On March 31, 2011, the healthcare system in the U.S. began to change forever with these words:
"An ACO will put the beneficiary and family at the center of all its activities. It will honor individual preferences, values, backgrounds, resources, and skills, and it will thoroughly engage people in shared decision-making about diagnostic and therapeutic options."
With these words, CMS has taken the bold step of moving the healthcare system from a provider-directed healthcare enterprise to a consumer-directed healthcare system. And the implications are enormous. It is also apparent that this will require leadership skills and abilities at the integration of culture and care. No more spin of shifting here among reimbursement options, playing docs off of one another, or avoiding difficult decisions.
Welcome to consumer-directed healthcare.
Eagerly or not so eagerly awaited, these 429 pages of proposed regulations mark the beginning of a great national discussion that will fundamentally change the healthcare delivery system in the U. S. Much as been written already by such publications as Becker's Hospital Review and more to follow.
Most of the commentary is focusing on the organizational structure and what it will require to successfully develop an ACO. My focus though is in what are the marketing implications? And there are many for what in the regulations is really a very small and insignificant portion, but can get newly developing ACOs in some serious difficulty should they fail to strategically plan and execute marketing properly. So, from the proposed regulations we find as an example:
11. ACO Marketing Guidelines:
"We believe there is a potential for beneficiaries to be misled about Medicare services available from an ACO or about the providers and suppliers from whom they can receive those services. We realize that care coordination is an important component of the Shared Savings Program; however, the potential for shared savings may be an incentive for ACOs, ACO participants, or ACO providers/suppliers to engage in behavior that may confuse or mislead beneficiaries about the Shared Savings Program or their Medicare rights.
As a result, issuing beneficiary communications or engaging in marketing activities that may be confusing or misleading would not be patient-centered because these activities restrict the ability of beneficiaries and/or their caregivers to be informed about their health care choices and thus limit the opportunity for beneficiaries to be properly involved in the management of their own care. We are proposing that all ACO marketing materials, communications, and activities related the ACO and its participation in the Shared Savings Program, such as mailings, telephone calls or community events, that are used to educate, solicit, notify, or contact Medicare beneficiaries or providers/suppliers regarding the ACO and its participation in the Shared Savings Program, be approved by us before use to protect beneficiaries and to ensure that they are not confusing or misleading. This requirement
would also apply to any materials or activities used by ACO participants or ACO providers/suppliers on behalf of the ACO to communicate about the ACO's participation in the Shared Savings Program in any manner to Medicare beneficiaries. In addition, we would want to ensure that materials distributed to beneficiaries do not misrepresent Shared Savings Program policies or suggest that we endorse the ACO, its ACO participants, or its ACO providers/suppliers.
We are further proposing that before any changes can be made to any approved materials, the revised materials must be approved by us before use. Finally, because the failure to comply with these requirements would demonstrate that the ACO does not meet the patient-centeredness criteria and therefore may no longer be eligible to participate in the program, we propose that an ACO that fails to adhere to these requirements may be placed under a corrective action plan or terminated, at our discretion.
For purposes of the Shared Savings Program, we are proposing to define ACO marketing materials, communications, and activities as including, but not limited to general audience materials such as brochures, advertisements, outreach events, letters to beneficiaries, web pages, mailings, or other activities, conducted by or on behalf of the ACO, or by ACO participants, or ACO providers/suppliers participating in the ACO, or by other individuals on behalf of the ACO or its participating providers and suppliers. If these materials or activities are used to educate, solicit, notify, or contact Medicare beneficiaries or providers and suppliers regarding the ACO and its participation in the Shared Savings Program, they must be approved by us.”
Marketing Does Matter
For those who have worked in pharmaceutical, medical device and health plans, you all know full well what happens when marketing materials are misleading and have not been approved by the responsible regulatory agencies. This just isn't throwing some brochures or flyers together, this requires high-quality, professionally-produced materials.
So as you being to assess you organizational capability, several marketing considerations become apparent:
Marketing needs to be at the table in the ACO development and decision making process as a senior management contributing member.
Marketing resources and systems need to be planned for.
Seek out an agency that has pharmaceutical, medical device and or heath plan experience. They already know what it's like to deal with and how to deal with regulatory agencies. This isn't something you do in-house.
Develop a highly integrated strategic marketing plan. Clarify brand architecture, messaging, and outcomes. Tactical execution comes last, not first.
Honestly assess the marketing organization, talent and level of expertise existing within the organization and change it if necessary. Seek out individuals with pharma, medical device or health plan expertise.
Understand this is not about making things look pretty.
It's not about you but about the consumer.
And this is important, it is not just communication strategies.
The regulations will change over the next year as comments are taken and considered. Even with change, these are marketing steps your organization needs to be taking anyway. You will be a lot better off in the long run.
By the way, did I mention the 65 quality of care indicators for ACOs that you will need to report on as well?
2012 is almost here.
You can continue the conversation with me on:
LinkedIn: http://www.linkedin.com/in/krivich0707
Twitter: http://www.twitter.com/mkrivich
Michael Krivich is an entrepreneurial healthcare marketing executive and internationally followed healthcare marketing blogger read daily in over 36 countries around the world. A Fellow, American College of Healthcare Executives as well as a Professional Certified Marketer, American Marketing Association, he can be reached at 815-293-1471 mailto:ormichael@themichaeljgroup.com . Areas of expertise include: brand management; strategic marketing; sales and marketing integration; medical device and specialty pharmacy marketing; physician marketing; product launch; start-up launch and revenue growth; tactical market planning; customer experience management; rebuilding and revitalizing marketing operations; media relations; and service line revitalizations. Mike is Huthwaite SPIN selling trained and a Miller Heiman Strategic Selling alumni.
tags:
"An ACO will put the beneficiary and family at the center of all its activities. It will honor individual preferences, values, backgrounds, resources, and skills, and it will thoroughly engage people in shared decision-making about diagnostic and therapeutic options."
