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MIPS Twitter Roundup – MACRA Monday

Posted on December 11, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

As we near the end of 2017, I found a number of tweets from CMS and other people that I thought would be useful to those that are interested in MACRA and MIPS.

First up is this tweet from CMS that it’s not too late to still participate in MIPS and collect some performance data before the end of 2017. This is them promoting the Test Option which would allow you to avoid the 4% penalty:

Next up is a fact sheet from CMS which outlines the different between 2017 and 2018 when it comes to MACRA/MIPS. I particularly like page 6 of the document. As you go through it, you’ll realize why 2018 is going to be much harder than 2017.

Next up is a stat from MGMA. I’d be interested in learning about the 14% of practices that think that their value-based reimbursement is going to decrease. Are these people going to direct primary care? I don’t see it going down for almost anyone. What do you think?

Finally, Matt Fisher asks a question about whether MIPS should be voluntary. I don’t think they can make it any more voluntary given the current legislation and do any of us think that congress is going to take up this topic? I don’t. So, it’s kind of a moot point. However, there is a lot of doctor angst about MIPS/MACRA. I just don’t see enough of it to really move the needle on things. I think we’re stuck with MACRA/MIPS for the forseeable future.

In The Hot Seat Again: eClinicalWorks Faces Billion-Dollar Suit Over Alleged Software Problems

Posted on November 27, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Earlier this year, eClinicalWorks agreed to pay $155 million to the U.S. Department of Justice to resolve allegations that it had faked its conformance with Meaningful Use criteria. The DoJ suit alleged that by withholding information needed for certification, eCW violated the False Claims Act.

Now, the vendor is facing what could be an even more serious legal threat, according to a news report appearing in Becker’s Hospital Review. BHR is reporting administrator of the estate of a deceased cancer patient is suing the vendor over data display errors that may have affected the patient’s care.

What makes the stakes so high in this case is that the complaint is asking the court to certify the case as class action, with members to include “all persons residing in the United States whose physicians used eCW to record and store their medical records at all dates relevant.” The suit is asking the court to award plaintiffs $999 million in damages, Becker’s Hospital Review reports.

According to the complaint, which was filed by Kristina Tot, administrator of the estate of the deceased Stjepan Tot, errors with eCW software began to appear before the cancer patient’s death. For example, “he was unable to display his medical history or progress notes,” the complaint reportedly states.

The cancer patient’s problems were far from unique, however, the suit asserts. According to the complaint, important eCW software functions didn’t work or violated regulatory guidelines. The filing claims the vendor didn’t provide accurate and reliable health information, displayed incorrect panels and didn’t record EHR user actions in audit logs.

The bottom line, the suit claims, is that millions of patient records were compromised, leaving patients and physicians unable to rely on the eCW platform.

I am not qualified to speak on whether there’s any merit to the latest suit against eCW, though I think it’s reasonable to assume that the company may not have its act together. (You might also want to check out the angry eCW critiques on this site — whose publisher, like our fearless leader John Lynn, I know to have an impeccable reputation for honesty.)

Ultimately, it’s hard to say whether this latest suit is largely blowback from the previous certification problem or yet another (extremely) costly headache. Either way, if I were part of its leadership team I’d be more than a little shaken by recent events even if the recent complaint gets dismissed.

MIPS Penalties Include Medicare Part B Drugs – MACRA Monday

Posted on November 13, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

I’m sure most regular readers can tell that we’re pretty worn out and tired of MACRA, MIPS, and related government regulation. No doubt you’ll see us posting fewer MACRA Mondays going forward, but we’ll still try to cover major MACRA events as they occur. We just won’t be publishing MACRA Monday every Monday like we’ve been doing.

Jim Tate recently posted about the Real MIPS Timeline which included:

  • Phase 1 – Denial
  • Phase 2 – Shock/Anger
  • Phase 3 – Acceptance

You should read his full writeup, but he’s right. There’s a lot of denial that’s going to lead to shock and anger until the majority of healthcare have to finally accept that MIPS and MACA aren’t going anywhere.

