David S. Read

CMS has published a final rule (http://federalregister.gov/a/2015-14005) focused on changes to the Medicare Shared Savings Program (MSSP) which impacts Accountable Care Organizations (ACO) significantly. There are a variety of interesting changes being made to the program. For this discussion I’m looking at CMS’ continual drive toward data use and integration as a basis for improving quality of care, gaining efficiency and cutting costs in health care. One way this drive is manifested in the new rule regards an ACO’s plans as related to “enabling technologies,” which is an umbrella term for leveraging electronic data.

As background, Subpart B (425.100 to 425.114) of the MSSP describes ACO eligibility requirements. Two of the changes in this section clearly underscore the importance of electronic data and data integration to the fundamental operation of an ACO. Specifically, looking at page 127, the following updates are being made to section 425.112(b)(4) (emphasis mine):

Therefore, we proposed to add a new requirement to the eligibility requirements under § 425.112(b)(4)(ii)(C) which would require an ACO to describe in its application how it will encourage and promote the use of enabling technologies for improving care coordination for beneficiaries. Such enabling technologies and services may include electronic health records and other health IT tools (such as population health management and data aggregation and analytic tools), telehealth services (including remote patient monitoring), health information exchange services, or other electronic tools to engage patients in their care.

It goes on to add:

Finally, we proposed to add a provision under § 425.112(b)(4)(ii)(E) to require that an ACO define and submit major milestones or performance targets it will use in each performance year to assess the progress of its ACO participants in implementing the elements required under § 425.112(b)(4). For instance, providers would be required to submit milestones and targets such as: projected dates for implementation of an electronic quality reporting infrastructure for participants;

It is clear from the first change that an ACO must have a documented plan in place for continually expanding its use of electronic data and providing data visibility and integration between itself and its beneficiaries and providers. This is a tall order. The number of different systems and data formats along with myriad reporting and analytic platforms makes a traditional integration approach tedious at best and a significant business risk at worst.

The second change, keeping CMS apprised of the progress of data-centric projects, is clearly intended to keep the attention on these data publishing and integration projects. It won’t be enough to have a well-articulated plan, the ACO must be able to demonstrate progress on a regular basis.

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This week I had the opportunity to attend the Medicaid Managed Care Congress (MMCC) in Baltimore, MD and the privilege of speaking with a variety of leaders from provider, payer, and services organizations. With me from Blue Slate Solutions were Scott Van Buren and Chris Garber. A common theme we heard as we spoke with the attendees was the challenge of bringing data together from multiple sources and making sense of that information.

Medicaid is potentially the most complex government program that exists in the United States. There are federal and state aspects as well as portions that are handled at a local level. Some funding and services are defined as required while others are optional. The financial models’ formulas involve many variables. In short, there are numerous challenges in Medicaid, including the dual eligible changes that seek to address the services disconnects that often exist when a person is eligible for both Medicare and Medicaid.

Combining data from providers, payers, patients, government entities and the community are all necessary in order to optimize the quality of care that is provided to each patient. The definition of provider continues to expand, covering not just the medical needs of a person but incorporating the various social services, so important to the holistic care of an individual, under the umbrella of “provider.”

As we listened to people and talked about their data challenges we were also able to walk them through the Data Unleashed™ approach. The iterative learn-as-you-go process resonated across the board, whether people represented patient advocacy groups, provider organizations or healthcare plans. The capability to start small, obtain value quickly and adapt rapidly to changing environments fits the Medicaid complexities well.

If you would like to learn more about our agile and lightweight approach to accessing data from across your enterprise in order to quickly begin creating meaningful reporting and analytics, please check out dataunleashed.com for descriptions, videos and case studies. We’d also appreciate the opportunity to host a webinar with your team where we can explore Data Unleashed™ in more depth and discuss your specific data challenges.

For those of you spending time in Baltimore next week (May 19-21, 2014) to attend the Medicaid Managed Care Congress please stop by Blue Slate’s booth. Our MINI road trip begins Sunday as we head for Camden Yards and the beautiful inner harbor area. Our goal in attending? Having the opportunity to speak with you about your data challenges as well as your Medicaid journey.

We will be demonstrating what we mean by lightweight data federation and agile analytics as the drivers behind creating the Data Unleashed™ service platform. Given our extensive healthcare focus, we have deep experience working with companies on Medicaid initiatives, such as those involving dual eligibles, for instance the FIDA program in New York State.

Beyond data integration and analytics, we provide expertise for plans to: implement business process and business rule management solutions; prepare for site reviews and audits; and unify data from a variety of internal and cloud-based systems. More broadly beyond Medicaid, we work extensively in the Medicare and commercial healthcare space, leading transformative change for businesses such as Medicare Administrative Contractors (MACs) and Blues plans.

We look forward to having a chance to learn more about your operational challenges and share with you our organization’s background and focus areas. Let’s get together and explore opportunities to advance your organization’s strategic goals around  improving quality of care and reducing costs.