HIMSS EHR Association: New payment models need IT timeline consideration
Episode-based payment incentives must be aligned across other value-based models, CMS says.
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The HIMSS Electronic Health Record Association has asked the Centers for Medicare and Medicaid Services to consider time lines for IT development in its release of new payment models.
In July, the Centers for Medicare and Medicaid Services solicited a request for information for a proposed episode-based payment model. Comments were due by Thursday, August 17.
In its comment letter to CMS Administrator Chiquita Brooks-LaSure, the 31-member companies of the HIMSS EHR Association said they strongly encourage CMS to align with the Office of the National Coordinator on requirements and timelines.
Previous alternative payment model initiatives have created time lines for participants that require health IT development without any input from developers or the ONC to ensure their feasibility, EHRA said.
"This has caused significant burden for provider organizations who wish to participate and the health IT developers who support them. Considering this model will be mandatory, it is especially important for CMS to coordinate on timelines and expectations for health IT," EHRA said. "We also suggest that providers and health IT developers be allowed to test and adopt the Alternative Payment Model (APM) and dQM (Data Quality Management) measures on a voluntary basis before any dQM become required."
WHY THIS MATTERS
The proposed episode-based payment model builds on previous models from the Center for Medicare and Medicaid Innovation, such as bundled payments. The models are aimed at giving providers incentive to coordinate a patient's full range of care needs during a clinical episode, rather than getting reimbursed for individual services.
CMS would implement its new model no earlier than 2026, according to America's Essential Hospitals.
CMS said it intends to test an episode-based payment model with the goal of improving care transitions for the beneficiary and increasing engagement of specialists within value-based, accountable care.
However, the agency acknowledges there's an issue in how various value-based approaches, such as between episode-based payment models and population-based Medicare Accountable Care Organizations, coexist.
"In theory, ACOs and episode-based payment models should be complementary, as ACOs are well situated to prevent unnecessary care, while episode-based payment model participants focus on controlling the cost of acute, high-cost episodes," CMS said. "However, these value-based care approaches have not consistently been complementary and, in some cases, have complicated healthcare operations."
This is because the current ACO and episode-based payment environment has created the perception that certain providers and suppliers are striving for the same cost savings, and uncertainty exists with respect to who manages a beneficiary's care, CMS said.
"This issue is further exacerbated by complex model overlap policies that have changed as models and initiatives have evolved over time," CMS said.
The unintended consequence is that providers may be discouraged from participating in alternative payment models, leading to fewer beneficiaries under accountable care relationships.
"In order for the Innovation Center to achieve its strategic policy goals, episode-based payment incentives must be aligned across models to encourage intentional overlap, promote coordination and facilitate seamless transition back to primary care," CMS said.
THE LARGER TREND
Early episode-based payment demonstrations were narrow in scope and assessed particular design aspects, such as the use of gainsharing mechanisms or bundled payments for inpatient stays, according to CMS. Current models build upon early tests by examining condition-specific or acute inpatient/outpatient episodes with accountability usually extending 90-days beyond the triggering event.
Generally, these episode-based payment models have demonstrated reductions in gross Medicare spending, driven in large part by reductions in post-acute care spending or utilization, with minimal to no change in quality of care, CMS said.
CMS has a goal of having 100% of Medicare fee-for-service beneficiaries and the vast majority of Medicaid beneficiaries in an accountable care relationship by 2030.
Twitter: @SusanJMorse
Email the writer: SMorse@himss.org