Jim Tate also wrote another important piece related to the MIPS penalties and Medicare Part B drugs. You can read the full details of the change, but for those too lazy to click over, here’s the summary:

  • Many organizations argued that Medicare Part B Drug Costs Shouldn’t be Included in the MIPS Penalties (I mean…payment adjustments)
  • The MACRA Final rule still includes Medicare Part B drug costs (for the majority of people) in the MIPS reimbursement and eligibility calculations

If you’re a practice with a high volume of part B drugs, you better start figuring out your MIPS strategy now! Otherwise, that payment adjustment is going to hit pretty hard.

Thanks Jim for the great insights into MACRA and MIPS. If you need help with MIPS, be sure to check out Jim’s company MIPS Consulting.

MACRA Twitter Roundup – MACRA Monday

Posted on October 30, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

We took last week off from our MACRA Monday series of blog posts. It seems like we’re in a kind of lull period for the program. Either you’ve started collecting the data you’ve needed or you haven’t. Plus, we’re kind of waiting for the next MACRA Final rule to drop for more details.

With that in mind, I did want to see what some of the latest things that were being shared on Twitter when it comes to MACRA. I found a lot of strong opinions about the program, some good resources, and some forward-looking thoughts on what could be coming in the next MACRA final rule.


It’s hard to argue with John. Not just because he’s a smart guy, but because he’s right that it’s hard to imagine a path forward that’s fee for service and doesn’t include a shift to value based care in some form or fashion. At least given the current market dynamics.


This caution from Workflow Chuck should have us all nervous about the shift. I see a lot of healthcare organizations going after the target as opposed to the goal of value based care.


MACRA is going to impact your biz. I liked the way Kelly broke it out into 4 areas. No doubt some of these things could be argued both ways.


This is still how most doctors I know feel about MACRA and even meaningful use before it. They feel like they’ve been thrown under the bus.

Here are two forward looking resources that look at what we might get from the MACRA Final Rule:

What else are you hearing about MACRA? Would love to hear your thoughts, insights, questions, perspectives, rants, etc in the comments.

Optimizing Your EHR for MIPS and Other Quality Payment Programs – MACRA Monday

Posted on October 9, 2017 I Written By

The following is a guest blog post by Meena Ande currently acts as Director of Implementation for Advantum Health. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

As quality reporting requirements ramp up under value-based payment programs like MIPS, healthcare organizations are busy retrofitting their EHRs to make way for new measures. In some settings, not much has changed by way of tech utilization since initial EHR investments were made. Many outpatient settings still lack the internal expertise needed to optimize their implementations.

The truth is many EHRs have the functionality providers need for quality reporting, but many providers don’t know that due to limited exposure to the system. Couple that stunted tech knowledge with the well documented lack of familiarity with MACRA and the recent rise of the service model in healthcare is no surprise. Many practice administrators are relying on their EHR vendor or engaging outside experts to help lead the charge on system reconfiguration to meet Quality Payment Program demands.

There are several EMR capabilities providers can take advantage of to support QPP reporting efforts. Here are a few tips to keep in mind as you customize your EHR for MIPS and other value-based models.

Don’t boil the ocean when selecting CQMs.

Most EHRs give the option of tracking more than what is required for quality reporting. Initially, track applicable measures that exceed reporting requirements. After three to four weeks you’ll know which are your strong areas. Pick the best of the litter and proceed.

Providers can be overwhelmed by too many measures, particularly in multi-specialty practice settings. While it can be difficult to find overlap in measures between specialties, taking advantage of shared metrics whenever possible can reduce reporting burdens. Sit down as early as possible and develop an EHR configuration that works for your practice’s various clinicians.

Case in Point:

A gastroenterologist and a cardiologist may work in the same multi-specialty organization and on the same EHR, but the clinical quality measures they care about differ. There is no reason to give the gastroenterologist access to the cardiology problem list in the EHR. Specialty views improve ease-of-use and support more complete documentation.

