Aligning Financial and Other Incentives: Strategies and Actions
STRATEGY
1. Create demonstration projects and private payer pilots to develop and test strategies for aligning incentives.
ACTIONS
1.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Federal Agencies, Researchers and/or NGOs should perform an independent evaluation to quantify and account for all of the costs incurred and benefits received by specific stakeholders from the adoption and effective use of health IT by providers. The results of this study should be utilized to inform future policy decisions. (2008-2009, and ongoing)
STAKEHOLDERS
Federal Agencies
NGOs
Public Health, Researchers, Etc.
1.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
CMS should consider expanding the DOQ-IT program in 2008 to include a “pay for use” pilot that would provide a one-time bonus payment to small physician practices post-implementation of a certified system when the physician demonstrates proper use of functionality, evaluating whether higher quality outcomes were achieved as a result of such use. The pilot should also explore the most appropriate definition of a “small” practice. (2008)
STAKEHOLDERS
Federal Agencies
1.3
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Federal Agencies, including CMS, should consider introducing a demonstration project (using provider submitted add-on codes) that evaluates the impact on the quality or efficiency of care of additional reimbursement for providers that use information from an active health data exchange (basic, intermediate and advanced levels of functionality). At a basic level, the provider might access information (such as laboratory results or medication history) electronically through a portal or electronic health record. At an intermediate level, the provider might demonstrate the ability to transfer clinical data electronically to other providers, plans or patients. At an advanced level, the provider might document the use of such information to support functions such as decision support, patient reminders, e-consults, or e-prescribing. (2009)
STAKEHOLDERS
Federal Agencies
1.4
2007
2008
2009
2010
2011
ONGOING >>
ACTION
The Federal Government and other payers (Health Plans) should consider establishing a demonstration program in which provider recognition and reward is based on achieving quality, cost and service objectives, and a certain percentage of which is dependent on implementation and use of EHR systems and information from other sources. The percentage dependent on EHR use decreases over time. The program could be coupled with financial assistance from the federal government for small providers to implement an EHR. The definition of “small” provider should be explored, studied and further defined. (2008-2010)
STAKEHOLDERS
Federal Agencies
Health Plans
1.5
2007
2008
2009
2010
2011
ONGOING >>
ACTION
As preferred networks begin to proliferate in 2008, Employers and Health Plans should consider using documentation of implementation and use of certified EHR and participation in health information exchange as important criteria, among others, for network inclusion. (2008)
STAKEHOLDERS
Health Plans
Payers (Employers/Purchasers)
1.6
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Health Plans, Federal Agencies and NGOs should share, and eHI and other NGOs should publicize in an ongoing manner, the results of various pilots and demonstrations regarding incentives for HIT adoption and quality improvement, measuring the impact on EHR uptake, especially among small providers, as well as the cost to Health Plans. (2008-ongoing)
STAKEHOLDERS
Federal Agencies
Health Plans
NGOs
1.7
2007
2008
2009
2010
2011
ONGOING >>
ACTION
As EHR adoption evolves to support effective quality and efficiency improvements, demonstration projects from Health Plans and the Federal Government should evolve to test other more broad payment reform strategies. (2009-2011)
STAKEHOLDERS
Federal Agencies
Health Plans
STRATEGY
2. Implement provider recognition strategies to encourage effective use of certified systems.
ACTIONS
2.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
NGOs, in partnership with providers, Health Plans and other stakeholders, should develop mechanisms to measure effective use of information from EHRs in both hospital and physician office settings. (2008-2009)
STAKEHOLDERS
Health Plans
NGOs
Providers/Provider Organizations
2.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Health Plans should consider listing in their directories those providers who have adopted certified EHR systems and are using them effectively, based on consensus measures of effective use. The listing should include an explanation to members about the significance of the EHR to patient care, impact on quality, and facilitation of improved patient access to the system. (2009)
Consumer Organizations should provide additional education about choosing a physician with an EHR and using quality ratings. (2008)
State and Community HIE Collaboratives should work with Health Plans to indicate physician participation in an HIE initiative and communicate that information to consumers through these directories. (2011)
STAKEHOLDERS
Consumer Organizations
Health Plans
State and Community HIE Collaboratives
2.3
2007
2008
2009
2010
2011
ONGOING >>
ACTION
As the use by providers of certified and interoperable EHR systems becomes more prevalent in a geographic area, those who sponsor health plans (Employers) should consider implementing member financial and other incentives to encourage consumers to select practices and hospitals that use certified EHR systems, among other things. (2009)
STAKEHOLDERS
Health Plans
Payers (Employers/Purchasers)
STRATEGY
3. Work with malpractice carriers to develop risk reduction strategies to lower malpractice insurance premium rates for providers who implement and effectively use certified systems to improve quality and safety.
