The Cost and Dangers of Giving Healthplans Your Patients’ Assessment Data

Healthplans, venture capital investors, and managed care start-up companies that provide referrals and claims management want (1) psychotherapist assessment data, including (2) psychotherapist and patient names. Healthplans that subsidize measurement-based care (MBC) do not tell psychotherapists that they want or have dashboards that give visible access and analysis of provider-patient screening, progress, satisfaction and outcomes. This information can be used to profile and grade provider performance, and target providers for so-called educational-audits; or worse, recoupment of payments.

They only way Healthplans can gather, aggregate, analyze or use psychotherapists data is to convince psychotherapists to use their required online software. A provider who uses software subsidized by a Healthplan or managed care company is giving away data worth at least $23,000 to $36,000 per year. (Estimate based these requirements: provider training, patient training, additional charting, subsequent reviews, technical problems, technical support calls, review and discussions with patients, breech notification insurance, 2 measure per patient per month, reduction in episodes of care, the complexity of using different measures for different Healthplans, and the financial value of data for Healthplan marketing.) For that, a provider may receive a small (by comparison) increase in their fee-for-services. Assuming the fee-for-service is $100 per appointment, the cost of measurement-based care should be in range no less than $20 to $30 per patient per week. (Providers should perform their own estimate in consideration of regional population and economic variability.)

Psychotherapists who participate in Healthplan subsidized AND directed measurement and data collection systems are giving Healthplans visibility into provider services and patient data. This allows Healthplans to steer psychotherapy interventions, procedures, processes, modalities, levels of care, duration of treatment and more.

The requirement to use ACORN, Tridiuum (1), PCOMs and MyOutcomes can be legitimately and easily circumvented by psychotherapists when they (a) provide ethical informed consent to patients, or (b) simply tell Healthplans and patients that they recommend an alternative method which has lower risk, is more useful when providing care, and is not funded or directed by a Healthplan.

Rather than using provider-patient data to improve provider services, Healthplans can monetize data, or use the data to direct mental health services; thereby using provider’s own data against them.

(1) Triduum is an example of Measurement Based Care system
that include the PHQ9, GAD7 as required measures.
https://mentalhealthtraining-ncal.kaiserpermanente.org/ce_lecture_library/tridiumm-and-feedback-informed-care/

For more information:
https://tridiuum.com/capabilities/tridiuum-one/
https://acorncollaboration.org/
https://betteroutcomesnow.com/
https://www.myoutcomes.com/
https://www.neuroflow.com/

Talking Points

Rather than giving their assessment data to Healthplans, psychotherapists should have opportunities to retain, gather, combine, and analyze disidentified patient data for the purpose of supporting data informed conversations among providers to improve outcomes and the quality of psychotherapy services.

Problems with required use of ACORN, PCOMs or MyOutcomes in Oregon

1. Coordinated Care Organizations (CCO) [which are dubbed Accountable Care Organizations (ACOs) in Oregon] require licensed psychotherapists, mental health professionals and treatment programs to use specific screening, progress, outcome and satisfaction measures that effect treatment interventions. Providers must use an approved measurement and treatment intervention system to receive referrals and reimbursement.

2. CCO’s have not been consistently transparent in the health care community regarding expectations until after clinician contracts with CCO’s have been signed. After contracts are signed, the Oregon Health Authority reportedly requires that provider groups must use specific feedback and outcome measurement systems (ACORN, PCOMS and My Outcomes). Tridiuum is accepted by OHA and reportedly at least 2 Healthplans.

3. ACORN, Tridiuum, PCOMS and My Outcomes are third party software systems which offer proprietary questionnaires that influence psychotherapy processes, progress and outcomes by introducing changes in how psychotherapy is conducted. They are in fact psychotherapy interventions and require modification of psychotherapy processes and priorities.

4. ACORN, Tridiuum, PCOMS and My Outcomes can be used by Healthplans to “steer”, oversee, limit and audit psychotherapy services provided by psychotherapists. They have been used for these purposes in other states. Healthplans expect direct access to outcome measures including information that can identify providers and patients. Provider profiles and patient progress measures have tremendous financial value. ACORN, PCOMS and My Outcomes have the data and names can be provided to the payer. Furthermore, providing this data allows patients’ data to be compared to a national data base.

5. ACORN, Tridiuum, PCOMs and MyOutcomes have been used in Oregon Community mental health programs. ACORN has been used in Oregon community mental health programs for more than a decade. Unfortunately, efforts to learn more about these initiatives and their impact on psychotherapy services have been prevented by several CCOs. One Oregon CCO refused to provide information about ACORN reporting requirements if a psychotherapist is not contracted with that CCO.

