On Monday, CMS proposed a rule outlining changes to the rules governing accountable care organizations participating in the Medicare Shared Savings Program.
The proposed rules include changes to telemedicine delivery and reimbursement, among a broader discussion of using health IT to improve care.
Here are five things to know about the rule's effect on health IT.
1. The rule underscores CMS' commitment to coordinated care assisted by the electronic exchange of health information across providers. "We believe having a process in place to coordinate a beneficiary's care by electronically sharing health information improves care, and that this helps all clinicians involved in the care of a patient to securely access the necessary health information in a timely manner," reads the rule. As such, the rule proposes a program eligibility requirement for applicants for the Shared Savings Program to outline their plans for improving care coordination using information technology, EHRs and HIEs as part of their application to the program.
Additionally, the rule would also require applicants to describe how the ACO plans to partner with long-term and post acute care providers to improve care coordination.
2. In addition to requiring the plans to implement such technologies and partnerships, the rule also proposes ACOs define and submit benchmarks or performance targets it will use to assess its growth and progress each year, such as projected dates for implementing and adopting IT infrastructure or the number of providers expected to be connected to an HIE each year. "We believe this information would allow us to better understand and support ACOs' plan to put into place the systems and processes needed to deliver high quality care to beneficiaries."
3. CMS' rules also proposes adjusting reimbursement practices for telehealth services. Currently, to be reimbursed for telemedicine, the services have to be on Medicare's list of services and meet a host of requirements for payment, such as restrictions on the originating site of the service and defining "eligible telehealth individuals."
The proposed rule offers the prospect of a waiver of certain Medicare telemedicine payment requirements to encourage more ACOs to utilize telehealth. The rule proposes a waiver that eliminates the current Medicare reimbursement requirement of the patient being located in a rural location at the time of service.
4. To eliminate and reduce the risk of abuse of the waiver, CMS anticipates establishing additional requirements to ensure program transparency, such as requiring ACOs indicate their intent to use the waiver in a CMS-specified form during their application or request for participation renewal. Other requirements include having the ACOs submit written plans on how they plan to use the waiver to meet the clinical needs of their beneficiaries and public reporting of such waivers. Additionally, if CMS were to terminate the participation agreement, the waiver would end on the date of the termination notice.
5. CMS still seeks additional comments from ACOs on the use of health IT and, specifically, telehealth and the possibility of the reimbursement waiver. "We…note that ACOs have flexibility to use telehealth services as they deem appropriate for their efforts to improve care and avoid unnecessary costs….We seek comment on the specific services and functions of this technology that might be appropriately adopted by ACOs," reads the proposed rule.
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