The Centers for Medicare & Medicaid Services (CMS) Innovation Center (the Innovation Center) published its data-sharing strategy, which seeks to further enable data sharing while ensuring proper security, risk management, and privacy obligations. The strategy outlines the Innovation Center’s approach to identifying data sharing needs across Innovation Center models and highlights the importance of data in developing and testing innovative healthcare payment and service delivery models.

The Innovation Center gathers and uses data in a number of ways: it collects data from model participants, including clinical and quality data; generates data during model operations; and uses CMS-wide data (e.g., Medicare claims data). Since 2022, the Innovation Center has released three types of participation data (i.e., entities, providers, and beneficiaries) for each available model. Data are available for certain Innovation Center models, including Accountable Care Organization (ACO) Realizing Equity, Access, and Community Health (ACO REACH), Bundled Payment for Care Improvement Advanced Model, and Primary Care First. Sharing data with participants allows the Innovation Center to enable the success of model participants in reducing expenditures and enhancing quality.

Summary of CMS Innovation Center Data Strategy Principles

The Innovation Center states that it interviewed many stakeholders, including health information exchanges (HIEs), data aggregators, data vendor representatives, and model participants over several months to receive feedback and identify gaps in data sharing. From these discussions and other research, the Innovation Center outlines the following data strategy principles:

1. Promote Access to CMS Data: The Innovation Center plans to continue to expand access to CMS data. This may include enabling application programming interface (API) access to claims data for participants beyond accountable care organizations (ACOs) and exploring participation in the Trusted Exchange Framework and Common Agreement (TEFCA).
2. Formulate Data-Sharing Strategy Early in Model Design: The Innovation Center will proactively address potential challenges to model-specific data-sharing initiatives and involve subject matter experts from the beginning.
3. Focus on Standards: The Innovation Center will invest in data standards, namely Fast Healthcare Interoperability Resources (FHIR), for data and data-sharing processes to reduce burden in the long term and streamline technical/data integrations.
4. Invest in Data Tools and Resources: The Innovation Center will enhance its analytic and dashboard tools so that more participants have access, and invest in non-technical resources, including support, technical assistance, and data literacy enhancements.
5. Enhance CMS Data Collection Capabilities: The Innovation Center will enhance data collection efforts to create efficiencies and reusable technology/processes, including through file-based exchange and use of APIs.
6. Partner Broadly to Enhance Our Data-Sharing Capabilities: The Innovation Center plans to foster continued stakeholder engagement with entities including data vendors, payers, HIEs, and electronic health record vendors, among others.

Takeaways

The Innovation Center states that its data-sharing strategy can advance transparency on model performance and provide a framework that may reduce the burden of participating in value-based care overall by facilitating multi-payer alignment. In order to implement its data strategy initiative, the Innovation Center intends to expand access to data for model participants and enhance its dashboard tools. The Innovation Center also highlights the need to maintain appropriate security and privacy controls while increasing access to data. To this end, it commits to aligning with the Department of Health and Human Services (HHS) Cybersecurity Performance Goals and complying with data privacy requirements under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Innovation Center model participants and others can benefit from increased access to data, which may address data readiness barriers and promote timely access to data intended for clinical management, thereby helping to encourage participation in value-based programs. The strategy also reflects recent federal efforts to promote interoperability and health data sharing, as demonstrated by greater adoption of industry-wide standards and recent policy developments to implement TEFCA.  

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