News About NRHI andRegional Health Improvement Collaboratives
New Medicare Data Regulations Will Support Regional Healthcare Improvement Efforts
Final regulations issued on December 5 by the Centers for Medicare and Medicaid Services (CMS) will significantly increase the ability of communities across the country to measure and improve the quality and cost of healthcare. "Regional Health Improvement Collaboratives have the most extensive experience in the nation in successfully implementing healthcare performance measurement and public reporting efforts," said Harold D. Miller, President and CEO of the Network for Regional Healthcare Improvement, which had supported legislation and regulations to make the data available. "The new regulations will enable Collaboratives to obtain data needed to measure and report on the quality and cost of care for senior citizens, and also to make all of their existing quality/cost measures more robust and reliable."
The new regulations specify the conditions under which Medicare claims data will be released to "qualified entities" for public reporting on the quality and cost of healthcare. Regional Health Improvement Collaboratives are expected to be the largest group of such qualified entities, since they currently are the principal source of information on the quality of healthcare in communities across the country.
In August, 2011, the Network for Regional Healthcare Improvement submitted extensive comments on the proposed version of the regulations. NRHI praised CMS for adopting almost all of NRHI's recommendations. In particular, NRHI noted the following important changes made by CMS in the final regulations:
- The cost of obtaining the data is being significantly reduced. Whereas CMS originally projected the cost of obtaining data for 2.5 million beneficiaries to be $200,000, CMS now projects the cost to be $40,000. The cost will presumably be lower for organizations in smaller states and regions.
- CMS will allow organizations to apply to become qualified entities at any time, rather than limiting applications to the first quarter of each year. This will give Collaboratives more time to apply than the original deadline of March 31.
- CMS will allow organizations to use contractors to meet the criteria for serving as a qualified entity. This will facilitate the ability of additional communities to form Regional Health Improvement Collaboratives to do measurement and reporting.
- CMS will now provide data on a quarterly basis rather than an annual basis, allowing for more current measures to be reported.
- CMS will allow reported measures be based on both claims and clinical data.
- CMS will provide qualified entities with a crosswalk file of beneficiary names and identifiers as well as the claims data, so that qualified entities can (a) link claims and clinical data, and (b) give providers patient-specific data for accuracy verification.
- CMS will make a 5% sample of national Medicare data available upon request so that qualified entities can create national benchmarks for their local data.
- CMS will allow qualified entities to use a new measure if local stakeholders in their market support the use of that measure and there is scientific evidence to support it.
NRHI Member Quality Reporting Referenced in Wall Street Journal
An article in the October 22, 2011 Wall Street Journal referred readers to NRHI member Regional Health Improvement Collaboratives as one of the only sources of information about the quality of physicians and hospitals.
NRHI Submits Recommendations to CMS on Rules for Release of Medicare Data
(August 8, 2011) The Network for Regional Healthcare Improvement (NRHI) today urged the Centers for Medicare and Medicaid Services to significantly revise its proposed regulation governing release of Medicare claims data to ensure that Regional Health Improvement Collaboratives can obtain and use the data to measure and report on the quality and cost of healthcare in their communities. NRHI said that the requirements in the proposed regulation could either preclude participation of Regional Health Improvement Collaboratives entirely or make it extremely difficult for them to do so. "These requirements are inconsistent with what we believe was the intent of Congress - to ensure that Medicare claims data can be used by as many communities as possible to help improve the quality of care for Medicare beneficiaries and thereby to also help control costs in the Medicare program," said Harold D. Miller, President and CEO of NRHI.
NRHI's member Regional Health Improvement Collaboratives have the most extensive experience in the nation in successfully implementing performance measurement and public reporting efforts for a wide range of measures and for patients associated with multiple payers, and in ensuring the reports are used to actually improve the quality of care in a community. A number of NRHI members have been collecting and publicly disseminating measures of the quality of healthcare services in their communities for multiple years, and a growing number of members also measure and report on patient experience and the cost of care, but the ability of Regional Health Improvement Collaboratives to identify and address opportunities to improve quality and reduce cost has been impeded because claims data on the care delivered to Medicare beneficiaries have not been available. Consequently, NRHI members strongly supported Section 10332 of the Patient Protection and Affordable Care Act which authorizes release of Medicare claims data to organizations such as Regional Health Improvement Collaboratives, and last September, NRHI provided CMS with detailed recommendations on how to successfully implement Section 10332.