Most EHRs offer role-based and specialty-based customization. Administrators can enable or disable EHR features related to some quality measures at the practice level and sometimes at the individual provider level. Clinical quality measures are based on details about the patient, but what is captured at each point of care should be tailored to the specific provider role.

Consider the roles impacted by different CQMs.

Keep the role of the person who may be responsible for different quality measures and Advancing Care Information workflows in mind when selecting and carving out space for CQMs in your EHR. Select measures that spread reporting work across multiple roles to relieve clinicians of unnecessary burdens.         

Case in Point:

The insurance eligibility verification required under Meaningful Use is managed by the front office. Front-office staff members should be made aware of the processes they need to complete before a patient checks in, and where to document that task in the EHR.

Control what is included in MIPS denominators.

Like Meaningful Use, patient encounter volume is important under MIPS. The size of the patient pool under any given quality measure directly impacts your adherence percentage. While most primary care encounters do meet patient visit requirements under MACRA, that is not always the case in specialty settings. Clinicians can exercise some control in determining what is included in patient denominators when reporting under MIPS.

Case in point:

Some primary care visits can be omitted. Let’s say a two-physician practice sees 50 patients a day. Only 15 of those patients might be seen by a physician. The rest of the patients may be there for a simple procedure like a blood pressure screening, stress test, or echocardiogram, where quality reporting elements are not verified. Such visits should be excluded.

Evaluate your reporting paths.

MIPS offers both EHR-based and registry-based reporting paths. Most specialties can submit CQM data via their EHR while others will have to rely on paid registry reporting. Additional reporting options might include submitting through associations that member clinicians are affiliated with, or through registries created by large hospital affiliates to help related providers.

Another hurdle for clinicians is deciding whether to submit data as a group or independently. Groups interested in participating in MIPS via the CMS web interface or administering the CAHPS for MIPS survey had until June 30, 2017, to register. Beyond that, clinicians have until the March 31, 2018, MIPS submission deadline to decide whether to report independently or as a group.

Case in point:

Big groups with different levels of EHR proficiency among providers may be better suited reporting at an individual level. Individual reporting takes more time for attestation, but the advantage is that higher-performing clinicians can avoid a penalty if the group doesn’t collectively meet reporting criteria.

Each month, sample 10 percent of EHR CQM data, including instances where criteria have been met and where it has not. Catch outliers with trouble following through on processes and extend targeted training to the team members bringing numbers down.

Conclusion

Optimizing the EHR and other tech resources providers have in place can be a huge MIPS enablement factor. Up-front customization work helps providers meet reporting requirements and save time over the long run. EHR optimization also enables future value-based care initiatives and lays the groundwork for population health management programs. Gains made in EHR use benefit the life of the practice through increased efficiency and, at the end of the day, better patient care.

About Meena Ande
Meena Ande currently acts as Director of Implementation for Advantum Health where she manages Implementation of services along with EHR optimization, with emphasis on workflow management for value-based reporting.

MACRA Preparation, Are You Ready? – MACRA Monday

Posted on October 2, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

I’ll admit that the timing of this week’s MACRA Monday is a bit rough for me given the tragedy that’s occurred in my town, Las Vegas. Instead of dwelling on the tragedy and the person who could do such an awful thing, it’s been amazing even in these early hours to see how many people in Las Vegas and around the world want to and are supporting the victims of this tragedy.

We heard that there was a need for blood and thought we could help. Turns out that hundreds of others had the same idea and the blood banks have their schedules full through Wednesday. We’ll go after that to replenish the blood banks that no doubt will take a while to replenish their supply.

Thanks to everyone on Facebook, Twitter, and other social media that have reached out to myself and the rest of us that live in Las Vegas. We’re in a bit of shock and it doesn’t feel real.

To keep with our tradition of MACRA Monday, I thought I could at least share this infographic from Integra Connect on how prepared specialty practices are for MACRA:

No doubt there are a lot of healthcare organizations that aren’t ready for MACRA and they are confused on how they should be ready. Hopefully, those who have read our weekly MACRA Monday posts feel better prepared than most. MACRA is upon us whether you’re ready or not. However, MACRA certainly seems much less important on this day of mourning in Las Vegas.

