The AAFP recently took advantage of an opportunity to influence CMS regarding a proposal that would expand the use of Medicare data and make it available to "qualified entities" as a performance measurement tool.
The proposed rule,(www.gpo.gov) published in the Feb. 2 Federal Register, reflects additional opportunities associated with the Medicare Access and CHIP Reauthorization Act (MACRA).
"In this regulation, CMS proposes to expand how qualified entities use and disclose data and to explain how qualified entities may create non-public analyses," wrote AAFP Board Chair Robert Wergin, M.D., in a March 23 letter(2 page PDF) to CMS Acting Administrator Andy Slavitt.
"In general, the AAFP is supportive of these proposals since providing these data and analyses has the potential to improve the patient experience of care, improve the health of populations and reduce the cost of health care," he added.
Indeed, CMS wrote in the Federal Register that the proposed changes to the program would be important in "driving higher quality, lower cost care in Medicare and the health system in general" and would lead to more transparency in provider and supplier performance as well as innovative uses of data.
Improvements made to the program -- with input from organizations such as the AAFP -- will "result in improvements to the health care delivery system while still ensuring appropriate privacy and security protections for beneficiary-identifiable data," said CMS.
Wergin told Slavitt that the AAFP and other medical societies are trusted partners that would continue to be responsible for providing "meaningful analysis" to providers.
He added that the AAFP's recommendations to CMS were intended to "strengthen and improve" the proposal.
For instance, the AAFP urged CMS to
- refine the definition of "patient,"
- explicitly define the term "provider" as an individual,
- consider all providers who belong to the same group practice as an entity authorized to receive non-public analyses and data, and
- add explicit permission for the re-disclosure of data for direct patient care and for issues of patient safety.
Wergin also stressed the importance of providers' ability to link to and combine data, and he recommended that all authorized users be held to the same restrictions as the qualified entity.
"This would allow authorized users who are providers with access only to their data to link and combine for the purposes of performance measurement, quality improvement and direct treatment of patients," he said.
For its part, CMS noted in the proposed rule that use by qualified entities of combined patient data likely would lead to "increased validity and reliability of the performance findings through the use of larger and more diverse samples."
For physicians desiring more information about qualified entities, CMS has listed 14 certified qualified entities in the Qualified Entity Program.(www.cms.gov)
As of March 18, the list includes some organizations that collect data in all 50 states and District of Columbia, and also groups such as the Maine Health Management Coalition Foundation, the California Healthcare Performance Information System, Minnesota Community Measures and the Wisconsin Health Information Organization.
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