The Federal Trade Commission on April 13 issued a favorable clinical integration advisory opinion letterthe third ever issuedto TriState Health Partners (April 20, p. 14). TriState is a physician hospital organization in Hagerstown, Md., composed of 217 community physicians and the Washington County Hospital Association. Supported by its technology vendor InforMed, Annapolis, Md., TriState developed a claims-driven, Web-based electronic health record for the physician desktop.
Seal of approval
Winning FTC’s nod for EHR collaboration
The EHR provides clinical and pharmacy utilization, laboratory results and compliance data on evidence-based medicine guidelines for 50 medical and nine preventive clinical conditions. InforMeds integration of the software into a single platform that supports more effective medical management and population analytics was key to TriStates integration strategy to promote a high degree of collaboration and mutual interdependence among the physicians that was unlikely to be achieved within the current fragmented care-delivery model.
TriStates journey to clinical integration began with the desire to create a care model that promoted population health improvement for the community. Over the next three years, TriState created the necessary infrastructure. It developed a comprehensive medical management program. Through development of the EHR, TriState also enhanced its capabilities in predictive modeling, client return-on-investment analysis and medical management outcomes tracking, and boosted its operating staff.
Concurrently, TriState developed and implemented a highly successful three-year longitudinal diabetes disease-management program that served as proof-of-concept for the FTC. Over the study, all clinical, utilization and financial indicators moved in the right direction, such as decreases in admissions by 20%, inpatient days by 29% and emergency room visits by 19%. The one metric expected to increaseevaluation and management of physician office visitsrose by 15%. The right care was directed to the right setting with the right clinical and financial results. The health plan enjoyed savings of $160,000, half of which was awarded to the physicians.
In late 2005, TriState retained Ober Kalerthe law firm that secured the two other favorable FTC opinionsto represent TriState before the FTC. TriState submitted its advisory opinion request in July 2007, and the FTC responded in January 2008 with a request for additional information. Several physician-led governance committees were engaged in drafting the response submitted in July 2008.
TriState pursued the FTC opinion because of the potential market power concerns, as the PHO is composed of a sole community hospital and about 64% of the communitys physicians. To alleviate those concerns, TriState assured the FTC it would be a nonexclusive network. Also, TriState wished to reassure everyone of its antitrust compliance. Seeking an advisory opinion would provide a comfort level for physicians, the hospital and payers.
Phase one of TriStates journey, securing the favorable advisory opinion, has been accomplished. Phase two, projected for completion by November 2009, includes: re-contracting with the physicians to ensure commitment to the program; development of a value-based purchasing program; and physician/office staff education on the technology tools and the program participation requirements.
A major lesson is that the value-based purchasing program should have been developed much earlier in the process. Phase three will be engaging the local health plans, employers and broker community to participate in and support the program.
The advisory opinion notes that TriStates program has the potential to create substantial integration among the PHO members, improve quality, and yield more cost-effective care and that joint contracting with payers is reasonably related to achieving those efficiencies. Through the EHR, TriState has turned data into information. TriStates clinical integration program will be measured by the success of all stakeholders turning that information into action, defined as demonstrated superior care at demonstrated superior cost.
Allan Field is the executive director of TriState Health Partners and the executive for business and payer relations for the Washington County Health System.
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