- The American Academy of Family Physicians (AAFP) has sounded off on methodology proposed by the Office of the National Coordinator for Health Information for measuring EHR interoperability as part of MACRA implementation and questioned the sense of restricting the measurement to only providers eligible for incentives.
"For the purpose of continuity of care, care coordination, and the standard of care for any given care encounter, physicians and healthcare providers who are meaningful EHR attesters must exchange information with non-meaningful users who have not yet attested to Meaningful Use, MACRA, the Merit-based Incentive Payment System (MIPS) or an Alternative Payment Model (APM)," AAFP Board Chair Robert Wergin, MD, said in a letter to ONC earlier this month.
"For this reason, it does not make sense to limit the focus of measurement to only those who are meaningful EHR users," he continued. "A calculated measurement of the achieved percentage of interoperability across the U.S. which does not include many long-term care facilities that are not yet meaningful EHR users does not reflect an accurate view of the status of interoperability within the health care ecosystem."
The academy has recommended a streamlined approach to measuring EHR interoperability that does not provide one-off assessments of health data exchange capabilities of different groups of providers (e.g., meaningful users, long-term/post-acute care providers); instead, it has advocated a single process for gauging widespread interoperability.
To that end, AAFP sees little value in measuring interoperability for MIPS or APM participants separately. "Appropriately so, it does not appear that interoperability requirements are grossly different for eligible professionals within MIPS versus APM payment models. If this is the case, we would recommend that the measurement process for interoperability be consistent across both programs," the letter states.
Additionally, the group has called for ONC to consider three principles to guide its assessment of EHR interoperability:
- Measures should be patient centric and promote coordination of care
- The measures should not add administrative burden to clinicians or their practices, and
- Multiple data sources should be utilized to measure interoperability.
AAFP has offered the same number of goals for ONC to consider in developing its EHR interoperability measurement methodology as part of MACRA implementation:
- Improved continuity of care
- Improved care coordination
- The ability to change out or substitute health IT systems
Another significant source of concern for the organization is the evaluation of health information exchange ONC intends to borrow from the EHR Incentive Programs and meaningful use requirements, which AAFP anticipate would increase reporting burdens on providers:
Health IT adoption is well underway, and utilization of health IT is the only means of achieving, efficiently and effectively, the desired outcomes which value-based payment rewards. Therefore, it is time to move forward and drop health IT utilization measures. Because of current law, we understand that CMS cannot completely abandon health IT utilization measures. However, we do believe that CMS can significantly reduce administrative complexity and burden while complying with current law. The AAFP recommends a new construct for addressing interoperability issues and the advancement of care information that is a desired outcome of interoperability.
The academy has called on ONC to make changes to its EHR and health IT certification process (e.g., increase testing of interoperability requirements) and provide assurances that data reported for the purposes of measuring interoperability can be done so electronically.
Above all, AAFP is seeking to make care coordination a top priority for ONC relative to EHR interoperability metrics.
"The AAFP recommends that measuring actual progress toward interoperability across disparate systems and across clinicians for the purpose of care coordination should receive highest prioritization among measures," Wergin maintained. "Again, administrative burden must be avoided to allow clinicians to focus their time on coordinating care rather than measuring the level of progress toward interoperability in care coordination."