- Three letters submitted over the past week highlight the negative impact of the proposed rule for revising payment policies under the 2017 physician fee schedule is likely to have on advancing healthcare interoperability.
The American Medical Association penned a lengthy letter to the Centers for Medicare & Medicaid Services in response to the publishing of the proposed rule in July. On the subject of health IT interoperability, Executive Vice President & CEO James Madara called the federal agency to focus on health IT standards used by clinical decision support mechanisms (CDSMs) and certified EHR technology.
"It is crucial that, for there to be any degree of interoperability between qualified CDSMs and EHRs, there are shared common standards to enable the exchange of clinical information," the AMA letter states. "It is likely that EHRs certified by ONC will undergo recertification as standards needed for interoperability evolve. Given the history of ONC’s Health IT Certification Program we expect this cycle to repeat at least twice within the next five years alone."
A lack of CDSM and health IT alignment, the group argued, could limit system functionality and reduce clinician productivity.
"As noted above, without tight clinical workflow integration, many physicians and staff will need to remove themselves from patient care in order to transcribe information from the EHR into a separate third-party application or website. This will drastically increase the data entry burden—further increasing physician dissatisfaction with their health IT tools, adding human error, or ultimately delaying patient care," Madara added.
To avoid this end-result, AMA has called on CMS to postpone CDSM implementation data until 2019 and offer an automatic hardship exemption to physicians lacking access to affordable and efficient CDSMs. The organization added that the additional time would also allow for emerging health IT standards to mature. "Emerging technologies—like SMART or FHIR—will enable a user-focused health IT ecosystem and, at this time, we urge CMS to take a measured approach with CDSM policy," the letter read.
Interoperability and chronic care management
For the Healthcare Information and Management Systems Society (HIMSS) and Personal Connected Health Alliance (PCHA), the interoperability conundrum presented by the proposed revisions to the Medicare physician fee schedule is the latter's reliance on certified EHR technology to manage chronic care patients.
"Meaningful use standards do NOT support chronic care management functions and service delivery; hence requiring certified EHR technology does not allow for the communication needed or required to provide CCM/TCM," they stated in a joint letter. "We urge CMS to eliminate the certified EHR requirement which impedes and suppresses the ability of providers to offer CCM services to beneficiaries."
According to the two groups current certified technology cannot help transform Medicare " to support a patient centered care delivery system that is enabled and improved by interoperable digital communications technology."
In short, the focus on EHR use gets in the way of patient-centered care delivery as currently proposed. " Patients need and expect our health care system to operate with 21st century technology that enables patient-provider electronic communication," the letter stated.
Ineffective support of patient-generated data
HIMSS was also one of a couple dozen organizations to criticize the proposed changes to 2017 physician fee schedule for falling short of incorporating patient-generated health data into clinical decision-making.
"In previous PFS updates, CMS has taken steps to better utilize connected health technology in several components of Medicare, such through the expansion of its Telehealth Services List, as well as in key Medicare programs such as the Medicare Shared Savings Program (MSSP)," they argued in the joint letter. "However, the protracted pace at which the system is being altered to incorporate connected technologies leaves the Medicare system and the millions of Americans it serves with outdated, inefficient, and less effective treatment options."
As part of their recommendations to promote the patient-generated health data and other connected health solutions, the group of organizations called for expansion of the telehealth services list, increased use of connected health technology in chronic disease management, and an expansion of a federal program for diabetes prevention.