HHS / CMS ambulatory Care Initiatives

Last Fall, Secretary of HHS Michael Leavitt announced several initiatives to foster ambulatory care system adoption and use by small- and medium-sized practices. In addition to the certification initiatives designed to assure stability and value, the Federal Government has also announced several other important elements to ambulatory practice.

• CMS completed its proposed rules on e-prescribing (CMS-0016-P). These are available online at http://www.cms.hhs.gov/EPrescribing/.
• The FCC awarded significant sums for rural connectivity. A press release on the broadband initiative is available at: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-278125A1.doc.
• CMS announced ambulatory care pilot programs. The link to this initiative is available at: http://www.cms.hhs.gov/DemoProjectsEvalRpts/MD/itemdetail.asp?itemID=CMS1204776
  

Little information is yet available on the latter pilot. The HHS page says:

CMS is developing a new demonstration initiative that aims to reward delivery of high-quality care supported by the adoption and use of electronic health records in physician practices. This initiative expands upon the foundation created by the Medicare Care Management Performance (MCMP) Demonstration. The goal of this 5-year demonstration is to foster the implementation and adoption of EHRs and health information technology (HIT) more broadly as effective vehicles not only to improve the quality of care provided, but also to transform the way medicine is practiced and delivered.

Additional documentation suggests that the program will be awarded through the Medicare waiver process. The goal would be to foster adoption and effective use in order to improve care quality and to transform medical practice and delivery. It is designed to leverage the force of private and public payers to drive physician practices to widespread adoption of EHRs.

Participating physicians will be required to have a certified CCHIT-EHR in the second year. They must demonstrate utilization of the EHR to support core functions that may include clinical documentation, laboratory testing, and prescription management. But the core incentive payment "will be based on performance on the quality measures, with an enhanced bonus on the degree of HIT functionality used to manage care."

The demonstration project is designed to be operational for five years. Year one payments wil be based on degree of use (and sophistication, including "sharing of records among providers of care") Payments will be determined by the Office Systems Survey. Payments in year two will depend also on reporting quality measures, and in outlying years will then be based on performance on the designated clinical quality measures with an "added bonus each year based on the degree to which the practice has used the EHR to change and improve the way it operates."

The Memphis, Tennesse area is one of many likely candidates for such a program within the state. It's attributes include:

• A functioning data exchange involving all of the major hospitals and some major clinics (with records on 950,000 individuals)
• A strong ASP provider base and experience with multiple platforms for ambulatory care including Allscripts, Cerner, eClinicalWorks, and NextGen.
• A new program - NetTN to provide additional support for connectivity to practitioners
• Strong support from State Government

With or without federal support, independent of political persuasions or philosophy, the challenges have moved beyond technical standards and now are more cultural and policy-driven. They include:

• True connectivity with laboratories, pharmacies, and other providers
• Data privacy and security
• Data exchange operating policies
• Meaningful transparency
• A critical mass of data for appropriate alignment of incentives
• Meaningful quality metrics
• Comparable pricing and quality information
  
• Patient engagement

There is sufficient momentum, this writer believes, to focus on key areas of concern and begin the challenging job of implementing and demonstrating value. These challenges are addressed primarily through local issues but also require support at the state and federal level.

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