RFI on Assessing Interoperability under MACRA

FederalRegister-RFI-200On April 8, 2016 the ONC issued a Request for Information – Office of the National Coordinator for Health Information Technology; Medicare Access and CHIP Reauthorization Act of 2015; Request for Information Regarding Assessing Interoperability for MACRA. ONC intends to consider metrics that address the specific populations and aspects of interoperable health information described in section 106(b)(1)(B) of the MACRA. ONC is issuing this RFI is to solicit input on the following three topics: (1) Measurement population and key components of interoperability that should be measured; (2) current data sources and potential metrics that address section 106(b)(1) of the MACRA; and (3) other data sources and metrics ONC should consider with respect to section 106(b)(1) of the MACRA or interoperability measurement more broadly.

The comment period closed on June 3. Here are some of the submitted comments.

DirectTrust Urges ONC to Expand Interoperability Measures Under MACRA
Calling the measurement of interoperability a difficult area of study, DirectTrust has filed comments applauding the Office of the National Coordinator of Health Information Technology’s (ONC) initiative to develop metrics for electronic health information exchange and interoperability.

AMA and Other Medical Societies Call for a Change in Interoperability Measurements
The American Medical Association and 36 specialty medical associations urged the Administration to rethink the way it measures the interoperability of electronic health records. The coalition of physician and medical organizations believes the current direction will require physicians to spend too much time meeting measures that will do little to make electronic health records valuable to patients and medical practices. The letters were delivered to Andrew Slavitt, the acting administrator for CMS, and Karen DeSalvo, the national coordinator for ONC.

HIMSS and PCHA submit comments to Assessing Interoperability RFI
HIMSS and PCHA appreciate the opportunity to leverage their member’s expertise as this information gathering that ONC has undertaken which will provide a great foundation for the continued shift in our healthcare system where value is rewarded over the volume of services that are being performed. A letter was submitted on June 3rd.

AHIMA Submits Letter Regarding Assessing Interoperability for MACRA
AHIMA is the national non-profit association of health information management (HIM) professionals. Serving 52 affiliated component state associations. “We appreciate the work ONC has done to advance nationwide exchange of electronic health information. The discussion here provides AHIMA’s responses to several of ONC’s questions.”

Consumer Partnership for eHealth Files Comments on How to Measure Interoperability in Order to Improve Value-Based Care in Response to Request for Information
Leading consumer, patient and labor advocates urge the ONC to incorporate robust measures of patient-to-provider interoperability and electronic health information exchange in payment and delivery models rolling out under MACRA. The comments, from the Consumer Partnership for eHealth (CPeH), note that patients and family caregivers are key partners in health care delivery and information sharing and use. Led by the National Partnership for Women & Families, CPeH includes more than 50 top consumer, patient and labor organizations that collectively represent more than 127 million Americans.

AAFP Letter to ONC on RFI
On behalf of the American Academy of Family Physicians (AAFP), which represents 124,900 family physicians and medical students across the country a letter was submitted in response to the RFI. The AAFP appreciates the opportunity to work with ONC toward achieving these goals and have the following responses to ONC’s questions in this regulation.

Dr. Larry Garber, Medical Director for Informatics at Reliant Medical Group
Dr. Garber. a practicing physician, penned this response to the HHS request for an assessment of interoperability needed to support MACRA. Dr. John Halamka thought is so good he posted it on his Life as a Healthcare CIO blog.