Many Regional Health Improvement Collaboratives intend to apply to become qualified entities under the provisions of Section 10332. Indeed, the Regulatory Impact Analysis in CMS's proposed regulation to implement the law acknowledges that Regional Health Improvement Collaboratives will represent most of the organizations that can serve as Qualified Entities. In its comment letter, NRHI identifed a number of aspects of the proposed regulation that would impose unreasonable or unnecessary restrictions or burdens on Regional Health Improvement Collaboratives in obtaining Medicare claims data for quality measurement and reporting, and made recommendations for specific changes. For example:
- Under the proposed regulation, organizations would have to have three years of experience in handling and publicly reporting claims data from non-Medicare sources before they could obtain access to Medicare data. This is unnecessary, and could preclude many Collaboratives that are currently reporting from immediately obtaining Medicare data, and significant delay or preclude new Regional Health Improvement Collaboratives from beginning measurement and reporting programs.
- The proposed regulations would impose extensive and burdensome requirements on Collaboratives in order to apply to access the data. CMS estimates that 500 hours of effort could be required simply to submit an application. NRHI recommended that the application requirements be significantly simplified.
- Under the proposed requirements, Collaboratives would have to pay hundreds of thousands of dollars in administrative fees to obtain the data, most of which would be to cover CMS administrative costs to review the detailed applications it is requiring be submitted. NRHI urged that fees for release of data be limited to the direct cost of producing the data, particularly since Regional Health Improvement Collaboratives would be using the data to improve the quality of care for Medicare beneficiaries and reduce costs for the Medicare program.
- The proposed regulation would require that before a Collaborative can make any changes to the measures it uses, to the reporting format it uses for already-approved measures, or even to the method by which it shares approved reports with the public, it must submit the changes to CMS and wait for its approval before being able to proceed. NRHI said that requiring CMS review and approval of all changes in reporting formats and public dissemination strategies is an unnecessarily burdensome level of micromanagement that will be expensive for both CMS and Collaboratives and will severely impede the ability of Collaboratives to implement successful measurement and reporting programs.
- The proposed regulation would require that before any Collaborative could use Medicare data for a measure that had not been endorsed by the National Quality Forum, CMS would have to publish the proposed measure for notice and comment using the formal rulemaking process, an extremely expensive and time-consuming approach, even though the law does not require the use of a formal notice and comment process. NRHI recommended that CMS approve the use of an alternative measure in a community if the providers in the community supported the use of the measure.
- The proposed regulation would require that if the amount of claims data that a Collaborative is receiving from non-Medicare payers "decreases," even by an insignificant amount, the Collaborative would have to immediately cease any measurement and reporting efforts using Medicare data until CMS "determines that the remaining claims data is sufficient." NRHI urged CMS not to focus on the amount of data that a Collaborative has, but rather the Collaborative's procedures for ensuring statistical validity of the measures.
A copy of NRHI's comment letter can be downloaded here.
NRHI Submits Recommendations to CMS on Accountable Care Organization Regulations
(June 6, 2011) The Network for Regional Healthcare Improvement submitted extensive comments to the Centers for Medicare and Medicaid Services on its proposed regulations for Accountable Care Organizations.
NRHI said that Accountable Care Organizations could be a very important mechanism for improving quality and controlling the costs of health care in communities across the nation, but only if they are implemented efficiently and effectively and in ways that complement community-wide quality improvement and cost containment initiatives
NRHI recommended that CMS make the following changes in the proposed regulations in order to support this:
- CMS should explicitly encourage and require ACOs to support and work with local multi-stakeholder Regional Health Improvement Collaboratives in the communities where such Collaboratives exist.
