FR 2020-29169

The document in question is a notice from the Centers for Medicare & Medicaid Services (CMS), under the Department of Health and Human Services. This notice announces a funding opportunity aimed at developing electronic clinical quality measures (eCQMs) for radiology involved in various hospital programs. These programs include the Hospital Inpatient and Outpatient Quality Reporting Programs. By promoting the development and use of such quality measures, CMS intends to enhance healthcare quality and reporting infrastructure.

Summary of the Notice

The notice specifies that CMS plans to award a single-source agreement to Alara Imaging. Alara Imaging is identified as having the particular expertise and proprietary software required for this project's mandates. The intended outcome is to improve existing hospital programs by integrating more efficient and effective eCQMs. It's noteworthy that this announcement does not impose additional information collection requirements on the public.

Significant Issues and Concerns

A primary concern is the awarding of a single-source contract to Alara Imaging, which could suggest a lack of competitive bidding or favoritism. There's a noticeable absence of justification or evidence establishing Alara Imaging's exclusive suitability for this task. Concerns might arise from the absence of a transparent explanation regarding the selection process, which could imply a lack of openness in governmental operations.

Furthermore, the mention of "proprietary software" is problematic as it may potentially lock CMS into a contractual relationship with Alara, limiting flexibility and possibly leading to increased costs. The document also refers to the need for eCQMs that are "high impact" but fails to provide objective criteria or benchmarks that define what constitutes "high impact." This lack of clarity might result in inconsistent interpretations and implementations of the measures aimed at driving policy improvements.

Broader Public Impact

The development of radiology eCQMs is fundamentally about improving healthcare quality data reporting which can benefit the public by enabling better patient care and outcomes. Improved measures can lead to more informed healthcare decisions, safer practices, and enhanced transparency in healthcare quality.

However, the potential absence of competitive bidding could have economic implications, possibly discouraging innovation and cost-efficiency. If other capable entities are overlooked, it may reduce competition in the market for development services, potentially impacting healthcare costs for the broader public.

Impact on Specific Stakeholders

For Alara Imaging, receiving this contract could significantly enhance its market position and reputation in the healthcare sector. It might also establish long-term partnerships with CMS, benefiting the company financially.

Healthcare providers participating in hospital programs might benefit from better standards and measures developed through this initiative, leading to improved patient care. Conversely, the perception of favoritism or lack of selection transparency could cause concerns among other healthcare technology developers and vendors, feeling left out or unfairly disadvantaged.

In summary, while the initiative has the potential to positively transform healthcare quality reporting, the execution as detailed in the notice raises questions about fairness, transparency, and market impact. These issues warrant careful consideration to ensure broader stakeholder engagement and optimal outcomes.