With ACO Final Rules, CMS is NOT relaxing EHR push anytime soon

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With the release of the Final Rules for ACOs last week, we learned that ACOs are no longer required to have half of primary care physicians meeting Meaningful Use criteria.  So does this mean that the government is slowing momentum with the digitization of healthcare?  Absolutely not.  By removing the requirement, CMS was simply eliminating redundancies in policy, incentives, and enforcement. 

The Final Rules for ACOs strengthen the need for robust EHRs, now more than ever, in four important ways:

1)    More incentives.  $170M in “advance payments” will be available for rural docs and hospitals to get help accelerating EHRs and staffing to turbo-charge accountable care.

2)    Digital data collection. Providers must report on 33 performance measures – and obviously those with digital records will have an edge. Of the 33 measures, 7 are collected via patient survey, 3 are calculated via claims, 1 is calculated from EHR Incentive Program data, and 22 are collected via the Group Practice Reporting Option (GPRO) web interface.  “The GPRO web interface, which represents a first step in EHR-based reporting, which we believe is more efficient and cost-effective, since it will allow ACOs to upload data directly from their EHR systems,” according to CMS’s Final Rule summary.   

3)    Double points for EHR. EHR is now one of 33 quality performance measures, and those providers having it will be given double points – helping an ACO boost overall performance scores if they are falling short in other categories.

4)    Surviving audits.  EMR accuracy will be critical to ensure savings targets are met, and CMS will conduct random audits.  “Failure to report quality measure data accurately, completely and timely (or to timely correct such data) might subject the ACO to termination or other sanctions,” according the Final Rules.

 In a nutshell, everything that passed in 2009 with the American Recovery and Reinvestment Act under the HITECH provision, where $19 Billion was made available for healthcare IT incentives for docs and hospitals to push forward with EMR, sticks.  With the ACO rules, CMS saw no need to double dip.  As passed in 2009, docs meeting Stage 1 Meaningful Use criteria by the deadlines can qualify for $44-64K in Medicare and Medicaid incentives; and hospitals can qualify for $2M plus more based on fancy math based for discharge volume. 

 Stage 1: Meaningful Use criteria for docs and hospitals include:

• Capture and code basic health information. 
• Use health information to track clinical conditions and coordinate care
• Report clinical quality measures and public health data

Stage 2:  More of #1 plus clinical Decision Support.  Stage 2 Proposed Rules are out for public comment.

Stage 3:  More of #1 and 2 plus improving outcomes.

Providers that do not implement an EHR by 2015 will be penalized with Medicare reimbursement cuts.  Adoption has been sluggish.  According to an article released today by Information Week “13% of the respondents' hospitals had received government incentive payments by Sept. 30. Four percent of the facilities received the incentives through Medicare, and 9 percent, through Medicaid.” 

As a fully digital provider, you’ll have an attractive edge as you audition for a starring role in an ACO.   The Final Rules for ACOs provide no signal whatsoever that the government is slowing down the push for digital healthcare – to drive quality, lower costs, and reduce hospital readmissions.