As the founding Chairman of the Wisconsin Health Information Organization (WHIO) it's encouraging that we may be getting closer to adding Medicare data to the all payer data bases being created in the U.S.Two significant problems still exist however.
The problems are 1.The cost of accessing the data 2.The timeliness of the data
As the following article in Modern Healthcare points out organizations such as WHIO must purchase the data from Medicare, a cost of up $270000. WHIO and other all payer claims databases across the country are not for profit organizations held together with bailing wire and goodwill. This type of financial burden could tip some in the wrong direction. We need just the opposite, we need them to the thrive and grow and we need more of them. It's important for CMS to recognize that getting this data to the providers through trusted sources such as WHIO and other qualified reporting entities will have a huge impact on cost improvement. Making the financial burden for access steep is counterproductive to CMS' goals.
Timeliness? For 200K Qualified Entities get 2008,2009, and 2010 data. That's old news by 2012 which is when entities such as WHIO get access. In Wisconsin we developed a process which delivers the data as a 27 month rolling average updated every six months.If we can do it with Medicaid and Commercial data why can't CMS do the same with Medicare claims data?
These suggestions are written with appreciation that CMS is now working on this very important issue. We need to go a few steps further. The Center has been working with a handful of CMS officials on this and remains willing to share any and all expertise gleaned from our experience in Wisconsin.
The following is the Modern Healthcare piece.
By Maureen McKinney
Posted: June 13, 2011 - 12:01 am ET
Medicare is poised to open its cache of claims data to organizations that produce healthcare quality reports, a long-awaited move that promises more accurate and complete views of provider performance.
But many of the regional groups that want the data say the proposed price tag may stand in the way of their participation.
“The costs are prohibitive,” said Julie Bartels, executive director of the Wisconsin Health Information Organization, a De Pere-based not-for-profit organization that has amassed claims data for more than 3.7 million of the state's residents. “Most of the organizations that would participate are non-profits that are running very lean operations, and those fees would be hard for them to consider.”
Placing the burden of those fees squarely on the shoulders of small, not-for-profit organizations is not sitting well with many groups like Bartels'. They argue that all stakeholders, including providers, patients and the CMS, will benefit from the reports they produce and the quality-improvement and cost-cutting opportunities they identify.
Mandated by the Patient Protection and Affordable Care Act, the proposed rule would require the CMS to provide extracts of Medicare claims data to qualified entities for reports detailing the performance of hospitals and physicians.
For the program's first year, the CMS estimates that about 35 organizations will apply and approximately 25 will make it through the approval process. The majority of those entities, the CMS said, will probably be existing not-for-profit community collaboratives that already use private-payer and Medicaid claims data to evaluate providers.
Many of those organizations, such as the Wisconsin Health Information Organization, are multistakeholder and incorporate feedback from providers, payers, employers and consumers.
But a major roadblock for interested groups could be the fees required to obtain Medicare's data set. In the proposed rule, published in the June 8 Federal Register, the CMS acknowledged that costs would vary based on the amount of information requested, but it estimated the fee—which covers the cost of data, technical assistance, application processing and monitoring—to be roughly $200,000 for three years of data for 2.5 million beneficiaries. Fees for three years of data for 5 million beneficiaries could run as high as $275,000, the agency said.
“That amount would not be feasible for us without going back to our members and subscribers and raising costs,” Bartels said. “That might stop them from participating altogether.”
Costs aside, the release of Medicare data for public reporting is a big step in the right direction, according to officials from many of the regional collaboratives. Organizations such as Bartels' have significant data from the commercial market, but a complete lack of Medicare data.
Access to that data set will enable those groups to produce reports that are much more reflective of total patient populations, Bartels said. But only if they can afford it.
“At this point, it appears that CMS is looking to all of the other entities to support the cost of this program,” Bartels said, adding that her organization is tentatively planning to apply for a spot, based on the provisions of the finalized rule. “We'll offer our comments and see what the response is.”
