ONC Request for Information (RFI): Assessing Interoperability for MACRA
CPeH Comment Outline
I.
Introduction
a. Goals of MACRA impossible to achieve without meaningful patient and family
engagement (improved health outcomes and better value).
b. CPeH supports goal of achieving widespread electronic exchange of health
information (as prerequisite for reimbursing value and improving health
outcomes).
c. However, the full spectrum of health / information exchange is not captured by
the components and provider populations ONC proposes to measure; ONC must
also measure the exchange and use of information by individuals (not just for
patients & families).
d. MACRA itself supports measuring interoperability with individuals and family
caregivers, as does ONC’s Interoperability Roadmap.
II.
Patients as Exchange Partners
a. Why measuring individual / consumer / patient exchange and use of data is an
important aspect of interoperability.
b. How to measure exchange / use of information by individuals:
i. Download and Transmit rates of VDT (Meaningful Use measure);
ii. Sharing and integration of PGHD (Meaningful Use measure);
iii. Secure messaging (Meaningful Use measure);
iv. Health Information National Trends Survey (HINTS) survey; and
v. (TENTATIVE) OCR Complaints re: violations of HIPAA Access Right
(indication of data blocking)
c. ONC should also consider disparities in interoperability – measure by
demographic variables (to be able to determine whether there are gaps in
information exchange among populations; ensure equal distribution of
information exchange and use across patient / population types).
III.
Support of Proposed Provider Measures
a. Support measurement of data integration and (medication) reconciliation
measures (important to focus on using data that has been exchanged).
b. Suggest enhanced focus on structured data (vs. eFax) to make the data more
useful, usable to all exchange partners.
IV.
Importance of Implementing Meaningful Use Stage 3 on Time and as Finalized
a. Lays important groundwork for measuring interoperability from consumer
perspective.
V.
Report to Congress on Barriers to Widespread Information Exchange
a. OCR complaints re: HIPAA Access Right violations should be included in any
potential report to Congress.
VI.
Conclusion