On this tragic day, it’s worth noting all the incredible stories I’ve heard about Las Vegas healthcare professionals that were prepared and ready for a tragedy like this. I read stories of UMC, a major Las Vegas hospital that was so full of victims that they asked to stop bringing people to UMC that didn’t have life-threatening injuries. I read of EMS people who were at home and went into the danger to help transport victims. No doubt there will be hundreds of other stories of heroism by healthcare professionals. Many that likely won’t be heard or seen, but saved people’s lives. We thank them for their preparation, care, and work that no doubt has saved hundreds of people’s lives.

A big thank you from Vegas to each of you for all of your support.

New EHR Certification Rules Including Self-Declaration – MACRA Monday

Posted on September 25, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

Elise Sweeney Anthony and Steven Posnack recently announced on the ONC Health IT Blog two major changes to the EHR certification program. In some ways, it shows a maturity of the EHR certification program, but in other ways, it’s ONC kind of taking a more hands off approach to EHR certification.

Here are the two big changes they made:

  1. Approving more than 50% of test procedures to be self-declaration; and
  2. Exercising discretion for randomized surveillance of certified health IT products.

The first one is really fascinating since they’re making 30 out of the 55 certification criteria as “self-declaration only.” That basically means that EHR vendors will just have to claim they meet the requirements. The ONC-ACBs won’t be certifying those 30 test procedures. In many ways, it reminds me of the meaningful use self-attestation. Does that mean that ONC-ACBs will cut their costs in half? Don’t be holding your breath on that one.

Let’s just hope that most EHR vendors don’t self-certify the way eCW approached EHR certification. Although, the eCW EHR certification issues are the perfect example of why a company self certifying their EHR software or the ONC-ACB certifying the EHR software is just about the same. I haven’t seen which test procedures will be self-declared, but my guess is that it was the ones that the ONC-ACBs weren’t really doing much to test and certify anyway. Ideally, this will free up the ONC-ACBs to dive deeper into the 25 test procedures they’ll still complete so they can avoid another eCW like incident.

Some might wonder why we don’t just take the self-declared EHR certification tests altogether if there’s no one that’s going to be checking them. What those people miss is that the self-declaration still keeps the EHR vendors on the hook for properly implementing the EHR certification criteria. If it’s discovered that they claimed to be compliant but aren’t, then the government can go after the EHR vendor for false claims.

The second change has me a little more puzzled. I’m not sure why they would want to release ONC-ACBs from the requirement to randomly audit EHR certifications. Maybe they didn’t discover any issues during their random audits and so they didn’t see a need to continue them. Or maybe the ONC-ACBs said they were going to pull out as certifying bodies if the government didn’t lighten the EHR Certification load. This is all conjecture, but they could be some of the reasons why ONC decided to make this change. They did offer the following insight into their reasoning:

This exercise of enforcement discretion will permit ONC-ACBs to prioritize complaint driven, or reactive, surveillance and allow them to devote their resources to certifying health IT to the 2015 Edition.

I wonder how many complaints the ONC-ACBs have gotten about the EHR software they’ve certified. Have they just been so overwhelmed with complaints that they need more time to deal with those complaints and so audits aren’t needed? I’d be surprised if this was the case. At this point I imagine most people with EHR certification issues will be calling the whistle blower attorneys, but I could be wrong.

All in all, I don’t think these EHR certification changes are a huge deal. It’s largely a maturing of the EHR certification program and does little to help the EHR certification burden on software vendors. Maybe the ONC-ACBs will charge a little less for their certification, but that’s always been a negligible cost compared to the development costs to become a certified EHR. I’m sure the ONC-ACBs are happy with these changes though.

What do you think of these changes? Any other impacts I haven’t described above that we should consider?

What’s Involved In Getting To EHR 2.0?

Posted on September 22, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

While the current crop of EHRs have (arguably) served a useful purpose, I think we’d all agree that there’s a ton of room for improvement. The question is, what will it take to move EHRs forward?

Certainly, we face some significant obstacles to progress.

