with the programs.”
The Association also expressed strong support for CMS’s decision to exclude eligible professional Meaningful Use incentive payments from ACO shared savings calculations, and proposed extending this exclusion to eligible hospitals as well, stating, “Such exclusions would avoid penalizing professionals and hospitals for having previously earned incentive payments.”