The HIMSS Electronic Health Record Association, a trade association of 46 EHR vendors, has submitted favorable comments on the accountable care organization shared savings notice of proposed rulemaking – highlighting aspects of the proposed rule that would benefit from more health IT utilization.

“The concept of the ACO, with provider accountability for cost containment and quality improvement, represents a real effort towards building a new value-driven healthcare system to address the critical shortcomings in the current payment model,” said Leigh Burchell, vice president of government affairs and public policy for Allscripts and chair of the EHR Association's Public Policy Leadership Work Group.

[See also: Consumer group supports ACO proposed rule.]

“Ultimately," she added, "we need to improve care coordination for individuals, improve population health, and lower the growth in healthcare-related expenditures. ACOs, if established properly, can be an important tool in accomplishing these objectives.”

The EHR Association commented favorably on the general approach to health IT in the propose rules, which nonetheless refrained from being prescriptive on when and how ACO’s would use IT for such areas as care coordination and patient engagement.

“We appreciate that CMS recognized in the proposed rule that ACOs may take different forms and approaches, following different health IT strategies," said Burchell. "But we do request that CMS recognize in the final rule that ACO success will depend on robust IT infrastructure, strong technology leadership, and use of bi- directional, standards-based health information exchange and interoperability.”

[See also: ACOs and meaningful use to go hand in hand.]

While recognizing the importance of accountable care and the promise of ACOs, the Association did comment that it shares the concerns of many industry stakeholders that the ACO Shared Savings proposed rule, as currently formulated, will substantially limit initial participation by constraining the ability of ACOs to invest in needed infrastructure and to operate effectively given the relatively high risk/reward ratio.

The EHR Association identified several other areas in which the ACO Shared Savings proposal could be strengthened, including quality reporting initiatives.

“Our customers – hospitals and physicians’ practices across the country – have reporting requirements related to many different programs already in place or in development," said Carl Dvorak, executive vice president at Epic Systems and chair of the EHR Association. "We hope CMS will recognize and minimize the impact on providers and software developers by aligning and avoiding duplication of measures."

He added that, as EHR vendors, association members "recognize the importance of ensuring that our customers are prepared and successful in supporting new aspects of payment reform and quality measurement. We provide our feedback on ACOs with the hope that we can ensure our customers’ ultimate success should they chose to participate in this program.”

The Association also expressed strong support for CMS’s decision to exclude eligible professional meaningful use incentive payments from ACO shared savings calculations, and proposed extending this exclusion to eligible hospitals as well. Such exclusions would avoid penalizing professionals and hospitals for having previously earned incentive payments.