There are environmental factors in play, such as reimbursement issues.

There’s the question of what providers will do with existing EHR infrastructure, which has cost them tens or even hundreds of millions of dollars if next-gen EHRs call for a new technical approach.

Then, of course, there’s the challenge of making the darn things usable by real, human clinicians. So far, we simply haven’t gotten anything that solves that issue yet.

That doesn’t mean people aren’t considering the issue, however. One health IT leader that’s stepped up to the plate is Dr. John Halamka, chief information officer of the Beth Israel Deaconess Medical Center and CIO and dean for technology at Harvard Medical School.

In his Life As Healthcare CIO, Halamka lays out the changes he sees as driving the shift to EHR 2.0. Here are some of his main points:

  • Regulators are shifting their focus from prescribing certain types of EHR functionality to looking at results technology achieves. This supports the healthcare industry’s movement from a data recording focus to an outcomes focus.
  • With doctors being pulled in too many directions, it will take teams to maintain patient health, this calls for a new generation of communication and groupware tools. These tools should include workflow integration, rules-based escalation messages, and routing based on time of day, location, schedules, urgency, and licensure.
  • With value-based purchasing gradually becoming the norm, EHRs need new capabilities. These should include the ability to document care plans and variation from those plans, along with outcomes reported from patient-generated healthcare data. Eventually, this will mean the dawn of the Care Management Medical Record, which enrolls patients and protocols based on their condition then ensures that patients get recommended services.
  • EHRs must be more usable. To accomplish this, it’s helpful to think of EHRs as platforms upon which entrepreneurs can create add-on functionality, along the lines of apps that rest on top of mobile operating systems.
  • Next-gen EHRs need to become more consumer-driven, making patients an equal member of the care team. Although existing EHR models do have patient portals, they aren’t robust enough to connect patients fully with their care, and they don’t include tools helping patients navigate their care system.

As far as I can tell, Dr. Halamka has covered the majority of issues we need to address in transitioning to new EHR models. I was also interested to learn that regulatory bodies have begun to “get it” about the limitations of demanding certain functions be included in an EHR system.

I’m still left with one question, however. How does interoperability fit into this picture? Can we even get to the next generation of EHRs without answering the question of how they share data between one another? To me, it’s clear that the answer is no, we can’t leave this issue aside.

Other than that, though, I found Dr. Halamka’s analysis to be fairly comforting. Nothing he’s described is out of reach, unless, of course, vendors won’t cooperate. I think that as providers reach the conclusions he has, they’ll demand the kind of functionality he’s outlined, and vendors will have no choice but to pony up. In other words, there might actually be light at the end of the EHR tunnel.

Mental Health EMRs And MIPS – MACRA Monday

Posted on September 18, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

Recently, I began researching the mental health EMR market on behalf of a client. I had expected to find it dwindling as a) the big EMR players have always insisted that an all-purpose EMR could be adapted to serve mental health providers effectively and b) more importantly because mental health professionals weren’t eligible for Meaningful Use payments, which presumably made them lousy sales targets for vendors.

However, my research concluded that there’s roughly a dozen mental health EMRs out there and kicking and that at least two large medical EMR vendors had bought into the mental health technology niche. (Allscripts bought a stake in NetSmart Technologies last year, and Cerner acquired Anasazi outright in 2012). With their investments, the two vendors effectively admitted that supporting mental health providers wasn’t as easy as they’d suggested.

Now, with MIPS imposing new demands on clinicians, mental health providers are likely to expect even more from mental health IT vendors, said Bob Ring, a consultant with Mica Information Systems.

Right now, few mental health EMRs defining themselves as “therapy specific” are CEHRT technology, which could become an issue if MDs on staff in a mental health setting want to meet MIPS requirements, Ring notes.

Under MIPS, psychiatrists must provide a wide range of mental health-specific data, some of which calls for specialty-related technology. For example, one category under the Clinical Practice Improvement Activity Performance Category calls for enhancements to an EMR to capture added data on behavioral health populations and use that data for additional decision-making.

