- A group of 37 medical societies have urged the Office of the National Coordinator for Health Information Technology to move away from using meaningful use requirements for data exchange as a means of measuring EHR interoperability as part of MACRA implementation.
Led by the American Medical Association, the group submitted its comments in response to an ONC request for information (RFI) for assessing interoperability under the Medicare Access and CHIP Reauthorization Act (MACRA), and its low opinion of EHR interoperability under meaningful use is very much palpable.
"Despite claims by many health IT vendors that their products are interoperable, the vast majority only exchange static documents in a manner that satisfies minimum Meaningful Use (MU) requirements," the letter states.
"Many in health care view this level of exchange as little more than digital faxing," We are therefore concerned that both the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator (ONC) are misinterpreting the current use of health IT as a benchmark for successful interoperability."
Just last week, the American Hospital Association voiced a similar concern, advising ONC to move away from utilizing meaningful use data to quantify use.
The 37 medical societies are critical of data exchange under meaningful use because of an emphasis on the quantity rather than the quality of information transmitted between providers:
"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," they argue. "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."
According to the medical societies, a failure to develop more robust metrics and standards would stifle competition in the health IT market and with it attempts to avoid data blocking and remove other barriers to health information exchange.
Another criticism of meaningful use requirements contained in the letter is their failure to go beyond interoperability as an abstract concept toward resolving concrete data exchange and technology problems, a position ONC supported in its comments in the RFI and the impetus for finding other data sources.
"We agree and believe that the answer is not to find other data sources but to improve the current measures being used to define interoperability," the medical societies say.
The letter's criticism of meaningful use requirements is not limited to the ONC's part in the program. In fact, the medical societies called into question the decision by the Centers for Medicare & Medicaid Services (CMS) to transition meaningful use to the advancing care information performance category under the Merit-based Incentive Payment System (MIPS):
Unfortunately, rather than directly addressing this problem, CMS has proposed to carry over these deficient measures in the recently proposed MACRA regulations in the Advancing Care Information (ACI) category. Continuing a policy of “counting physician clicks” will not adequately measure interoperability or incentivize health IT developers to make significant changes. Rather, it will further propel developers to build EHRs that simply meet federal reporting requirements that focus solely on data exchange. The ACI category is an opportunity for CMS and ONC to move away from this construct and develop true metrics for promoting and improving interoperability.
As a solution, the letter calls for ONC and CMS to work together to identify ACI objectives for which interoperability is "inherent."
"There should be a natural fit between the use of health IT and the achievement of certain interoperability goals," it reads. "Such an approach could be done by focusing on specialty-specific interoperability use cases rather than the quantity of data exchanged."
Failing to do so, the medical societies contend, would only serve to increase the burden on physicians for participating in MIPS and MACRA implementation more generally.