Clinically Integrated Networks (CIN) Myths

Clinically Integrated Networks (CIN) Myths

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How Achieve CIN Status

Myth: A Medicare Accountable Care Organization (ACO) is presumed to be a Clinically Integrated Network (CIN)

Fact: In February 2023, the Department of Justice (DOJ) withdrew their guidance of presumptively treating Medicare ACOs as CINs.

Myth:?The use of a Health Information Exchange (HIE) by the Clinically Integrated Network (CIN) meets the CIN requirement of common information technology sharing ALL relevant patient data.

Fact:?The majority of HIEs do NOT meet the requirement of common information technology to share ALL relevant patient data as HIEs normally only share very limited data sets such as Admit, Discharge, Transfer (ADT) alerts.

Myth:?The use of certified EHRs by all medical practices in the network meets the definition of common information technology.

Fact:?It most likely does NOT meet the requirement of common information technology to share ALL relevant patient data as most EHRs are not connected to share ALL relevant data.

Myth:?It is more difficult for employed physicians to achieve CIN status?

Fact:?It is easier as all on the same EHR or connected EHRs.

Myth:?The return on investment of a CIN is always worth the cost of common technology.

Fact:?Except for very large networks that achieve CIN status easily for their employed providers, the return on investment (joint negotiation of contracts) of higher negotiated payer rates rarely outweighs the cost of common technology and related CIN functions.

Myth:?CINs require a hospital to participate.

Fact:?While many CINS include a hospital, it is not required.

Myth:?CINs may only make patient referrals within their network.

Fact:?Providers participating in a CIN may refer to a provider in or out-of-network and must honor patient choice.

Myth:?CINs and Independent Physician Associations (IPAs) are the same.

Fact:?CINs and IPAs are NOT the same as most IPAs do not have the common technology and do not meet the other requirements to achieve CIN status.?


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CIN Checklist


Kris Gates, [email protected]


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Health Endeavors


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