Accountable Care Organizations as Drivers for Trusted and Valued Information Sharing

June 6, 2011 | Collaborative Comment
Markle Connecting for Health

These collaborative comments encourage CMS to support a culture of quality improvement and trusted information sharing through the Accountable Care Organization Program.


Markle Connecting for Health, a public-private collaborative of more than 100 organizations across the spectrum of health care and information technology (IT), appreciates the opportunity to comment on Accountable Care Organizations (ACOs) within the Medicare Shared Savings Program.

The basic concept of an Accountable Care Organization represents a needed shift in priorities for transforming the health sector toward more continuous and cost-effective care. The proposed rule sets three broad and ambitious aims of better care for individuals, better health for populations, and lower growth in expenditures.

In this letter, we build upon our past collaborative comments on how the Department of Health and Human Services (HHS) can foster the trusted information sharing necessary for ACOs to succeed. We focus only on key ingredients for the health information sharing and information technology components of ACOs.

These comments are limited to the health IT and information sharing aspects of the proposed rule. Clearly, many legitimate questions and concerns about ACOs fall outside this limited area. Regardless of how these other issues are addressed and resolved, information sharing will be a core requirement for achieving the goals of the program. In that regard, we comment on four distinct categories:

  • Improve decision making throughout the care continuum by leveraging the insights gained from the data received from ACOs.
  • Align with and build from the investments in Meaningful Use.
  • Adopt and implement a complete trust framework based on Fair Information Practices (FIPs) that is consistent with the shared set of policy and technology principles developed by the Federal Health IT Task Force.
  • Engage patients through improved access to their own health information.