Archive for the ‘CMS’ Category

Cerner is embarking on a journey of transformation. That transformation, if successful, will culminate in Cerner becoming more than a health IT company to becoming a health company. They’ve tested much of this strategy internally with onsite campus clinics, health and wellness challenges, the creation of rich consumer/patient engagement tools, heck, they have even created their own third party administrator (TPA) as Cerner is self-insured. The company wishes to take these lessons learned, these solutions that have been developed, to transform their company into a health company to address not only the patient experience in a clinical setting, but the patient/consumer health experience throughout the community.

This is all a part of Cerner’s Healthe Intent strategy, a strategy we received a deep dive in during our recent attendance to the Cerner User Conference in early October. Healthe Intent is a big, grand, bold vision in an industry where there seems to be a dearth of such visions. Whether or not Cerner is successful, Healthe Intent certainly has its fair share of challenges, rests more with Cerner than any other outside force.

In the October Monthly Update, which is exclusive to Chilmark Advisory Service (CAS) subscribers, we provided subscribers a deep dive into Cerner’s Healthe Intent strategy and what its implications are for both Cerner and more broadly, the healthcare industry. Each month, CAS subscribers  receive an update of our latest research findings on some of the most transformative trends in healthcare IT. This is all part of the CAS service, a service that provides a continuous feed of research findings and access to our analysts keeping CAS subscribers abreast of the rapid-fire changes in this market. Below are abstracts of the other two research notes we published in the October Monthly Update.

 With Readmission Penalties Looming, Can Care Get Coordinated?
CMS penalties for patient readmissions within 30 days of discharge went into effect October 1, posing a very real challenge that all hospitals must now address. Needless to say, better care coordination across various settings will be critical to cutting back on readmissions. Currently, patients are transferred from venue to venue with incomplete records, leaving providers to fill in the blanks in their care. Healthcare IT has long been promoted as a magic fix to this problem, but it will take more than technology to truly coordinate care, and different patient populations pose different technology needs. This is partially why our 2013 HIE Market Report will pay particular attention to what solutions vendors may be developing to ensure providers have complete patient data.

Clinical Analytics Gears Up for Second Wave
The second story continues to unwrap the analytics market. Though other sectors have used analytics to make business decisions for decades, all but the most innovative healthcare providers lagged behind under fee for service. With that reimbursement model on its way out, the second wave of healthcare providers are grappling to choose an analytics vendor, even as many work through the rocky early years of electronic health record adoption. These providers are in for a confusing procurement process, with a market awash in vendors claiming to offer a clinical analytics solutions. To say this market is getting heated is putting it mildly.

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Now that NwHIN has been spun-out into the public-private entity Healtheway one has to wonder exactly what value they can deliver to market that will sustain them as they attempt to ween themselves from the federal spigot. Healtheway has no lack of challenges ahead but they intend to target one area that presents an interesting opportunity. Question is: Are they too early to market?

During a recent webinar, Healtheway’s interim executive director, Mariann Yeager, outlined the origin of Healtheway, the apparent traction Healtheway is gaining in the market and what their plan is going forward.

Healtheway got its start via funding from a variety of federal sources, all of whom who were looking for a solution to address their unique problems. For the Social Security Administration it was the need for a nationwide network to facilitate processing of disability claims. For the VA and lesser extent DoD it was the need to enable military personnel to receive care in the public sector and insure that their records were complete. Health & Human Services led most of the development effort leading to NHIN CONNECT, a less than stellar technology platform built by beltway bandits (who else), that hit the market with a thud.

One of the things the feds did get right though is a clear and comprehensive policy for data use sharing across disparate entities. The DURSA (data use and reciprocal support agreement) remains one of the key differentiators in Healtheway’s portfolio. Healtheway’s intent is to leverage the DURSA as the “unifying trust framework” and build upon that with a common set of technical exchange requirements (standards) to facilitate exchange with eHealth Exchange (this replaces the former NwHIN Exchange). Healtheway has also enlisted CCHIT to perform testing of technology vendors solutions to insure they comply with the technical exchange requirements that will allow for HIE-to-HIE connectivity.

That last sentence is the kicker. Healtheway and its eHealth Exchange is not intended to be an uber-national HIE but a set of policies and technical specs that will allow HIEs, be they public or private, to share information across institutional boundaries. Therefore, Healtheway will not get into the current rat’s nest of looking to on-board the multitude of ambulatory EHRs into an HIE but sit one level above that facilitating exchange across HIEs. This is something that many regional and state HIE programs are looking to facilitate, thus it is not surprising to see that a significant proportion of Healtheway members come from such organizations.

