CMS recently released their Medicare Accountable Care Organization rules for public comment. It’s about 430 pages, in case you are struggling with insomnia.

There is a lot in there, but for those of us in the HIT business, here are a few nuggets:

• Primary care physicians must be exclusive to a particular ACO (specialists can belong to several ACOs). However, at least 50% of the PCPs in an ACO must qualify for meaningful use for the ACO to be recognized by CMS. Hospital systems seeking to become an ACO must either a) employ at least 50% of their PCPs, and thus be able to dictate the EHR adoption, b) persuade, probably through subsidy, enough of their independent PCPs to get on their system, or c) develop a robust EHR strategy and delivery capability that allows independent PCPs some choice in getting to MU. Regardless of the strategy, this just became an even more critical path item for hospital systems. The industry generally agrees that getting small primary care practices to MU is one of the greatest challenges we face.
• The ACO will need to report on 65 quality measures. In even the top tier EHR products, easy and automated reporting on those 65 measures is rare. This requirement will drive a lot of work. The obvious is the IT work around reporting. The less obvious, but maybe more significant, will be the business processes that must be built and operated in order to produce this reporting.
• The ability to transfer patient information between providers, both within the ACO and outside it, is critical. We all know this is a big technical challenge that will require a lot of resource (or billable hours, depending on your point of view).
• The identification of high risk patients so they can be put on a proactive care plan will be a key to ACO success. This presupposes some very robust data architecture and some good thinking around predictive clinical modeling. This will be a booming area in the coming years.

We’ll see how many organizations actually step up to apply for ACO status. Some will see these HIT hurdles as insurmountable. Most will plunge ahead.

HIT players continue to have government mandate tailwinds at their back.