Nancy Foster, the American Hospital Association's vice president for quality and patient safety, said the AHA's members have spoken highly of many regional quality organizations. Those organizations have been working at a big disadvantage, she said, because without Medicare information, they have been blind to a huge amount of data.
Granting access to that information could help those groups find opportunities for improvement, and it could also help them to more accurately gauge the frequency of very rare adverse events, such as wrong-site surgery. “You need a fairly large data set to do that,” Foster said.
Foster also expressed concern that the proposed costs seemed high and the application process looked cumbersome, barriers that she said could prove difficult for some organizations to overcome.
The Pacific Business Group on Health, a San Francisco-based business coalition, praised the proposed rule as a means of achieving greater transparency and bolstering public-private cooperation, said Jennifer Eames Huff, director of the PBGH's consumer-purchaser disclosure project. That public-private partnership allows for more “reliable, granular-level reporting,” she said.
Huff also said the PBGH is considering applying to be a qualified entity, but has not yet made a decision.
For many of these groups, however, the high data fees seemed especially exorbitant because the resulting reports will be useful for everyone, including the government.
“This data will produce value for CMS because it will help healthcare providers see where there are opportunities for cost reduction, and it will help them participate in accountable care organizations and other delivery models,” said Harold Miller, president and CEO of the Network for Regional Healthcare Improvement, Pittsburgh, a national membership association for regional health improvement collaboratives.
In a September letter to the CMS, NRHI and its members provided a list of recommendations for making Medicare claims data available. The letter urged the CMS to keep data fees as low as possible, “recognizing that collaboratives are non-profit agencies which are using the data to help improve the quality and lower the cost of healthcare for Medicare beneficiaries.”
If the proposed fee structure remains unchanged in the final rule, Miller said, the regional collaboratives that have more resources and stronger community support may be able to come up with the necessary cash. But others—particularly those whose member providers have tighter margins—may be unable to participate.
“CMS may be creating harm by setting the cost bar so high because communities will be busy trying to find money instead of setting improvement priorities,” Miller said, adding that the cost of data is only one of several big expenses. “You have to spend money on analysis and you have to invest money in hiring staff who know how to process the data.”
Oregon Healthcare Quality Corp., Portland, will probably apply to qualify for the data, despite the cost burden, said Mylia Christensen, the group's executive director. Medicare claims data has been on the organization's wish list for some time, Christensen said, and she predicted they would do what they needed to do to get it.
Still, she said she hoped the CMS would realize the overall benefits of releasing the data and relax on the fees.
“We see the audience for this information as a cross section of stakeholders,” Christensen said. “I'm assuming CMS has the same interests and would benefit. I hope that over time, as they see the value, those costs might be reduced or eliminated.”
Other concerns about the rule include the timeliness of the data. The CMS proposed providing qualified entities with the three most recent years of Medicare data available at the time an organization is approved for participation.
In 2012, for instance, an approved organization would receive data for 2008, 2009 and 2010. After that first year, qualified organizations would receive an additional year of data on an annual basis.
But as more hospitals and physicians enact big changes and the evolution of the healthcare delivery system accelerates, 3-year-old data just won't cut it, said Miller, of the Network for Regional Healthcare Improvement.
“Data from three years ago won't help providers understand opportunities for improvement today,” he said. “When you're trying to form an ACO, you need the most accurate and current information.”
Another concern is the proposed rule's restrictions regarding performance measures, said Christopher Queram, president and CEO of the Wisconsin Collaborative for Healthcare Quality, Middleton. Applicants must prospectively identify the measures they plan to use, and if they want to make changes, they must submit additional information to the CMS.
“Most people would acknowledge that performance measures—and particularly measures that use large databases—are still in their infancy, and some degree of experimentation is important,” Queram said. “There needs to be a balance between using established measures and allowing for that flexibility. That would be another area where I would expect to see a lot of comments.”
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