With these words, CMS has taken the bold step of moving the healthcare system from a provider-directed healthcare enterprise to a consumer-directed healthcare system. And the implications are enormous. It is also apparent that this will require leadership skills and abilities at the integration of culture and care. No more spin of shifting here among reimbursement options, playing docs off of one another, or avoiding difficult decisions.
Welcome to consumer-directed healthcare.
Eagerly or not so eagerly awaited, these 429 pages of proposed regulations mark the beginning of a great national discussion that will fundamentally change the healthcare delivery system in the U. S. Much as been written already by such publications as Becker's Hospital Review and more to follow.
Most of the commentary is focusing on the organizational structure and what it will require to successfully develop an ACO. My focus though is in what are the marketing implications? And there are many for what in the regulations is really a very small and insignificant portion, but can get newly developing ACOs in some serious difficulty should they fail to strategically plan and execute marketing properly. So, from the proposed regulations we find as an example:
11. ACO Marketing Guidelines:
"We believe there is a potential for beneficiaries to be misled about Medicare services available from an ACO or about the providers and suppliers from whom they can receive those services. We realize that care coordination is an important component of the Shared Savings Program; however, the potential for shared savings may be an incentive for ACOs, ACO participants, or ACO providers/suppliers to engage in behavior that may confuse or mislead beneficiaries about the Shared Savings Program or their Medicare rights.
As a result, issuing beneficiary communications or engaging in marketing activities that may be confusing or misleading would not be patient-centered because these activities restrict the ability of beneficiaries and/or their caregivers to be informed about their health care choices and thus limit the opportunity for beneficiaries to be properly involved in the management of their own care. We are proposing that all ACO marketing materials, communications, and activities related the ACO and its participation in the Shared Savings Program, such as mailings, telephone calls or community events, that are used to educate, solicit, notify, or contact Medicare beneficiaries or providers/suppliers regarding the ACO and its participation in the Shared Savings Program, be approved by us before use to protect beneficiaries and to ensure that they are not confusing or misleading. This requirement
would also apply to any materials or activities used by ACO participants or ACO providers/suppliers on behalf of the ACO to communicate about the ACO's participation in the Shared Savings Program in any manner to Medicare beneficiaries. In addition, we would want to ensure that materials distributed to beneficiaries do not misrepresent Shared Savings Program policies or suggest that we endorse the ACO, its ACO participants, or its ACO providers/suppliers.
We are further proposing that before any changes can be made to any approved materials, the revised materials must be approved by us before use. Finally, because the failure to comply with these requirements would demonstrate that the ACO does not meet the patient-centeredness criteria and therefore may no longer be eligible to participate in the program, we propose that an ACO that fails to adhere to these requirements may be placed under a corrective action plan or terminated, at our discretion.
For purposes of the Shared Savings Program, we are proposing to define ACO marketing materials, communications, and activities as including, but not limited to general audience materials such as brochures, advertisements, outreach events, letters to beneficiaries, web pages, mailings, or other activities, conducted by or on behalf of the ACO, or by ACO participants, or ACO providers/suppliers participating in the ACO, or by other individuals on behalf of the ACO or its participating providers and suppliers. If these materials or activities are used to educate, solicit, notify, or contact Medicare beneficiaries or providers and suppliers regarding the ACO and its participation in the Shared Savings Program, they must be approved by us.”
Marketing Does Matter
For those who have worked in pharmaceutical, medical device and health plans, you all know full well what happens when marketing materials are misleading and have not been approved by the responsible regulatory agencies. This just isn't throwing some brochures or flyers together, this requires high-quality, professionally-produced materials.
So as you being to assess you organizational capability, several marketing considerations become apparent:
Marketing needs to be at the table in the ACO development and decision making process as a senior management contributing member.
Marketing resources and systems need to be planned for.
Seek out an agency that has pharmaceutical, medical device and or heath plan experience. They already know what it's like to deal with and how to deal with regulatory agencies. This isn't something you do in-house.
Develop a highly integrated strategic marketing plan. Clarify brand architecture, messaging, and outcomes. Tactical execution comes last, not first.
Honestly assess the marketing organization, talent and level of expertise existing within the organization and change it if necessary. Seek out individuals with pharma, medical device or health plan expertise.
Understand this is not about making things look pretty.
It's not about you but about the consumer.
And this is important, it is not just communication strategies.
The regulations will change over the next year as comments are taken and considered. Even with change, these are marketing steps your organization needs to be taking anyway. You will be a lot better off in the long run.
By the way, did I mention the 65 quality of care indicators for ACOs that you will need to report on as well?
2012 is almost here.
You can continue the conversation with me on:
LinkedIn: http://www.linkedin.com/in/krivich0707
Twitter: http://www.twitter.com/mkrivich
Michael Krivich is an entrepreneurial healthcare marketing executive and internationally followed healthcare marketing blogger read daily in over 36 countries around the world. A Fellow, American College of Healthcare Executives as well as a Professional Certified Marketer, American Marketing Association, he can be reached at 815-293-1471 mailto:ormichael@themichaeljgroup.com . Areas of expertise include: brand management; strategic marketing; sales and marketing integration; medical device and specialty pharmacy marketing; physician marketing; product launch; start-up launch and revenue growth; tactical market planning; customer experience management; rebuilding and revitalizing marketing operations; media relations; and service line revitalizations. Mike is Huthwaite SPIN selling trained and a Miller Heiman Strategic Selling alumni.
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