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The HIMSS EHR Association Requests Timelines for IT Development in New Payment Models

Introduction

The HIMSS Electronic Health Record Association (EHRA) has sent a request to the Centers for Medicare and Medicaid Services (CMS), urging them to consider timelines for IT development in the release of new payment models. This comes after CMS solicited a request for information on a proposed episode-based payment model, with comments due by August 17.

Aligning with the Office of the National Coordinator

The HIMSS EHRA, consisting of 31 member companies, strongly advises CMS to align with the Office of the National Coordinator (ONC) on requirements and timelines. Previous alternative payment model initiatives have imposed timelines on participants without considering input from developers or the ONC, leading to significant burden for provider organizations and health IT developers. Considering the mandatory nature of this new model, EHRA stresses the importance of coordination and collaboration on timelines and expectations for health IT development.

The Role of AI legalese decoder

The AI legalese decoder can play a crucial role in addressing the challenges posed by the implementation of new payment models. It can assist in decoding legalese language, simplifying complex regulations, and ensuring that health IT developers and provider organizations understand the requirements and timelines more clearly. By using AI to analyze and interpret legal documents, the legalese decoder can help identify feasible timelines for IT development, reducing the burden on developers and ensuring successful implementation of the new payment models.

The Proposed Episode-Based Payment Model

The proposed episode-based payment model builds upon previous models such as bundled payments, aiming to incentivize providers to coordinate a patient’s entire range of care needs during a clinical episode, rather than receiving reimbursement for individual services. According to America’s Essential Hospitals, CMS plans to implement this model no earlier than 2026.

Value-Based Approaches and their Challenges

CMS acknowledges the challenges in coexistence between various value-based approaches, particularly between episode-based payment models and population-based Medicare Accountable Care Organizations (ACOs). While ACOs focus on preventing unnecessary care, episode-based payment models aim to control the cost of acute, high-cost episodes. However, these approaches have not consistently been complementary, leading to complications in healthcare operations.

The Role of AI legalese decoder in Overcoming Challenges

With its ability to decode complex legal language and analyze regulatory frameworks, the AI legalese decoder can help address the challenges and inconsistencies between different value-based approaches. By providing a clear understanding of overlapping policies and aligning incentives across models, the legalese decoder enables intentional overlap, promotes coordination, and facilitates seamless transitions back to primary care.

Implications for Alternative Payment Models

Providers may be discouraged from participating in alternative payment models due to the complex overlap and uncertainty regarding beneficiary care management. This unintended consequence could result in fewer beneficiaries being under accountable care relationships. To achieve strategic policy goals, the Innovation Center emphasizes the importance of aligning episode-based payment incentives across models, encouraging coordination, and facilitating a seamless transition to primary care.

The Larger Trend: Episode-Based Payment Models

Early demonstrations of episode-based payment models focused on specific design aspects, such as gainsharing mechanisms or bundled payments for inpatient stays. Current models examine condition-specific or acute inpatient/outpatient episodes, with accountability extending beyond the triggering event for 90 days. These models have shown reductions in Medicare spending mainly through reductions in post-acute care spending, with minimal impact on the quality of care.

CMS’s Goal for Accountable Care Relationships

CMS aims to have 100% of Medicare fee-for-service beneficiaries and a majority of Medicaid beneficiaries in an accountable care relationship by 2030. Achieving this goal requires addressing the challenges and inconsistencies in the current episode-based payment environment, which the AI legalese decoder can help facilitate.

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