ONC Request for Information (RFI): Assessing Interoperability for MACRA
CPeH Summary
PURPOSE of RFI:
 Establish metrics to evaluate interoperability for report to Congress, as required in
MACRA (section 106(b)(1)(B))
 Topics:
(1) Scope of measurement: which population(s), components of interoperability
(2) Current data sources for measurement; possible metrics
(3) Other data sources, metrics
(4) Overarching questions
BACKGROUND: MACRA’s interoperability requirements
 MACRA section 106(b)(1) declares widespread exchange of health information through
interoperable certified EHR technology (CEHRT) by the beginning of 2019 to be a
national objective.
o Compels HHS to establish metrics by July 1, 2016 to determine if objective met.
 Definitions:
o Interoperability – the ability of two or more health information systems or
components to:
 exchange clinical and other information; and
 use that information so health care providers have access to longitudinal
information for coordinated care and improved health outcomes.
o Widespread interoperability – interoperability between CEHRT systems
employed by meaningful EHR users and other clinicians and health care providers
on a nationwide basis.
 ONC measures interoperability (“exchange and use”) by the following activities:
o electronically sending, receiving, finding, integrating, and subsequent use of
information.
 ONC concludes that MACRA limits measurement to meaningful EHR users and their
exchange partners, but recognizes need to measure interoperability across other
populations and settings (in line with Interoperability Roadmap).
1.) SCOPE OF MEASUREMENT
 Should metrics be limited to Meaningful Users and their exchange partners, or include
actors in ONC’s Roadmap (e.g. consumers, behavioral health, long-term care providers)?
 Does measuring sending, receiving, finding, integrating and using electronic health
information adequately measure “exchange” and “use” for interoperability?
 Should the metrics be limited to use of CEHRT?
2.) CURRENT DATA SOURCES
 ONC proposes to evaluate interoperability from two perspectives:
o By provider – proportion of Meaningful Users who exchange and use; and
o By transaction or volume of exchange – proportion of visits or transitions of care
where information is electronically exchanged and used.
 Data source - by provider: National surveys of hospitals and office-based physicians
(conducted by provider organizations)

o Possible measures:
 Proportion of providers who send, receive, find, and integrate key health
information (e.g. summary of care records);
 Proportion of providers who use the information they electronically
receive for clinical decision-making; and
 Proportion of providers who reconcile clinical information received (e.g.
medications).
o Recognition that self-reported data are subject to bias; don’t reflect all types of
providers; and don’t report on transactions.
o Questions for comment:
 Do these survey-based measures adequately assess “exchange” and “use”?
 Do national surveys adequately determine why electronic health
information may not be widely exchanged? Other recommended methods?
Data source – by transaction: Meaningful Use attestation data (submitted by eligible
professionals and eligible hospitals)
o Possible measures:
 Proportion of transitions of care or referrals where a summary of care
record was created, received, or reconciled.
o Recognition of limitation: cannot evaluate interoperability for Medicaid providers
because states do not all report individual provider performance data for Medicaid
providers
o Questions for comment:
 Do these measures adequately assess “exchange” and “use”?
 Should ONC evaluate interoperability across providers as well as
transitions, even if limited to Medicare providers?
3.) OTHER DATA SOURCES
 Medicare fee-for-service claims data;
 Performance data from other programs; and
 Data from MACRA – forthcoming MIPS, APM measures (for MIPS, APM eligible
providers)
4.) OVERARCHING QUESTIONS:
 Should ONC select measures from one data source for consistency, or a variety of data
sources? If the latter, are Meaningful Use data and national survey measures the
appropriate combination?
 What other measures should ONC consider?
 Are there Medicare claims-based measures that can add unique information?
 What other national-level data sources should ONC consider?
 What are the highest priority measures (if ONC limits the measures selected)?
 How should ONC define “widespread” across measures (e.g. >50%, or higher threshold)?