One of the things that needs to happen as physician payment reform and EHR interoperability (post-meaningful use) evolve under MACRA is this: CMS and ONC need to promote, measure and significantly enhance consumers’ access to their health information and/or interaction with EHRs.
Stated another way: after spending $30 billion to compel the adoption of EHRs, the federal government needs to get its act together to assure that consumers and patients are directly—and not just indirectly—benefiting. That was, after all, part of the original vision way back in the George W. Bush administration. Simply stated: Electronically stored and continually updated information and records on you should be available to you. And without a lot of trouble.
ONC—the Office of the National Coordinator for HIT, having been charged with the task—recently asked for comments on the section of MACRA [106 (b)(1)(B)] that deals with progress towards interoperability, including consumer/patient access to their own health records and information. Comments were due June 3. ONC received 99. They’ll all be made public here at regulation.gov soon but several groups released their comments on June 3.
As a reminder, MACRA mandates that the nation achieve “widespread interoperability” by the end of 2018. (Not 100% but “widespread.”) ONC and HHS have until July 1 to establish the metrics by which that will be assessed—in a proposed rule.
This post focuses on just one group’s comments—the Consumer Partnership for eHealth (CPeH), which I helped birth several years ago but with whom I have no formal ties now. CPeH is composed of some 50 consumer, patient and labor groups; 14 signed its’ comment letter, including AARP, the American Cancer Society Cancer Action Network, the Center for Medical Consumers, Consumers Union, and the Informed Medical Decisions Foundation. (If you are so inclined, you can read comments from the American Medical Association and 36 medical specialty groups; the group HealthIT Now; and the American Academy of Family Physicians.)
What CPeH wants under MACRA is no less than an EHR interoperability infrastructure that fully nurtures (a) patient access to digital health information, and (b) 2-way communications between providers and consumers/patients that fosters coordination of care. And it wants metrics in place that promote both, and in particular metrics that assess “patient use and exchange of health information in the new models of care,” that MACRA creates, says Mark Savage, director of health information technology policy and programs at the National Partnership for Women & Families, which houses CPeH.
CPeH also wants ONC to:
* Incorporate measures of certified EHR technology use that emphasize patient access and use of their own health information, including: view, download and transmit (VDT); secure messaging with providers; patient-generated health data; and use of third-party applications connected to open application programming interfaces (APIs); and
* Stratify metrics of individuals’ exchange and use of information by demographic variables, to allow ONC to identify disparities in interoperability and information exchange across patient populations. Translation: it won’t be acceptable in the long run to expand patient access to e-health information among just upper middle class white people.
Summed up by National Partnership President Debra L. Ness in a press release, CPeH wants ONC and CMS to “ensure that individuals, their families and their care providers can send, receive, find and use their electronic health information.”
Lygeia Ricciardi, Director of ONC’s Office of Consumer eHealth until July 2014, strongly concurs. In an email to me, she said: “I agree with the CPeH comments. Consumers play a critical role in improving both their own health and the healthcare system. As we move toward value-based care, if we expect to see results, it’s critical that we empower consumers to more effectively be a part of their own care and wellness teams. That requires access to and the ability to use information.”
THCB readers know all too well the missteps and travails surrounding EHR adoption, meaningful use, and interoperability. MACRA affords an opportunity to set a new course. It looks like physician groups are going to continue to fight ONC and CMS on how all things EHR roll out; that’s to be expected given the large-scale change MACRA represents for them.
Amid all that, let’s keep the patient/consumer role and impact very much in mind. MACRA represents an opportunity to, at long last, get that going in a positive direction, too.
Although obscured in a technical document, the primacy of patient engagement and improved access to digital health information is, after all, a critical path in ONC’s “Roadmap” to interoperability released last year.
Steven Findlay is an independent journalist and editor who covers medicine and healthcare policy and technology.