When the Centers for Medicare and Medicaid Services released the proposed rule for accountable care organizations at the end of March, health information technology was recognized and emphasized as a central component. Technological aspects of the proposed rule are closely aligned to the Electronic Health Records Implementation Program and HITECH. HIT will play a large role in a number of processes or concepts of an ACO.
Requirements on meaningful users of EHR
By the start of the second ACO performance year, at least 50 percent of an ACO’s primary-care physicians must be meaningful users of certified EHRs. Achieving meaningful use is an important step in HIT implementation, but providers must first overcome initial barriers that may hinder their attainment of meaningful use. Healthcare providers have demonstrated a need for assistance in overcoming barriers to HIT, such as tight financial resources to buy EHRs and a lack of technical expertise to select the proper system.
Evidence-based medicine requires HIT infrastructure
ACOs are required to develop and implement evidence-based medical practices and processes to coordinate care, requiring an infrastructure that allows the ACO to collect data, evaluate it and provide feedback to participants. One technological infrastructure that will perform these tasks is an integrated EHR system with clinical decision support. Furthermore, CMS has required ACOs coordinate care through technologies such as predictive modeling, remote monitoring, telehealth and electronic health information exchanges.
Physician quality reporting improved with EHR adoption
ACOs must meet quality performance standards to qualify for shared savings under the proposed rule. The 65 quality measures issued by CMS can be divided into give domains: patient or caregiver experience (7 measures), care coordination (16 measures), patient safety (2 measures), preventive health (9 measures) and at-risk population (31 measures).
Data may still be submitted through existing reporting programs — like the Physician Quality Reporting System, the Centers for Disease Control and Prevention National Healthcare Safety Network — but CMS has noted increased alignment with ACO measure specifications and EHR quality measure specifications, proposing a system that necessitates increased EHR technology adoption.
Privacy concerns and HIPAA compliance
The Department of Health and Human Services has proposed three types of medical information be made available to ACO participants: (a) aggregated data on beneficiary use of services, (b) identification of historically assigned beneficiaries, such as name, date of birth, gender and Medicare ID and (c) Medicare parts A, B and D claims data.
A significant portion of the information ACOs are required to share qualifies as protected health information under HIPAA. In compliance with HIPAA, ACO participants may exchange protected health information under three conditions of healthcare operations: (a) both covered entities have or had a relationship with the subject of the PHI to be shared, (b) the PHI pertains to that shared relationship and (c) the recipient will use the PHI for a “healthcare operations” function, which includes population-based activities, protocol development, case management and care coordination.