The aggregated data presents opportunities for commercialization. We currently have contracts with several commercial entities for data sales and are in discussion with others. While the fair market value of chart data has its limits*, the commercialization of data can provide a financial return that is substantially greater than the United Rheumatology Annual Practice Membership fee.
EMR data will however serve a far more important purpose. Policy makers and payers, commercial and government, have introduced their concepts of value and quality and linked these in a movement for pay for performance models. MACRA and MIPS call for new payment models to replace traditional fee for service. Data will be essential to validate a practice’s performance in any contract. The payers will have their sources of data, and we must have ours, and they must be robust and defensible. Thus the principal and most significant reason for participating in the data project is to contribute to the aggregated EMR database that may be analyzed and used to objectively define and then defend the highest level of standard of care for our patients.
The data is used to validate the United Rheumatology guidelines and inform modifications to these guidelines when indicated. The analysis of our aggregated data gives us the power to “intelligently” engage in alternative payment models with CMS and the payers, with a scope ranging from local to national.
Even with MACRA and MIPS posing a January 1, 2017 start date, CMS has not yet published final descriptions of alternative payments models. Physicians will find themselves faced with a potentially daunting task in performing the due diligence needed to make participation decisions. The door will be open to developing our own models as well. United Rheumatology has engaged consultants with national experience with both commercial and government payers, who will help and support us in developing Rheumatology specific models. In every conversation with every consultant, the value of the United Rheumatology MDI data project has been identified and praised, as the data has been described as providing our currency, our blood supply, or our nervous system.
The aggregated data will provide us with “our own” objective evidence to demonstrate that we have succeeded in performing in accordance with the payment model definitions and performance measures and are entitled to the incentives incorporated within those agreements.
*Payments for data may be considered a “transfer of value” under “Sunshine” statute, and limits may be placed by commercial entities based on their estimation of the fair market value of data.
Thus, while IMS and others continue to earn substantial amounts of money commercializing the data that we produce, and still others (CMS) are currently mandating the extraction of our EMR data to enable them to designate our quality and value as healthcare providers and adjust our payments accordingly, United Rheumatology is using our data to work for our practices and our patients in entirely positive ways.