But uncertified EMRs are likely to stay that way, Ring says. “Because these therapy-specific [EMRs] are generally priced very low, and it is expensive to go through the ONC certification process, it’s questionable whether many of them ever will be,” he concludes.

Not only that, things could get even trickier for both mental health clinicians and mental health EMR vendors in the future, if CMS follows through on its threat to hold therapists to the same standards as MDs beginning in 2019.

This could create chaos, however, according to my colleague John Lynn, who contends that putting mental health therapy EMRs under MIPS would be “a disaster.” Instead, mental health should not piggyback MU or MIPS, but instead, focus on incentives for mental health focused EHR incentives.

“The relationship between a mental health provider and a client is totally different than the relationship between a medical provider and their patient,” said John, whose first EMR implementation came when he rolled out a medical EMR in a health and counseling center. “Their methods of documentation are different. Their methods of billing are different. Their approach to care is different. We made it work, but it took a lot of duct tape and jerry rigging to fit it in.”

Why Delaying the Transition to 2015 Edition Technology Would Be a Problem for Patients and Families – MACRA Monday

Posted on September 11, 2017 I Written By

The following is a guest blog post by Erin Mackay, Associate Director, Health Information Technology Policy and Programs, National Partnership for Women & Families.  This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

The National Partnership for Women & Families recently weighed in on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for 2018 updates to the Quality Payment Program (QPP). In our comments, we express concerns that many of the proposed requirements would have a chilling effect on the country’s badly needed transition to a health care system that rewards quality and value over volume. Of particular concern to us is the proposed delay in clinicians’ transition to the 2015 Edition electronic health record (EHR) certification requirements.

Putting off requirements to use more advanced health IT would be a one-two punch to health transformation. First, new models of care that demand high-quality, efficient practices and coordinated care rely on robust health IT. Likewise, these new models only succeed when patients have the information – about their medications, health status, diagnoses and treatment received – they need to participate in their care and make informed decisions with their health care teams.

Here are three ways the proposed rule would delay critical functionalities that are foundational to a patient and family-centered health care system:

1) Delaying Availability of APIs for Consumer Access
It would undermine the commitment to patient engagement to delay the availability of application programming interfaces (APIs) as a way for patients and their caregivers to access, download and share health data. When available, APIs will let consumers choose from a range of apps that pull in health data from various health care providers and hospitals, helping form a comprehensive picture of their health and health care and facilitating information sharing. Gone will be the days when patients and family caregivers struggled to remember passwords for multiple patient portals, or were able to view only one aspect of their medical history at a time.

2) Slowing More Robust Collection of Demographic Data
To enhance health equity, we must first be able to identify disparities by gathering standardized, granular demographic data. Right now, certified EHRs are not designed to distinguish among Chinese, Indian or Vietnamese patients, for instance, instead collapsing these identities into a single “Asian” category. Similarly, EHRs cannot currently store structured information about patients’ sexual orientation or gender identity. In both these examples, this information has clinical relevance and is vital for improving health outcomes. For example, too often transgender individuals do not receive appropriate “gendered” preventive screenings such as Pap tests, mammograms and prostate exams.

3) Failing to Capture Information on Social Determinants of Health
In addition to better demographic information, to best support providers in delivering patient- and family-centered care, EHRs should also capture information about non-clinical factors pertinent to individuals’ health. The 2015 Edition includes a new criterion to capture relevant social, psychological and behavioral data. This includes information on financial resource strain, educational attainment, stress, depression, physical activity, alcohol use, social connection and isolation, and intimate partner violence. At the individual level, this information could help clinicians and care teams determine treatment options that address the unique needs of the patients and families they serve. To improve population health, clinicians, hospitals and community organizations need this information to identify communities that need additional support in order to get and stay healthy.

Conclusion
Overall, the proposed rule for QPP 2018 raises a number of concerns for the National Partnership, particularly the proposed delay of 2015 Edition certified health IT products. We strongly encourage CMS to maintain the current requirements and timeline for clinicians transitioning to the 2015 Edition to provide the necessary infrastructure for the kind of patient- and family-centered health system our country urgently needs.