There will be a need for this functionality at some future point in time, but not today and likely not tomorrow either. Three key challenges stand in their way:

1) Getting buy-in from healthcare organizations and technology vendors. While membership has indeed grown, Healtheway is offering membership at a discount (likely a loss) to gain traction and unfortunately they still do not have significant traction as many brand names in healthcare are missing.

2) A tainted history with more than its share of missteps. Slowly coming out from under the wing of federal politics as a pseudo independent organization (Board still has plenty of government influence), Healtheway may begin to act more as an independent organization, more like a business. Unfortunately, due to a likely continual need for government funding that independence will likely be limited.

3) The HIE market, both from a technology, policy and implementation/deployment perspective is still primitive. The broad market is simply nowhere near the point of needing what Healtheway intends to offer for a few years to come, at least as it pertains to the exchange of clinical data. Good idea, too early to market. That being said, tehre will be value on the transaction side, e.g., SSA and disability claims processing.

Hopefully the future will prove us wrong on this one and Healtheway will indeed prosper and contribute to the maturity of the HIE market. But our advice, don’t bet on this horse just yet, give them six months than take a second look.

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Last week we attended the big healthcare IT confab HIMSS in that grand city of sin, Las Vegas. While many spoke of how HIMSS hit an all time record of over 37K attendees (an impressive number), HIMSS is still dwarfed by what is arguably the largest US-based healthcare trade show, RSNA, which had a 2011 attendance of just over 57K, (roughly 54% greater than HIMSS). Why such a radical difference you ask? As one colleague put it:

RSNA is where providers come to make money and HIMSS is where they go to lose money.

While that may be the case today, it is unlikely to be so in the future. The healthcare industry is undergoing a massive transformation that will likely take a decade to complete as we transition from a reimbursement model largely based on fee for service to one based on outcomes. Under this new model, providers will be taking on a greater portion of risk. In reward, these providers have an opportunity to receive a significantly higher net reimbursement. This transition is making for some interesting bedfellows as payers and providers join together to create new care delivery models such as Accountable Care Organizations (ACOs) and Patient Centered Medical Homes (PCMHs). These new models will be increasingly dependent on a robust HIT infrastructure to effectively measure quality, risk and performance, something that simply cannot be done effectively with the antiquated systems that are in place today in many healthcare organizations (HCOs).

Nearly every vendor we met with at HIMSS had a story to tell about how they had the solution the market was seeking for ACO enablement. This was not entirely unexpected for last year we thought that would be the year of ACO. Obviously, we were a little ahead of ourselves and the industry with that prediction but alas it has come to pass. Small problem though: HIT vendors have had plenty of time to prepare their solutions for ACO enablement but to our surprise, most solutions were still far from mature. Frankly, we are not too worried about this right now for Chilmark is forecasting significant evolution, innovation, and in short-time maturity in these solutions as customers (HCOs) further define what they truly need to succeed in this new world order of reimbursement for healthcare delivery in the US.

This raises what our research team found to be the most significant learning from HIMSS’12.

As most of you already know, ONC made quite a splash at HIMSS by announcing the release of Stage 2 meaningful use (MU) requirements (we’ll have a future post on the implications of these requirements later this week). But honestly, we did not see a wild wrangling of commentary and discussion in the halls of HIMSS’12 regarding these new requirements. Maybe this was because most attendees were simply addressing the needs of today and did not have time to thoroughly review these new requirements. But we believe something else may be at work here.

Our Thesis:
The MU requirements have become little more than a “spec-sheet” for vendors, consultants and IT shops and departments. These requirements have nothing to do with innovation and have little to do with the dramatic changes that will occur in this industry in the next decade. Quoting that oft-used phrase, “follow the money” one can quickly see that the billions in funding for incentivizing providers to adopt EHRs under the HITECH Act is relative chump change to the dramatic fortunes that may be won or lost under the new value-based payment models that are proliferating throughout the industry – payment models that commonly fall under the rubric of ACO or PCMH. In each of these models, EHRs are important to a degree, they are part of the basic infrastructure. But it is what one does with the data that matters (collect, communicate, collaborate, synthesize, analyze, measure and improve). Therefore, if you want to see innovation look beyond today and the tactical push to effectively adopt and meaningfully use EHRs and towards the future of how that data will be used to drive quality improvements, better outcomes and lowering risk exposure.

