- The American Hospital Association has recommended changes to the methods the Office of the National Coordinator for Health Information Technology is proposing for measuring EHR interoperability as part of MACRA implementation.
Chief of among them in extended ONC's interoperability measurement of the provider community's current technical capabilities for exchanging and using clinical data, which the organization spelled out in a comment letter in response to an request for information (RFI) issued by ONC in April.
"The AHA recommends that ONC expand its scope of measurement beyond just the exchange and use of electronic health information to include whether we have the standards, technology and infrastructure needed to support these goals," writes Ashley Thompson, Senior Vice President of Public Policy Analysis and Development.
"In the RFI, ONC proposes to measure 'exchange' and 'use' of electronic health information," she continues. "It does not, however, seek input on how to assess whether we have the correct infrastructure to support exchange."
The recommendation suggests that that assessment will reveal limitations in health IT infrastructure. The letter to ONC includes data from a AHA annual survey conducted in 2015 indicating that half of the 3500 respondents encountered information exchange challenges likely caused by a lack of health IT standardization or an inability to locate desired recipients electronically.
The AHA's comments also point to the lack of a unique patient identifier as an obstacle to safe and effective health information exchange.
As for the subjects of exchange and use, AHA questions whether the ONC's proposed methodology will demonstrate the "true extent of information sharing" by preferring certain types of exchange over others:
For example, hospitals and health systems are sharing information with clinicians and post-acute care providers by offering access to shared data systems. This type of sharing can be more efficient and effective than exchange, as the latest data are always available and clinicians with appropriate access rights may access it whenever needed. The RFI does not contemplate this type of sharing, although it clearly fulfills the goals of ensuring data are available for care. We recognize that this type of sharing will be challenging to measure, and may not be available in a quantifiable format. However, we believe that the true extent of information sharing should be reflected in ONC’s assessments.
Additionally, the organization views use as another problematic subject of measurement because the "receipt of information does not always equate to use in clinical care." Thompson recommends that ONC consider provider participation in alternative payment models (APMs) and other quality reporting programs as a better reflect of clinical data use.
Another sticking point for AHA is the use of meaningful use data on exchange and use in informing ONC's methodology for measuring interoperability under MACRA.
For one, the use of meaningful use data on exchange is limited to the electronic sharing of certain types of clinical documents (e.g. clinical summaries) and specific mechanisms for health data exchange (e.g., C-CDA).
"Given the many challenges with the types of exchange required under meaningful use, it may be more appropriate to simply look at success with meaningful use, the Merit-Based Incentive Payment System (MIPS), and alternative payment models rather than assessing specific measures within those programs," writes Thompson.
The AHA letter likewise includes criticisms of meaningful use data on use, particularly meaningful use attestation data on clinical information reconciliation as an indicator of data use. " Given concerns about whether technology will really support clinical information reconciliation, we urge ONC to refrain from using this item as a measure of 'use,'" Thompson adds.
Other recommendations include using non-provider data on health IT certification, certified health IT vendors, HIE, and other exchange organizations to assess their technical capabilities; convening an expert panel of providers to determine the types of information most helpful to care delivery; and avoiding the use of a numeric figure for determining widespread interoperability.