Groups Weigh In on Health IT Provisions of CMS’ ACO Program

February 9, 2015 in News

Health care organizations are urging CMS to provide more real-time data to accountable care organizations participating in the Medicare Shared Savings Program, Health Data Management reports (Goedert, Health Data Management, 2/9).

The letters came in response to a proposed rule released by CMS in December 2014 that includes provisions designed to increase health IT use among MSSP participants. The comment period on the proposed rule closed on Friday (iHealthBeat, 12/2/14).

NAACOS Letter

The National Association of ACOs in a letter urged CMS to make more patient data available to ACOs and to provide that information in a timelier manner.

In its letter, NAACOS wrote that it “appreciate[s] CMS’ proposal to include health status and utilization rates in aggregate data reports, as it will make the data more meaningful and actionable.” The group provided suggestions of “additional beneficiary identifiable data elements to include in the quarterly reports” to “enhance [the] meaningfulness” of the data reports, including:

  • The initial date of beneficiaries’ Medicare eligibility (NAACOS letter, 2/6);
  • The date of changes in beneficiaries’ eligibility status;
  • The date of changes in beneficiaries’ health insurance claim number and an indicator identifying any such changes;
  • Aggregate data on substance misuse claims expenditures;
  • An indicator of beneficiaries’ hospice/institutional status for each beneficiary included on every attribution report to help ACOs track domiciled patients they might not be aware of; and
  • Opt-out data to beneficiaries’ attribution file to help ensure beneficiaries are not lost during the data reporting process.

In addition, NAACOS urged CMS to provide real-time data when beneficiaries are undergoing eligibility checks at hospitals, emergency departments and post-acute care providers. It wrote that “since CMS currently receives all eligibility checks from” such providers, the agency “could make [these] data available to ACOs.” NAACOS noted that “Medicare patients have the right to seek care from any provider who accepts Medicare,” whether or not that provider is in an ACO. The organization said that access to such real-time data could allow ACOs to better coordinate care with outside providers or redirect beneficiaries to other providers.

Further, NAACOS expressed support for CMS to allow beneficiaries to opt out of data sharing by calling 1-800-Medicare. However, the group argued that beneficiaries opting out “will effectively eliminate the ability for an ACO to coordinate [their] care” and that “ACOs should not be held financially responsible for these beneficiaries” during the financial reconciliation process (Health Data Management, 2/9).

AHA Letter

The American Hospital Association in a separate letter to CMS also called on the agency to provide ACOs with more real-time data.

AHA Executive Vice President Rick Pollack wrote that his group “support[s] CMS’ proposal to increase the data it provides to ACO.” However, he added that AHA “continue[s] to stress the importance of providing real-time data to help ACOs better manage and coordinate care and strongly urge[s] CMS to develop a ‘rapid response’ system to provide such data to ACOs.”

Specifically, Pollack wrote that the CMS data provided to ACOs “are often six to nine months delayed” and that “[i]t is critical for an ACO to know its aligned beneficiaries on a monthly, not quarterly, basis.” He added that AHA’s “MSSP ACO-participating hospitals have stressed that the data provided are inadequate, incomplete and often erroneous” and that ACOs need more utilization data to improve care quality and costs.

AHA also called on CMS to remove assigned beneficiaries who opt out of data sharing from consideration “during the financial reconciliation process since an ACO will be unable to coordinate effectively the care of these patients and should not be held financially accountable for them” (Murphy, EHR Intelligence, 2/6).

Health IT Now Letter

In a separate letter, Health IT Now wrote that it “is pleased to see CMS emphasize the value of health IT” within ACOs.

The group wrote that it supports the proposed rule’s requirement that ACOs “include plans for improving care coordination by developing, encouraging and using enabling technologies and electronic health records.”

In addition, Health IT Now wrote that it “supports waiving for ACOs the restrictions placed on reimbursement for telehealth services under traditional Medicare.” However, it argued that “telehealth services should not by default be reimbursed at the same level as in-person services,” adding, “We believe that the use of technology in health care can lower costs, and this should be taken into consideration when developing reimbursement rates for services provided via telehealth” (Health IT Now letter, 2/6).

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