And speaking of risks…

What was clearly lacking at this year’s HIMSS was patient engagement. Yes, there was a seminar on the topic and sure, everyone speaks of patient-centric care but there was little evidence among exhibitors at this year’s HIMSS (with a few exceptions, e.g., Cerner, MEDSEEK, RelayHealth) that spoke to the need to engage patients as part of the care team. Get a clue folks, one will never get to that nirvana of a truly effective ACO or PCMH without active, effective engagement of the patient. Not having an engaged patient is your greatest risk.

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Last week was the massive Salesforce.com user conference Dreamforce (massive in that there were more attendees at Dreamforce then this year’s HIMSS!). We’ve been reviewing more than a few articles and writings written by those who attended the event. In the few short years of its existence (~13yrs) Salesforce.com has become one of the leading Customer Relationship Management (CRM) vendors in the market and basically pushed the previous leader Siebel to the brink and into the arms of Oracle. Salesforce is arguably the leader in the Software as a Service (SaaS) market and thus someone to pay close attention to on all things “Cloud Computing.”

So what makes Salesforce.com so compelling and what are some parallels to the healthcare sector?

Similar Market Demographics: From the beginning Salesforce has always been structured as a SaaS and targeted the hard to reach and highly distributed sales forces of companies of all sizes. Actually, they first targeted the small to medium business (SMB) market and once successful there, went after Siebel in big enterprises. In healthcare, the vast majority of care is provided by small, 1-3 physician practices that are highly distributed across the country – perfect target for a hosted SaaS offering.

Deliver Value, Not Pain: Since most sales people get a large portion of their salary via commissions, the last thing they want to do is hassle with software that is cumbersome to use. Salesforce.com’s user interface (UI) is very intuitive and surprisingly customizable (within limits) for an SaaS offering. This allows a sales person to configure the the solution to their specific needs. We hear time and again from physicians that the EHR they are being forced to use doesn’t fit their workflow and is often painful to use. (Having been demo’d more than our fair share of EHR solutions, it still shocks us just how awful the UI is for these solutions.) Like their sales brethren, physicians need solutions that fit their processes and do not slow them down.

Fold in Rich Communication Tools: At this year’s Dreamforce, Salesforce.com CEO Marc Beniof spend a substantial amount of time focusing on the rich communication tools that Salesforce is embedding to tap the move to social networks. Right now, the US Government is dumping over a half billion dollars to stand-up HIEs in every State and enterprises are easily spending double that amount to facilitate information exchange in support of referrals, lab distribution, orders, etc. What if a Salesforce for healthcare arrived on the scene allowing physicians to securely exchange information in the same manner that those on Salesforce.com use that platform for secure ad hoc communication with internal and external partners to meet customer needs?

Provide Robust Security – No Leakage: Sales leads are a sales person’s bread and butter and they guard them with their lives for it truly is their livelihood. Thus, Salesforce had to build a system that ensured a sales person’s leads were their own with no possibility of a breach (leakage) to a competitor. If Salesforce can meet this strict requirement, is it such a stretch to preserve the integrity of personal health information (PHI) on such a system?

Focus on the Data & Deliver Simple Yet Useful Analytics: Sales is often a numbers game. This requires superior, robust data management and ultimately the ability to create a wide variety of pre-configured and customizable reports. As we move towards value-based contracts, providers of all sizes will be asked to provide reports as well (typically on quality metrics) to those paying the bills (CMS, payers, etc.).

Provide an Ecosystem: Salesforce has a vision to provide an ecosystem of third party apps on top of their platform but to date, like most companies, they have struggled to make much headway here. But in time, as more and more IT functions move to the “Cloud” to support an increasingly mobile device centric world, an ecosystem is inevitable. In healthcare, where one might successfully argue that physicians are one of the most mobile of professions, accessing apps via mobile devices is quickly becoming standard practice. Increasingly, the healthcare market and in particularly those far-flung physician practices, will look to ecosystems of apps delivered over the Web to their mobile device (touch-screen tablet) to support their practices.

Adhere to KISS Principle: Like sales professionals and for that matter just about any other professional worth their salt, physicians in private practices are extremely busy and the last thing they need is to fuss around with software maintenance and upgrades. Subscribing to a SaaS takes that big upgrade headache and slams it with a double dose of Excedrin.

This got us to thinking…

Who in the Healthcare IT (HIT) market might become the Salesforce.com of HIT?

