Proposed regulations for becoming an accountable care organization have drawn harsh criticism from nearly every direction. Several healthcare associations have individually and publicly described the regulations as essentially too difficult to be realistically workable – and seven U.S. Senators have said the ACO program is doomed to failure.
Is the ACO model simply supposed to be intimidatingly stringent in the early phases?
Bruce Henderson said that answer, at least in part, is “yes.”
Henderson, the national leader of PricewaterhouseCoopers' EHR/HIE practice, spoke with Government Health IT Editor Tom Sullivan about the grinding nature of ACOs, the industry's overproducing units of care, and ACO challenges particular to government health agencies and the IT shops who support them.
Q: To address one of the main criticisms of ACOs, can providers realistically meet expectations according to the ACO regulations as they stand today – which call for, among other things, 65 performance measures within the year?
A: I think that the regulations are intended to be pretty onerous and grinding for a reason. I believe the intent was to limit the participants initially and focus on the elements that people agree are central for success to make sure that those providers that participated in the initial pilots would be exactly that – successful. I don’t think the government wants any massive failure during the initial pilot phase. They wanted to make sure to have the right pieces for ACOs in place, and working well to produce the kind of results they’re expecting.
It’s going to be a challenge for most organizations to be able to meet those kinds of requirements in such a short period of time. There’s a lot of transformation that needs to occur. But to that exact same point, I think the government isn’t necessarily looking for everyone to meet those requirements during the pilot phase and they’re really looking for a chosen few to demonstrate the value proposition.
Q: Detractors are saying that ACOs simply won’t work because too little incentive exists for providers to meet those requirements and, indeed, they can make more money under a fee-for-service model.
A: That may be the case. It may also be that the industry as a whole is overproducing units of care – visits, exams, tests – but I think the government has laid down a path of changing that model of payment and creating a value-based purchasing system and one that is focused on quality and efficient results against fixed payments. So the incentives of today are clearly going to change. They need to change. One of the underlying purposes of the ACO is payment reform.
[See also: The 4 ACO aspects that boost population health. Related Q&A: The good, bad, and otherwise of ACO regs.]
The meaningful use regulations have put into motion a certain amount of enabling ability to change the care model to become more efficient and connect with the patient in a more engaging way. But meaningful use and the HITECH Act don’t adjust the payment model. We’re still paying in a fee-for-service arrangement, and the ACO regulation is part of the first step in adjusting and creating true payment reform.
Q: What are the most concerning privacy and security issues with ACOs?
A: The privacy and security issues that will emanate from an ACO are the same privacy and security issues that we have in meaningful use Stage 1 and Stage 2. In Stage 1, we have the privacy and security issue of moving from paper records to electronic media and the ability of accessing records via electronic medium, the ability to copy data, that kind of stuff. When we start to look at interoperability, in Stage 2, the nature of connectivity across communities and the ability to actually move that data within a community of providers who have a reason to share information about a single patient and to aggregate that information in a single location so it tells a more complete story about the patient to render better, faster decisions. And so Stage 2 regulations, when they’re published, we expect to in a major way address the privacy and security issues around that record. That’s the location where privacy and security issues should be addressed.
Q: Are there any ACO challenges unique to federal, state and local health agencies?
A: Within the various federal care delivery agencies, I think that the treatment of populations has been a function of the way these organizations behave for many years. They were organized to serve a population, rather than a patient at a time, and those populations have been automated now for a good number of years. So there are results and best practices that can be measured. In the interaction with (an) ACO, facilitating that information-sharing across communities outside a federal agency and within provider systems in a particular community is going to become very, very important.
As we move forward with all the new challenges that regulatory compliance brings to us, and as we keep the patient at the center of the focus, our collaboration, our discussions, our concerns for privacy, our ability to provide better service, that will achieve the best outcome. That’s where we break down the walls of competitiveness to focus on what’s best for the patient and how we bring about that care as quickly as possible. Those vehicles for collaboration are going to be increasingly important across the country. There are many federal healthcare initiatives and some means of capturing those lessons and communicating that to the private side of the industry would be incredibly valuable. We need to look at ourselves as more common than different and I think we need to learn as much as we possibly can from all aspects of how healthcare is delivered, whether it's within a structured agency setting or a private hospital system environment. And so I think that’s a challenge for the federal agencies to take up and provide some leadership around.
