- The American Medical Group Association (AMGA) and AHA disagree over whether CMS should modify Conditions of Participation (CoPs) in Medicare and Medicaid for hospitals to promote interoperability improvements.
The associations submitted comments to CMS in response to an April request for information (RFI) about ways to improve interoperability initiatives and patient health data exchange.
In its letter, AMGA stated medical groups and health systems must have timely access to patient health information in order to effectively deliver value-based care. In the interest of enabling a value-based care system, CMS should revise CoPs for hospitals so that providers can quickly communicate patient data.
“Improving interoperability will give medical groups the ability to transform the quality of care delivered to patients,” said AMGA President and CEO Jerry Penso, MD. “By allowing care providers more real-time access to electronic patient information, CMS can help us achieve a far more interoperable system that will foster care coordination and improve patient engagement.”
Specifically, AMGA suggested CMS require hospitals to share health data with providers in real-time when their patients arrive in hospital emergency departments.
Additionally, the association recommended CMS require that hospitals utilize admission, discharge, and transfer (ADT) notifications to alert providers about their patients’ status as patients move across the care continuum.
Furthermore, AMGA requested that discharge instructions and summary of care information be electronically available to patients within 24 hours of leaving the hospital.
AMGA acknowledged hospitals may have difficulty engaging in ADT notification use and real-time health data exchange due to existing barriers that inhibit data liquidity across the care continuum. With the steep costs and requirements of streamlining health data exchange in mind, AMGA recommended CMS give hospitals ample time to develop the necessary infrastructure to support ADT notification use.
A phased approach to ADT notification use may be appropriate, the association stated.
“AMGA has a physician practice group member that has been working with two unaffiliated hospitals, a community health clinic and their Health Information Exchange (HIE) to share patient medical records real time,” wrote AMGA. “They have told us the effort has been time intensive.”
Overall, AMGA emphasized that any changes made to CoPs should align with the Quality Payment Program (QPP) and the developing Trusted Exchange Framework and Common Agreement (TEFCA).
Meanwhile, AHA advised CMS against creating CoP requirements that promote interoperability in its own response to the RFI.
“The AHA recommends that CMS not implement a CoP/CfC to increase interoperability across the continuum of care because post-acute care providers were not provided the resources or incentives to adopt health IT and creating this requirement would put another unfunded mandate on these organizations,” wrote AHA.
However, the association did suggest CMS support interoperability and health data exchange improvements in other ways.
“Establish a framework for interoperability such that the technology and governance of health information exchange are universally and consistently implemented and demonstrable,” suggested AHA.
Specifically, AHA recommended CMS postpone developing any initiatives or new requirements related to interoperability until after TEFCA is finalized.
CMS released the notice requesting stakeholder feedback about how to revise CoPs related to interoperability initiatives on April 27.
The RFI is intended to advance the aims of the MyHealthEData initiative and was released as part of the new fiscal year 2019 CMS inpatient prospective payment system (IPPS) proposed rule. MyHealthEData is designed to improve EHR patient data access to create a more patient-centric healthcare system.
CMS plans to consider all stakeholder input when developing future regulatory proposals or sub-regulatory guidance.