Everyone agrees that widespread interoperability of patient records is needed to improve care coordination and outcomes. But there's little agreement on how to measure it.
Congress, in its infinite wisdom, did not believe that the Meaningful Use program was making adequate strides when it came to increasing interoperability, and decided to include the requirement of "widespread interoperability" in 2015's Medicare Access & CHIP Reauthorization Act (MACRA). It defined "widespread interoperability" as interoperability between certified electronic health record systems employed by providers nationwide, a goal to be met by the end of 2018.
But the Department of Health and Human Services has only until July 1 to establish the metrics to measure this objective.
The pressure is on.
And it gets worse, since there's been little consensus regarding what should be measured, and how.
The Office of the National Coordinator for Health IT floated some ideas in its April 7 request for information on the matter, suggesting that the scope should be limited to meaningful users and their exchange partners, and noting that it was considering several measures curried from the Meaningful Use program, such as the proportion of providers who are sending, receiving, finding and integrating the information.
However, commenters had other ideas, some adding metrics, others suggesting a completely different approach.
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 they dubbed "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.
Health IT Now thought that there was too much emphasis on what EHR users were doing and not enough on the vendors that create the infrastructure to support data exchange.
A number of commenters suggested that interoperability encompass more than what ONC proposed. Several recommended that interoperability be more patient centric and include patients and family caregivers, as well as community and social settings, such as nursing homes. Others recommended that the measures be less focused on the number of users and transactions, and more on quality, coordination of care and other issues, such as the need for more accurate patient identification and matching. The American Academy of Family Physicians suggested that the measurements be harmonized into a single process to reduce administrative burdens.
And several commenters specifically addressed what may be the real crux of the problem in measuring interoperability: HHS must scramble to meet the metrics deadline. Comments were due June 3, giving HHS less than a month to digest them all and create a roadmap for everyone.
With that in mind, commenters such as HIMSS and its Electronic Health Record Association suggested a more modest approach of focusing on the existing Meaningful Use metrics, as noted in the request for information, but adding a few familiar ones, such as sending electronic prescriptions, incoming lab results and sending to immunization registries.
And several commenters, such as the American Medical Informatics Association, suggested that, at the least, build into the metrics the ability to be flexible and adjustable over time.
Creating these metrics is a daunting task. HHS should not be rushed into creating something inappropriate, ill-fitting, slipshod or otherwise problematic.That's just setting HHS and the metrics up for failure, criticism and continual statutory and regulatory intervention.
We just went through that with the Meaningful Use program. It's a waste of time, energy and resources all round. Give HHS more time to get it right. The industry--and the agency--shouldn't have to go through that again. - Marla (@MarlaHirsch and @FierceHealthIT)