By: Ann Meehan

The transition from fee-for-service to value-based care and reimbursement is at the top of major health care industry leaders’ lists of trends and challenges for 2017.

Health care experts often debate what it will take to make the transition successful in the new payment model, discussing everything from care models to technology solutions. However, the integrity and trustworthiness of the health care organization’s data and information should be a main focus of these discussions. This is why information governance is imperative.



Information governance provides the formalized framework around all decisions about information collection, use, reporting and sharing. Given the evolving world of technology, health care organizations can no longer assume that their information is accurate and usable and, therefore, should direct their efforts toward implementing this framework. Organizations must put the best policies, procedures and processes into place as an organized approach to manage information and to make more informed clinical and business decisions. It is their ethical obligation to do so.

AHIMA’s Information Governance Adoption Model addresses every aspect of managing and overseeing decisions around information.

A strong IG program is particularly important to the nuances we are finding in value-based care programs, or those that reward health care providers with incentive payments for the quality of their care provided. These programs are part of our larger quality strategy to reform how health care is delivered and paid for, providing better care for individuals, health populations and lowering costs for all parties involved.

Trustworthy data and information are at the center of what is required for value-based care in order to provide quality care, address care coordination, consistent follow-up and reporting of required data to CMS, as well as other payers who follow suit. A formalized information governance program provides the infrastructure around all data and information decisions to ensure that a provider can offer quality patient care and meet all reporting requirements.

Value-based care programs have been in place in various models for a number of years, including the: Hospital Value-Based Purchasing (HVBP) Program; Hospital Readmission Reduction (HRR) Program; Physician Value-Based Modifier (PVBM) Program; and Hospital Acquired Conditions (HAC) Program. New programs, such as the Alternative Payment Models (APMs) and Merit-Based Incentive Program (MIPS), are expected to be implemented in 2019.

While the focus of all value-based care programs is to improve the quality of patient care and reduce costs, shifting from reimbursement that is based on quantity to quality, let’s focus on a couple of specific programs and their requirements.

Starting with the Hospital Readmission Reduction (HRR) Program, CMS indicates that “there are many things hospitals are doing to lower the rate of readmissions, including:
• Focusing on better coordination of care and communications between providers, and patients and their caregivers.
• Improving discharge planning, education and follow-up for discharged patients.
• Using electronic medical records to share information and provide continuity of care.



MIPS states that eligible clinicians (EC) who choose to participate “earn a performance-based payment adjustment to Medicare payments.” ECs must show high-quality, efficient care, using technology in these areas: quality; improvement activities; advancing care; and cost. Data in support of these four areas are to be collected and submitted Jan. 1, 2017, through Oct. 2, 2017. Payment adjustments begin Jan. 1, 2019, and are based on performance and the amount of data submitted in 2017.

These programs dictate an exchange of accurate, correct and timely information that is readily available and is protected. Discharge planning and follow-up to ensure patient compliance requires a formalized process to accomplish the exchange between EC and patient, as well as documented results. The use of electronic medical (health) records needs to be governed to ensure that the information collected is accurate and meaningful and is readily available in a useable format for making patient care decisions. This is why the information governance competencies of enterprise information management (EIM) and IT are critical to ensuring that all enterprise-wide information and technology is in place to provide the best care and follow-up, and to reduce unnecessary readmissions.

As shown through these examples, MIPS requires reporting data on key measures in support of the quality of patient care, activities to improve patient engagement, technology use and reducing costs. Likewise, providers must ensure that the data and information captured and reported is complete, accurate and timely. Only through reported data and information can results be adequately measured. Therefore, information governance in the new world of value-based care is imperative.


About the author: Ann Meehan, RHIA, is the director of information governance at AHIMA IGAdvisors.