EHR Vendors:
We can’t think of a single vendor in the EHR market that has the foresight, the vision, the chutzpa to pull off a Salesforce.com move. Sure, one can point to PracticeFusion (who happens to have received backing from Salesforce) but we don’t see the vision there. What about athenahealth you might ask? Yes, they like to portray themselves as such, but honestly, their bread n’butter solution is not a SaaS play but more of a straight services play delivered via the Internet and a lot of old school back office processing in a warehouse in Maine. All the other EHR vendors? Either they’re too small to matter or chained to their legacy business models that they can not break free of to deliver the scale and gravitas of a Salesforce.com like solution for healthcare.

HIE Vendors:
Increasingly, HIE vendors are providing simple EHRs targeting ambulatory practices, they certainly have the information exchange piece covered (to highly varying degrees) are beginning to fold in analytics (big reason why UHG acquired Axolotl) and some are looking to provide an ecosystem play such as Medicity with its iNexx platform, Covisint with its AppCloud or even Microsoft’s somewhat aborted attempt with Amalga. Yet, despite these efforts, we do not see any one HIE company really grasping the reigns and running away with the prize. Each of the aforementioned vendors have their own reasons why they haven’t quite captured the imagination of the healthcare sector and we are not holding our breath waiting for someone to breakout.

Emdeon has a huge presence in the market as a clearinghouse for claims processing and having just been taken private by private equity firm Blackstone, they may try to make such a play. At the most recent HIMSS sat down with Emdeon for a briefing where they hinted to a desire to move more directly into clinicals, but to date, we’ve seen nothing materialize and it is unlikely to happen anytime soon. Emdeon also has the very real issue of their existing business model (did you no their number one capital expense is postage stamps?) that will keep them on the sidelines.

NaviNet is similar to Emdeon in that they already have a direct connection into the physician’s office with some one million plus healthcare providers using their service. NaviNet has the links but it does not appear that they want to get into the nitty gritty of providing a host of other services and offerings on top of their existing platform. It appears that NaviNet will add small incremental services to their platform rather than go for the whole enchilada keeping the platform simple and streamlined.

Surescripts is making a play in the HIE market with its Kryptiq partnership offering the Clinical Interoperability platform. While still early in its development. the Surescripts play is the closest thing we have seen to date to match the existing Salesforce juggernaut and the one to watch.

Now we certainly do not claim to have all the answers, never have. That is why we have a comments section below. So dear readers, we’ve given you are analysis and now it’ your turn. Who do you think is in the best position to become the Salesforce.com of the HIT market?

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Attending the annual health insurers confab (AHIP Institute) last week gave one some insight as to the challenges this part of the healthcare industry is facing. There were plenty of sessions on addressing data analytics for everything from population health management to fraud, a number of other sessions on consumer engagement, disease management, health & wellness, and of course the ever ubiquitous sessions on Accountable Care Organizations (ACOs).

But what pervaded many a discussion, panel session, and even keynotes was the level of uncertainty in the market today. Though the Affordable Care Act (ACA) was passed and signed into law, its future is anything but certain. There is both legal and political uncertainty. Legal in the numerous lawsuits that have been filed, particularly regarding the individual mandate that will ultimately be a Supreme Court decision. Political in that numerous politicians and some presidential contenders have built a portion of their platform on repealing ACA. Such uncertainty makes it extremely difficult for payers and employers to effectively plan for the future. Regardless, there were a few key areas that seemed to attract the most attention: ACO, Consumer Engagement & HIX.

Following are some quick snapshots:

Accountable Care Organizations (ACOs): Plenty of talk on this subject, primarily from the consulting firms who seemed to have run most of the sessions at AHIP. Payers have been experimenting with the model for some time now, well in advance of CMS’s NPRM. In one session, Blue Shield of California (BS-CA) talked about their ACO with Catholic Healthcare West. A very challenging relationship that took 4 years to iron-out and stand-up the ACO and the only reason they kept at it: Calpers was supporting them with an enrollment of 40K new members and Kaiser-Permanente was beating the hell out of both of them in the market. More competitive necessity. This may foretell future attempts and challenges to move to this model. One other important point expressed many times over regarding ACO: data exchange is an ACO’s life-blood.

Consumer/Member Engagement: Numerous sessions drilled down on how payers will market to and serve their members in a deeper, more meaningful fashion but it all sounds just so superficial. Sure, payers are indeed trying to engage the consumer (marketing to new prospects via HIX – payers are really struggling here) and provide consumers with information they can use to make better “value” choices. There are also the ubiquitous efforts of payers to promote health & wellness and institute various disease management programs. Yet based on the sessions attended, seems more like a lot of hand waving and not convinced payers are seeing any meaningful traction in truly engaging their members.

