(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.