- Just as other experts have suggested, the Healthcare Information and Management System Society (HIMSS) and the Personal Connected Health Alliance (PCHA) have suggested CMS expand its scope in interoperability measures under the new MACRA legislation.
In a letter signed by HIMSS president and CEO H. Stephen Lieber, CAE, and vice president Dana Alexander, RN, MSN, MBA, FAAN, FHIMSS, the organization explained the various ways in which CMS can expand the scope of its interoperability measures, including in the populations to be measured and the data sources used.
On the whole, HIMSS and PCHA appeared to agree with many of the measure proposals presented by CMS, but thought interoperability measurement needed to be more robust. First, patient access to health data through health information exchange needs to be included in MACRA, Lieber and Alexander said.
“We observed that the patient perspective, and their ability to access their health information, is missed in this definition and should be considered in any metrics that assess interoperability,” the pair wrote. “In our healthcare system’s continued shift to a value-based payment system, patients and the care they receive should be at the forefront and fully considered in assessing overall interoperability and health information exchange.”
The agency should also add more dimensions to measuring interoperability by looking at how the data is used. By looking beyond the metric of how much data is being exchanged, CMS can better understand how interoperability is having an effect on healthcare delivery, and better shape their approaches to policy further.
“For example, the healthcare community would benefit from ONC examining the extent to which clinicians make decisions by incorporating exchanged data,” Lieber and Alexander posited. “The resulting analysis and guidance could have a greater impact on care delivery than simply looking at the technical capabilities between interoperable systems.”
CMS should also include policies to measure interoperability between different kinds of providers, such as acute care facilities and ambulatory care facilities.
In so far as data sources go, Lieber and Alexander agreed that meaningful use data served as a logical launching pad for looking into interoperability, especially considering that all of the measures and requirements are in place. Further, meaningful use has a proven track record for sparking changes in how physicians use technology, and HIMSS and PCHA believes it could be effective in further driving interoperability.
Given that MACRA requires ONC to report to Congress by the end of 2018 on the progress towards interoperability, we recommend focusing on Meaningful Use metrics as they offer a fertile ground for evaluation in the short timeframe between now and 2018. These metrics have the advantage of having already been standardized through the meaningful use program and having been widely captured and already reported to CMS.
HIMSS and PHCA also suggested measuring the following metrics:
- Sending e-prescriptions
- Incoming lab results
- Incoming imaging results
- Sending to immunization registries
- Sending reportable labs to public health
- Sending syndromic surveillance data to public health
Further, HIMSS and PCHA suggest ONC consult industry surveys as short-term data sources for interoperability measures, and look to larger breadths of data, like the HIMSS Continuity of Care Maturity Model, which can reportedly provide long-term data on interoperability.
ONC can also look past traditional measures like meaningful use and toward the use of health information exchanges.
“HIEs offer a rich database of patient health records that could be used for measuring interoperability,” Lieber and Alexander explained. “This will enable ONC to leverage the power of aggregated HIE data to better understand the different types of health information that is exchanged across many HIEs and determine what is feasible across the entire country.”
Many other healthcare organizations have weighed in on interoperability measures under MACRA. Late last week, the American Medical Association led 37 professional healthcare organizations in urging CMS to limit the role of meaningful use interoperability measures under MACRA.
Specifically, the group said that meaningful use measures put too heavy an emphasis on the quantity of data exchange rather than the quality.
"These measures are a poor metric for interoperability, being too focused on the quantity of information moved and not the relevance of these exchanges or the underlying business case for transmitting data," the group argued.
"Greater exchange of patient data does not mean that we are achieving interoperability and better coordinated care. For medical professionals and patients alike, interoperability means the usefulness, timeliness, correctness, and completeness of data, as well as the ease and cost of information access."