Health Insurance Exchanges (HIX): In accordance with the ACA, a State must have its HIX operational by Jan. 2014. Each State in the country will have their own, slightly nuanced HIX to meet the needs of their citizens and in compliance with their laws. There is no commercial off the shelf (COTs) solution so each exchange will be a separate, custom build. The big winners here are consulting/system integrator (SI) firms (e.g., ACS, CSC, Deloitte, etc.) and they were out in force at this event. They are going to make a killing first standing up these HIXs and then of course keeping the HIX up and running over the years to come. The big challenge, however, is that these exchanges are slated to support Medicaid recipients and most States’ Medicaid IT infrastructures are so outdated that they need to be rebuilt. Even more $$$ to those SI/consulting firms.

What may have been the most bizarre aspect of this event was simply its isolation from the rest of the healthcare sector. This was a very insular event. There were no consumers/members giving presentations or keynotes on what they are looking for from this industry sector. There were few if any providers or representatives of provider organizations talking (either in sessions or keynotes) about what they were looking for from payers, how they wish to engage them, work together to improve health outcomes, improve the value of healthcare delivered.

All very, VERY strange.

If this sector of the healthcare industry is truly interested in improving the quality and value of healthcare delivered, it has its work cut out for them. In our next post we’ll delve into the three overarching challenges payers face with the coming changes brought about by ACA. Small hint, start with trust.


Consulting firm Perficient was also in attendance and wrote about the ACO issue as well that is worth a read.

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On Tuesday, to a tremendous amount of fanfare, HHS announced it will invest $1B in the Partnership for Patients. The press release is certainly buzzword compliant having all the wonderful terms that will endear others to join. And join they have, coming from all corners including employers such as GE, Honeywell and Walmart to small communities such as Casper WY to various advocacy groups from the Consumers Union to the Renal Support Network and hospitals and healthcare organizations galore. How could one not support such a program who’s objective is to lower hospital acquired complications by 40% by the end of 2013. Certainly a noble goal.

But is this really the best use of $1B?

Some would argue yes, we need to spend this kind of money to help disseminate best practices from leading healthcare organizations to those that are less skilled at preventing hospital acquired complications that put patients at risk. But is that not what AHRQ is suppose to do as part of its existing charter?  And does not NIH and CDC also have some role to play here?  Also, the recently released ACO proposed rules from CMS are looking to tackle this issue and one could even argue that the HITECH Act and Meaningful Use are structured to help address this issue as well. Which raises the question:

Do we really need another program to address the issue of patient safety or are we just adding another layer of bureaucracy and another pot of gold for various special interests groups to tap?

It may be heresy to ask these questions and maybe our questions are based more on ignorance, but this program just doesn’t seem to pass the sniff taste.

Rather then spend that billion dollars on yet another program that will be managed by beltway bandit contractors for HHS, would it not be better to develop programs similar to what is outlined in the ACO rules (but far simpler) that create incentives for healthcare organizations to go out on their own and find what will work best for them to improve patient safety.  While we are at it, we can use a stick as well. Why not start publishing in the local papers say on a quarterly basis, quality reports on the nine areas that HHS wishes to see improvement in as part of this program. In our view there is nothing like bad publicity to ignite changes in behavior.

The more one thinks about the Partnership for Patients the more one begins to see it for what it truly is; a publicity stunt designed to create broad-based support for the Accountable Care Act for it certainly is not the most effective or efficient way to change current practices to improve patient outcomes.

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On March 31st, the HHS’s Center for Medicare and Medicaid Services (CMS) dropped its neutron bomb (proposed Accountable Care Organization (ACO) rules, caution PDF) on the healthcare industry. Much like the neutron bomb, the proposed rules will leave buildings standing, but any healthcare organization (HCO) planning to become a successful ACO will need to decimate cherished internal processes to create new models of care delivery. Those new models of care delivery by an ACO are intended to meet three core objectives of these proposed rules:

  1. Deliver better care for individuals
  2. Provide better health for populations and
  3. Lower growth on Medicare expenditures.

The proposed rules, which go by the overall heading of Medicare Shared Savings Plan (MSSP), provide as an incentive an ability for an ACO to share in the expected savings to CMS (it’s a rather complicated two tier structure) that also includes some downside risk should the ACO not meet some of the core objectives. To become an ACO, an HCO must have a minimum of 5,000 Medicare beneficiaries under management. The first round of applicants, who will sign-on to a three year ACO contract with CMS, will begin January 1, 2012. It is envisioned, these are proposed rules after all, that subsequent HCOs wishing to become an ACO may do so at the beginning of the calendar year.

