There was certainly no lack of comments on how the government should support and measure interoperability, but not a lot of consensus.
Congress declared in the Medicare Access & CHIP Reauthorization Act a national objective to achieve widespread exchange of health information through interoperable certified electronic health record technology nationwide by Dec. 31, 2018. The Office of the National Coordinator for Health IT then released a request for information on the topic April 7, looking for input on, among other things, what should be measured, the potential metrics and what else the Health and Human Services Department should should consider.
The American Medical Association (AMA) and 36 other medical societies expressed concern that the Centers for Medicare & Medicaid Services and ONC were "misinterpreting" the current use of health IT as a benchmark for successful interoperability because most EHRs only exchanged static documents in a way that satisfies Meaningful Use, which is "little more than digital faxing." They also remarked that the Meaningful Use measures are a poor metric for interoperability and too focused on the quantity of information moved, not the relevance of the exchange. They recommended instead the use of "advancing care information" objectives in which interoperability measurement is inherent.
Many commenters suggested that interoperability look beyond meaningful users. The Consumer Partnership for eHealth, for instance, suggested that interoperability include patients and family caregivers as "key exchange partners," as well as community and social settings, such as nursing homes. The American Association of Family Physicians also said that the focus should not be limited to meaningful users, and instead must be patient centric and promotional of coordination of care. AAFP also suggested that the measurements be harmonized into a single process to reduce administrative burdens.
The College of Healthcare Information Management Executives submitted similar comments, also emphasizing the need for accurate patient identification and matching.
Several other commenters focused on the more practical limitations of measuring interoperability. Both HIMSS and its Electronic Health Record Association suggested that ONC focus on the Meaningful Use metrics since there's so little time between now and the 2018 launch date of MACRA. However, they also suggested adding a few metrics to those in the request for information, such as sending electronic prescriptions, incoming lab results and sending to immunization registries.
Health IT Now pointed out that ONC's "current jurisdiction complicates its ability to promote solutions" and that it should use its certification program to bolster interoperability, such as building interoperability and information blocking error reporting into those requirements. It also recommended that ONC focus more on vendors and less on the Meaningful Users.
HHS is slated to establish the metrics to be used to measure this objective by July 1.
To learn more:
- access the medical societies' letter (.pdf)
- read Consumer Partnership for eHealth's comments
- here's CHIME's letter (.pdf)
- read Health IT Now's letter (.pdf)
- here's AAFP's letter (.pdf)
- check out HIMSS' letter (.pdf)
- here are the EHRA's comments (.pdf)