- CMS should provide funding to Regional Health Improvement Collaboratives so that they can assist CMS in proactively educating the Medicare beneficiaries in their communities about things such as (a) the quality of care delivered by the physicians and hospitals participating in the ACOs in the community as well as providers who are not part of an ACO, and (b) the types of actions beneficiaries can take to support efforts by an ACO to improve their health and the quality of the healthcare services they receive.
- Instead of requiring that all ACO marketing materials be approved in advance by CMS, CMS should permit ACOs to use materials that have been approved by, or developed and issued jointly with, the Regional Health Improvement Collaborative in the community where the ACO operates.
- CMS should permit and encourage ACOs to assess patients' experience of care through community-wide patient experience surveys conducted by Regional Health Improvement Collaboratives.
- CMS should draw on the experience and expertise of the Regional Health Improvement Collaboratives that are currently collecting and reporting patient experience measures as CMS refines its requirements for ACOs to collect such measures.
- CMS should provide financial support for programs by Regional Health Improvement Collaboratives to collect and report data on patient experience, so that ACOs , particularly ACOs composed of small providers, can utilize such programs to comply with requirements under the Shared Savings Program.
- CMS and AHRQ should work with Regional Health Improvement Collaboratives to develop and test new patient experience measures that specifically address the care delivery issues associated with ACOs.
- CMS should give priority to using quality measures that are already successfully being used for public reporting by one or more Regional Health Improvement Collaboratives.
- ACOs should be allowed to report on and be held accountable for quality measures that are being collected and publicly reported by a Regional Health Improvement Collaborative in their community, in place of some of the measures proposed by CMS.
- ACOs should be consistently required to calculate quality measures on all patients seen by the ACO to whom the measure is applicable, not just Medicare patients or attributed patients.
- CMS should provide Regional Health Improvement Collaboratives with Medicare claims data for all of the beneficiaries in the community, so that the Collaboratives can calculate claims-based quality measures on the full populations served by ACOs and by other healthcare providers in the community.
- Any reports issued by CMS on the quality of care delivered by ACOs should clearly and visibly explain any differences between the measures CMS reports and the measures that are being publicly reported by Regional Health Improvement Collaboratives in the ACOs' communities.
- CMS should replace Measure 35 with the Optimal Diabetes Care Composite that was recently endorsed by the National Quality Forum (#0729), and CMS should use the specifications for the individual elements of NQF Measure #0729 for the proposed measures 36-41.
- Instead of Measure 52, CMS should use the Optimal Vascular Care Composite that has been endorsed by the National Quality Forum (#0076), since it focuses on outcome measures rather than process measures.
- Instead of or in addition to Measure 34 (Depression Screening), CMS should require measurement of (1) the use of the Patient Health Questionnaire 9 (PHQ-9) for patients with depression, and (2) the remission rate for patients with depression, either at 6 months or 12 months or both, which are measures that have been endorsed by the National Quality Forum (#0710, #0711, and #0712).
- In states and regions where a Regional Health Improvement Collaborative is already collecting and publicly reporting on the quality of care in physician practices and/or hospitals and has the capability to collect and report the quality measures required by CMS, CMS should allow the ACO to use the Collaborative's data to meet its reporting obligations under the Shared Savings program, rather than requiring ACOs to collect and submit data separately.
- Before developing its own data submission tool, CMS should consider using existing reporting tools, such as the RBS system that was developed by the Wisconsin Collaborative for Healthcare Quality and is being used in several other communities.
- In addition to any mechanisms CMS establishes for making claims data available directly to providers, CMS should make Medicare claims data available to Regional Health Improvement Collaboratives on all of the Medicare beneficiaries living in and/or receiving care in the region or state that the Collaborative serves.
- CMS should begin making Medicare claims data available to Regional Health Improvement Collaboratives immediately so that the Collaboratives can help providers in their communities identify successful strategies for forming ACOs.