ACTIONS
3.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Provider Organizations and other NGOs should work with the malpractice insurance carrier industry to collect actuarial evidence of the benefit of health IT use by providers. (2007-2008)
STAKEHOLDERS
Health Plans
NGOs
Providers/Provider Organizations
3.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Malpractice insurers should calculate a premium discount that reflects the proportionate savings. (2008-2009)
STAKEHOLDERS
Health Plans
3.3
2007
2008
2009
2010
2011
ONGOING >>
ACTION
NGOs and Provider Organizations should identify and publicize the names of malpractice carriers in various states who already provide premium rate reduction for providers who implement certified systems. (2008)
STAKEHOLDERS
NGOs
Providers/Provider Organizations
3.4
2007
2008
2009
2010
2011
ONGOING >>
ACTION
NGOs, such as HITSP and HISPC, should work with industry stakeholders to establish standards for compliance functions in an EHR, so that all EHRs have proper compliance controls in place (e.g. inability to turn off audit controls, etc.). (2007-2008)
STAKEHOLDERS
NGOs
3.5
2007
2008
2009
2010
2011
ONGOING >>
ACTION
CCHIT should certify EHRs against these legal and compliance standards. (2009)
STAKEHOLDERS
NGOs
STRATEGY
4. Educate small practices and small hospitals to empower them to make wise purchasing decisions and provide them with the tools to make necessary workflow changes to improve the health and healthcare of their patients using EHRs and health information exchange.
ACTIONS
4.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
CMS should increase QIO funding for the DOQ-IT program and provide personalized support for additional small physician practices. (2008)
STAKEHOLDERS
Federal Agencies
4.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
CMS should expand the QIO program to assist additional small hospitals with the effective use of CPOE and EHRs to promote higher quality healthcare. (2008)
STAKEHOLDERS
Federal Agencies
4.3
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Quality Organizations (QIOs) and Provider Organizations should help all providers, and especially small and rural providers, to make wise purchasing decisions, leveraging certification and other programs and ensuring that an EHR is able to capture the right data to participate in quality reporting or improvement incentive programs. (2008-ongoing)
STAKEHOLDERS
Providers/Provider Organizations
Quality Organizations
4.4
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Quality Organizations (QIOs) and Provider Organizations should help educate providers on the cost and value of system acquisition and care process redesign, as well as value derived from increased data capture, improved administrative efficiencies, and ability to participate in quality reporting or improvement incentive programs. (2008-ongoing)
STAKEHOLDERS
Providers/Provider Organizations
Quality Organizations
4.5
2007
2008
2009
2010
2011
ONGOING >>
ACTION
State Governments should provide grants to small hospitals and small practices to help offset the cost of EHR acquisition and health information exchange and facilitate group purchasing and education. (2008-2009)
STAKEHOLDERS
State/Local Government
STRATEGY
5. Implement tax incentives to encourage improvements in health and healthcare through HIT adoption by physicians in small practices and small hospitals.
ACTIONS
5.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Federal Agencies and NGOs should study the impact of providing tax incentives for small and rural providers to adopt HIT and use it effectively. (2008)
STAKEHOLDERS
Federal Agencies
NGOs
5.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Congress should consider instituting tax incentives for small and rural providers to adopt HIT and use it effectively. (2009-2010)
STAKEHOLDERS
Congress
5.3
2007
2008
2009
2010
2011
ONGOING >>
ACTION
State Governments should offer tax incentives to or small and rural providers to adopt HIT and use it effectively. (2008-2009)
STAKEHOLDERS
State/Local Government
5.4
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Federal and State Governments should consider creating low cost guaranteed loans and a loan forgiveness program where small providers can receive low-cost loans from federal and state dollars, administered by a private sector entity. Low cost loans could be used to purchase certified HIT systems. For providers meeting a minimum set of benchmarks in practice/provider performance improvement, a portion per year of the loan is forgiven for each year the provider meets the benchmarks. (2009-ongoing)
STAKEHOLDERS
Federal Agencies
State/Local Government
5.5
2007
2008
2009
2010
2011
ONGOING >>
ACTION
NGOs should study the feasibility and benefits of tax incentives to employer groups and plans to financially incentivize providers (in a meaningful way) to encourage adoption and effective use for quality improvement. (2008)
STAKEHOLDERS
NGOs
5.6
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Based on the results of the study above, Congress should consider instituting tax incentives for employers and plans that provide meaningful incentives. (2009)
STAKEHOLDERS
Congress
STRATEGY
6. Examine HIEs that are sustainable and study the data to identify exact sources of sustainability and provide a how to guide to sustainability, recognizing that one size doesn’t fit all.
ACTIONS
6.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Federal Agencies (such as HRSA and ONC) should fund research and development of lessons and tools to support sustainability of HIEs (2008)
STAKEHOLDERS
Federal Agencies
6.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
NGOs should work directly with successful and unsuccessful HIEs to study their processes for creating the organization, identify and learn from business models, and create models for ongoing sustainability. (2008)
STAKEHOLDERS
NGOs
6.3
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Based on this research, NGOs should develop guides and tools to support sustainability that are adaptable to individual HIE network needs. (2009)
STAKEHOLDERS
NGOs
STRATEGY
7. Provide grants and loans to offset start up costs of exchanges in geographic areas where no or limited data exchange currently exists.
ACTIONS
7.1
2007
2008
2009
2010
2011
ONGOING >>
ACTION
Congress should establish a matching funds loan program for states to make initial low cost loans to start-up HIEs in areas where no or limited HIEs exist. Funding should be available to allow providers to acquire the systems/infrastructure needed to connect to the exchange. (2008)
STAKEHOLDERS
Congress
7.2
2007
2008
2009
2010
2011
ONGOING >>
ACTION
NGOs (philanthropies) and Federal Agencies should continue to fund early developmental phases of HIEs, tied to specific performance goals and deliverables to help ensure sustainability. (2008-ongoing)
STAKEHOLDERS
Federal Agencies
NGOs
STRATEGY
8. Harmonize and leverage efforts of current organizations that are creating evidence-based performance measures to maximize impact, streamline and standardize reporting.
