August 2, 2024

RE: 21st Century Cures 2.0 RFI

Submitted via email to cures.rfi@mail.house.gov

Representatives Bucshon and DeGette,

On behalf of Accountable for Health we appreciate the opportunity to respond to the request for information regarding the 21st Century Cures Act and Cures 2.0. Accountable for Health is a non-partisan, national advocacy and policy organization accelerating the adoption of effective accountable care. We aim to inform policy that advances the movement in the health care system toward accountable care that achieves better outcomes, improved care experiences, increased access and lower costs.

Alternative payment models improve patient care by fostering coordinated approaches to managing patient populations. They aim to achieve better health outcomes while controlling costs. Accountable care models have demonstrated success by improving health outcomes and lowering costs. Population health data is an essential component of success in accountable care, offering insights and metrics that are crucial for effective care management and quality improvement.

Participating in accountable care requires investment in health information technology. Elements might include:

• Data Integration Platform. The ability to ingest and interpret health records, claims, and health information exchange data from multiple payers is imperative to success. To develop data infrastructure, a practice must invest in the data platform itself and additional staffing, either by building an in-house data team or by licensing out. Data integration costs are higher for unaffiliated practices that use different electronic medical systems.
• Care Pattern Analysis Software. Care pattern analysis software is necessary to effectively track and assess patient care. These platforms, in the form of population health software or workflow support, are commonly licensed on a per-patient-per-month basis.
• Workflow Redesign. Electronic medical record systems may need to be upgraded to include workflows designed for population health management.
• Technology Start-up Costs. The software described above will include modules for administrators to track key performance indicators and care teams to identify gaps in care and stratify patients according to their risk profiles. Users require initial training, and ongoing costs related to administration and care delivery will arise.

Since the enactment of 21st Century Cures and subsequent pieces of legislation, the health information technology landscape has shifted dramatically. In addition, the development of innovative care delivery models has progressed substantially, incorporating new technologies, information and partnerships that enable accountable care entities to improve health outcomes and care experiences.

A4H recommends that future legislative efforts in this area incorporate health information technology provisions that accelerate the adoption of accountable care, making it simpler and more streamlined for accountable care participants to access and share population health data, and providing supports for infrastructure to better leverage health information to advance the goals of accountable care.

Sincerely,

Mara McDermott
CEO
Accountable for Health