- In states and regions where a Regional Health Improvement Collaborative has an active quality measurement and reporting program, ACOs should be required to submit quality measurement information to the Collaborative.
More detail on NRHI's recommendations is available in the letter submitted to CMS.
GDAHC Posts Hospital Payment Amounts for Medicare Patients
(April 22, 2011) The Greater Detroit Area Health Council has begun posting data on the amounts hospitals are paid for care of Medicare patients on its MyCareCompare website.
New Report on Regional Health Improvement Collaboratives
(February 4, 2011) A new report describes the key roles that non-profit, multi-stakeholder Regional Health Improvement Collaboratives are playing all across the country in transforming the healthcare delivery system and improving the health of citizens. Regional Health Improvement Collaboratives: Essential Elements for Successful Healthcare Reform provides an overview of what Collaboratives are doing in performance measurement, payment and delivery system reform, training and assistance for providers to help improve performance, and patient education and engagement, as well as detailed profiles on eleven Collaboratives and their leaders.
The report was produced by the Jewish Healthcare Foundation, which has been a major supporter of the Pittsburgh Regional Health Initiative and the Network for Regional Healthcare Improvement.
New Guide for Reducing Catheter-Associated Urinary Tract Infections from the Iowa Healthcare Collaborative
(January 27, 2011) The Iowa Healthcare Collaborative has developed the
Iowa CAUTI Prevention Collaborative
Resource Manual, a comprehensive resource manual aimed at reducing catheter-associated urinary tract
infections (CAUTIs). IHC is partnering with the Iowa Department of Public Health and 77 Iowa hospitals to
reduce CAUTIs in Iowa.
New Guide for Reducing Hospital Readmissions from the Pittsburgh Regional Health Initiative
(January 21, 2011) The Pittsburgh Regional Health Initiative has developed the
PRHI Readmission Reduction Guide, a detailed manual for how to design and implement processes to reduce hospital readmissions, particularly
for patients with chronic diseases. Although the majority of readmission reduction initiatives across the country
have focused narrowly on improving the hospital discharge process, the processes developed by PRHI also include
ways to improve inpatient care and, perhaps most importantly, ways to enhance primary care for patients so that readmissions
can be reduced beyond the typical 30-day measurement limit. Because of its emphasis on enhancing primary care rather than
merely improving hospital discharges and transitions, the PRHI approach can be used to reduce the number
of initial hospitalizations for patients with chronic diseases as well as readmissions. In addition to the PRHI Readmission Reduction Guide, PRHI developed a
video illustrating the work
done at one pilot site in Pittsburgh which was able to reduce readmission rates by 44% in the first year of
implementing changes designed using the techniques described in the Readmission Reduction Guide.
Quality Quest Launches Maternity Care Initiative
(January 2011) Quality Quest for Health of Illinois has launched the Healthy Babies, Healthy Moms project designed to eliminate elective pre-term inductions and c-sections. More than one in five babies are electively delivered before it is truly safe. The team working on the Healthy Babies, Healthy Moms initiative will identify evidence-based guidelines, encourage adoption of processes needed to eliminate unsafe, pre-term inductions, select key quality and safety measures and determine a means of collecting data to report to Quality Quest, and recommend approaches to heighten the awareness of clinicians, patients and families about the importance of full-term births.
Sanne Magnan Named New CEO of Institute for Clinical Systems Improvement
(January 11, 2011) The Institute for Clinical Systems Improvement appointed Sanne Magnan, M.D., Ph.D. as its new President and Chief Executive Officer. Dr. Magnan was ICSI’s President in 2006-2007 before being appointed Minnesota Commissioner of Health in 2007. While at ICSI, she helped expand ICSI’s focus beyond guideline development and quality improvement activities to include strategic initiatives designed to enhance patient-centered and value-driven health care, which led to the development of ICSI’s DIAMOND program for depression and the statewide initiative to ensure the appropriate use of high-technology diagnostic imaging scans. As Commissioner of Health, she was responsible for implementation of significant components of Minnesota’s 2008 health reform legislation.
