15 Jul Task Force Comments on LAN Population-Based Payment Work Group’s Data Sharing White Paper
The Task Force supports innovative, person-centered, value-based payment models and recognizes the importance of data sharing to drive improvements in cost and quality under these models. We believe the principles put forth in the LAN Population-Based Payment Work Group’s white paper are directionally consistent with the data sharing needs we believe are essential for the successful operation of population-based payment models, including an emphasis on transparency, collaboration across the care continuum, and patient-centeredness. Further, we posit that any accountable entity requires a complete, patient identifiable data set to effectively manage triple-aim goals.
While we understand the work group’s intent to focus on the “who,” “what,” and “why” of requisite data arrangements, we support the further specification of options and endorsement of meaningful recommendations to address the “how” of each arrangement. Considering the high rates of EHR adoption among hospitals and office-based physicians, we are now at a place where greater specificity is necessary to drive usability and optimize functionality.
Task Force Summary Response
1. Stakeholder communication regarding privacy and security. The Use Cases appropriately describe the potential benefits for purchasers, payers, providers, regulators, researchers, and patients when health care data is made available to support improved health system performance. We have found that some groups may need more targeted and cogent information to gain an appreciation for that benefit.
2. Consent Policies. Purely opt-in consent policies have proven prohibitive in reaching the goals discussed in the White Paper. Further, the variation in consent policies and/or regulatory requirements among states, providers, payers, and data types can cause confusion and subsequently low rates of data sharing due to onerous or unnecessary policies.
3. Practical Considerations. We believe that payers, purchasers and providers must continuously improve access to complete, accurate, reliable, timely data. Yet, the cost and burden for providers to access, aggregate, and exchange clinical information from their certified electronic health records for population health and care coordination purposes – even under a public utility model – can be exorbitant.
4. Transparency. In principle, we support the goal of making population-level data available and transparent among health care stakeholders. We also recognize that health care stakeholders can be differentially mandated to participate in data aggregation or transparency efforts
Read the letter for the Task Force full response to the LAN Population-Based Payment Work Group’s Data Sharing White Paper.
Letter submitted on July 14, 2016