6. ACORN, Tridiuum, PCOMS and My Outcomes have value to private practice professionals who are amenable to their respective treatment and intervention methods. However, a fear is that Healthplans may require all psychotherapists to use platforms that report patient data to Healthplans. These systems can be used by Healthplans to gather protected health information (PHI), restrict the level and frequency of care, impose treatment interventions, and “steer” psychotherapists.

7. ACORN, PCOMS and My Outcomes have many limitations. These systems do not offer a wide range of information gathering, analytics and coordination of care options that would be useful to psychotherapists.

8. Requirements enforced by Healthplans to use ACORN, Tridiuum, PCOMs and MyOutcomes will have a negative clinical impact on psychotherapists and patients. There will be resistance by providers who would prefer to use other assessment and alliance measurement options which are secure, and more useful to psychotherapists and their patients.

9. ACORN, Tridiuum, PCOMS and My Outcomes have been used by Healthplans to measure therapist performance, to compare providers to each other in ways that can criticize a provider’s effectiveness and undermine the therapist-patient alliance.

10. ACORN and Tridiuum is widely used to market and promote Healthplans. Their data base is proprietary and not available to users who wish to examine and challenge how the PHI collected is used by Healthplans.

11. Providers using ACORN, particularly those who have group contracts, are required to use an online version on a subscription basis which must be paid for by Healthplans, provider groups and individual psychotherapists. Healthplans are charged $40 per month per psychotherapist. Psychotherapists are charged $30 per month. The cost of creating custom reports is not known but can be created at a rate of approximately $150 per hour.

12. The data gathered by Healthplans who fund and direct the use of questionnaires can be used to compare one provider’s data (i.e., PHI) to PHI obtained from other providers. Calculations are routinely performed to determine if a psychotherapist’s treatment is “on-track” or “off-track.” ACORN sponsored research has developed a statistical method to calculate and identify that as many as 50% of psychotherapists are significantly less effective than peers based on the ACORN criteria.

13. Data gathered by Healthplans using ACORN and Tridiuum have considerable financial value to a Healthplan. Once a psychotherapist relinquishes their PHI data to a Healthplan it becomes the property of the Healthplan to use or sell to its benefit. Giving this provider owned data to a Healthplan has no clinical purpose or value to patients. It does have tremendous financial value to Healthplans.

14. A secure, less expensive, and more useful system has been developed for Oregon psychotherapists by psychotherapists with the specific purpose of keeping clinical PHI separate from Healthplan databases, providing more reliable diagnoses, creating symptom and problem lists for treatment planning, documenting the medical necessity of care, reducing patient drop-out, and justifying services that patients require if reimbursement is challenged or denied.

15. Data gathered by ACORN and software like Tridiuum have significant financial value to Healthplans. Providers should not relinquish their data to a 3rd party that is not responsible to providers. Rather than using this data to improve provider services, Healthplans may monetize ACORN and Tridiuum data, or use the data to dictate mental health services; thereby using the provider’s own data against them.

16. Mental health professionals should be encouraged to combine their deidentified data to create trainings and conversations among providers that are of benefit to patients, and support providers’ legal, ethical, clinical, and legitimate contract responsibilities.

17. ACORN, Tridiuum, PCOMs and MyOutcomes are treatment interventions. They influence and change treatment processes, methods and the relationship between therapists and patients in a variety of ways.

18. Psychotherapists should not participate in Healthplan funded and directed data collection programs. Relinquishing patient symptoms, behaviors and functional status obtained electronically will almost certainly allow payers to establish local norms and to validate their utilization review procedures.

19. Psychotherapists in Oregon should not participate in validating Healthplan utilization control criteria for Oregon that has been established in other regions of the United States.

20. Psychotherapists who participate in Healthplan subsidized AND directed measurement and data collection systems are empowering Healthplans to gain visibility into provider services and patient data. This will allow Healthplans to steer psychotherapy interventions, procedures, processes, modalities, level of care, duration of treatment and more.

21. The requirement to use ACORN, Tridiuum, PCOMs and MyOutcomes can be legitimately and easily circumvented by providers if psychotherapists (a) provide ethical informed consent to patients, or (b) simply tell Healthplans and patients that they recommend an alternative method which has lower risk, is more useful when providing care, and is not funded or directed by a Healthplan.

22. Rather than giving their assessment data to Healthplans, psychotherapists should have opportunities to retain, gather, combine, and analyze deidentified patient data for the purpose of supporting data informed conversations among providers to improve outcomes and the quality of psychotherapy services.

CollaborativeOutcomes™ is a trademark of the American Mental Health Alliance - USA.