The ACO rules have been anticipated for some time (they are an outcome of the Healthcare Reform Act) and at 429pgs, this document is quite a tome. The proposed rules are very expansive covering everything from ACO governance (a Medicare beneficiary must be on the Board), to ACO marketing (CMS wants to review ALL ACO marketing material), to quality measures & reporting, to how savings will be shared. We at Chilmark Research have reviewed a good portion of these rules and provide the briefest of summaries below focusing on the healthcare IT (HIT) aspects of these proposed rules.

Without a robust HIT infrastructure already in place, an HCO simply will not cross the chasm to becoming an ACO.

The above statement is about as brief and simple as we can make it regarding these proposed rules. CMS, along with its sister agencies that helped draft these rules, have set a very high bar for HCOs to leap over to meet these requirements. We predict that exceedingly few HCOs will make that leap in the inaugural year for the following reasons:

The ACO will need to report on 65 quality measures in five categories. Even though the quality measures chosen are well-known, accepted standards, few HIT systems today can automatically produce such reports. Thus the overhead burden of manually creating such reports may result in little upside gain for an HCO.

Core to the ACO model that CMS proposes is facilitating transitions in care via use of HIT (e.g., summary of care record) not only within the ACO but also beyond the ACO to whomever a beneficiary cares to see. This requires a level of local/regional health information exchange (HIE, the verb) that simply does not exist today in most communities. Sure, its coming but it won’t be ready in 2012.

An ACO must have at least 50% of its primary care physicians (PCPs) be “meaningful EHR users” as defined by the HITECH Act. The big challenge with EHR adoption under the HITECH Act has always been the small PCP practice. Will an ACO be able to aggregate enough of these practices to meet the 50% threshold?

Patient-centered care is a hallmark of these proposed rules with the term mentioned on nearly every page. A core objective that an ACO will need to meet is:

“…ACOs must have systems in place to identify high-risk individuals and processes to develop individualized care plans for targeted patient populations.”  And goes on to state: “The individualized care plans should include identification of community and other resources to support the beneficiary in following the plan.”

A robust HIT infrastructure will be required to facilitate and automate many of the processes required to identify at-risk populations and create and share those beneficiary-specific care plans. Very few HCOs today have the systems and processes in place to enable the creation and distribution of such care plans.

After reviewing these proposed rules the first thing that came to us was:

From an HIT perspective, meeting meaningful use criteria is a cakewalk in comparison to meeting these proposed ACOs rules, they are that big, that much of a game changer.

Clearly, CMS is taking this somewhat unique opportunity to create a future model for healthcare delivery that will meet those three core objectives mentioned at the beginning of this post. But in doing so, there is the very real danger that CMS has bitten off far more than it can chew, which will ultimately result in an even bigger bureaucracy at HHS than the one we have today and subsequently higher administrative costs. (Seriously, review all marketing material that an ACO proposes to use? What were they thinking?).

There is also the issue of HIT maturity in this sector and the woeful lack of process maturity that we discussed in a previous post. Exceedingly few HCOs will rise to the ACO challenge in the early years. Therefore, are we setting ourselves up for a colossal failure or more likely, a nation of haves and have nots wherein those communities with skilled, IT savvy HCOs will ultimately be able to capitalize on the MSSP at the expense of their smaller rivals? There is plenty of language in the proposed rules to prevent predatory and monopolistic practices but the threat is there just the same should one HCO, by becoming an ACO, become more profitable than their competitors down the street or across town squeezing them out of business.

But not to end on a sour note, we are quite pleased by some of the language we saw in the proposed rules. Specifically we like:

The strong focus on processes to enable an ACO. Process change is put right out front as core to the metrics that CMS will use to evaluate an ACO, which frankly is right where it should be. Technology is just an enabler of process change.

Openness to innovative approaches and new models of care delivery including the use of telemedicine and remote monitoring.  This has the potential to finally crack open the telemedicine/telehealth market.

The strong focus on patient-centric care. Finally, the lightbulb has gone on in DC that to truly bend that proverbial cost curve, the patient (beneficiary), their community and their personal care team (family, friends, loved ones) all need to be an integral part of the care team. This is visionary and for that we applaud CMS’s efforts to create a new model of care for this country.

Other good sources of ACO information we have found include:

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