New Patient-Friendly Quality Website Developed by Wisconsin Collaborative for Healthcare Quality
(January 4, 2011) The Wisconsin Collaborative for Healthcare Quality has developed a new patient-friendly website, Wisconsin Health Reports, which enables people to access data on the quality of physician care in Wisconsin in an easy-to-understand way, and provides more general "Learn, Compare, Act" advice on how to choose physician practices, what "quality" means, how to best plan a visit to the doctor, etc.
Mylia Christensen Named New Executive Director of Oregon Health Care Quality Corporation
(December 14, 2010) The Oregon Health Care Quality Corporation (Quality Corp) announced that Mylia Christensen has joined the organization as the new Executive Director, replacing Nancy Clarke, who retired. Christensen joins Quality Corp with over 30 years of experience in Oregon’s health care sector. She has worked in almost all facets of health care, from clinical settings to hospital and health care system management, strategic planning, public policy, and administration. Most recently, Christensen led the OHSU Center for Evidence-Based Policy’s national Medicaid and state agency collaborative focused on the development, translation, and dissemination of objective evidence to improve health policies and outcomes.
Albuquerque Coalition for Healthcare Quality Releases First Public Report on Quality of Medical Groups
(December, 2010) The Albuquerque Coalition for Healthcare Quality released “Medical Group Snapshot,” a public report on medical group performance. The report is based on claims data from Blue Cross Blue Shield of New Mexico, Lovelace Health Plan, Molina Health Care of New Mexico, and Presbyterian Health Plan for First Choice Community Health, Presbyterian Medical Group, and University of New Mexico Medical Group. Participation in the public report is voluntary for both health plans and medical groups. The reports covers information for the 2009 calendar year and provides information on the following process measures:
- Blood sugar (A1C) testing for diabetic patients;
- Cholesterol (LDL) testing for diabetic patients;
- Cholesterol (LDL) testing for cardiac patients;
- Breast Cancer Screening for women;
- Cervical Cancer Screening for women; and
- Appropriate use of asthma medications for patients between 5-17 years old, 18-56 years old, and 5-56 years old.
NRHI Joins National Priorities Partnership
(November, 2010) The Network for Regional Healthcare Improvement has joined the National Priorities Partnership. The 48 national organizations which are members of the National Priorities Partnership work to develop and implement National Priorities and Goals for payment reform, public reporting, quality improvement, and consumer engagement.
Regional Health Improvement Collaboratives Win Joint AHRQ Grant
(September, 2010) The Agency for Healthcare Research and Qualty (AHRQ) has awarded a $3.5 million, 3-year grant to the Pittsburgh Regional Health Initiative (PRHI) for a joint effort by PRHI, the Institute for Clinical Systems Improvement, the Wisconsin Collaborative for HEalthcare Quality, and the Network for Regional Healthcare Improvement to improve screening and treatment for depression and substance abuse in primary care practices. The first two years of the project will be focused on Minnesota, Pittsburgh, and Wisconsin, where up to 90 primary care practices will be assisted to implement behavioral health screening and early intervention using the IMPACT and SBIRT models. NRHI will assist ICSI, PRHI, and WCHQ in addressing payment system barriers to implementation during this first phase. Then, in the third year, NRHI will identify a fourth Regional Health Improvement Collaborative to implement the initiative.
NRHI Calls for Federal Help for Regional Health Improvement Collaboratives
(January, 2009) The Network for Regional Healthcare Improvement has joined with the American Health Quality Association, the National Business Coalition on Health, and the National Partnership for Women and Families in calling on Congress and the Obama Administration to provide federal assistance to Regional Health Improvement Collaboratives in their efforts to improve healthcare quality. In a letter, the four organizations identified three critical needs which must be addressed:
- the ability to include Medicare data in regional quality reporting initiatives;
- authorization for Medicare participation in regional payment and delivery system reform initiatives; and
- funding to support regional initiatives that promote greater accountability and faster improvement in the quality of American health care.
The full text of NRHI's letter can be downloaded here.