Life Science Compliance Update

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April 25, 2016

Office of National Coordinator Seeks Input on MACRA Interoperability

The Office of the National Coordinator for Health IT (ONC) released a new request for information (RFI) in which they are seeking the public's thoughts on how to measure interoperability. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) sets an objective to achieve the widespread exchange of health information through the use of interoperable certified electronic health records and directs the Department of Health and Human Services (HHS) to establish metrics in consultation with the health IT community and to see if that objective has been met. The public comment period closes on June 3, 2016. Comments can be submitted electronically and ONC specifically states it prefers comments in the Microsoft Word format. Additional information about submitting comments can be found on the Federal Register page.

Specifically, ONC is seeking input on:

  • What populations and elements of information flow should we measure?
  • How can we use current data sources and associated metrics to address the MACRA requirements?
  • What other data sources and metrics should HHS consider to measure interoperability more broadly?

Jodi Daniel, formerly the ONC policy chief, now at the Washington, D.C. law firm of Crowell & Moring, co-authored a short overview of the RFI. The law firm's summary notes: "The RFI presents an opportunity for stakeholders and the public to weigh in on how policy makers understand interoperability. Congress and HHS likely will make both policy and funding decisions based on the goals and measurements that are established in response to feedback received through the RFI."

The directive to establish secure and seamless health data sharing also flows from the Federal Health IT Strategic Plan, the Nationwide Interoperability Roadmap, and pledges from private sector market leaders, the ONC notes, and follows a commitment announced this year by HHS Secretary Sylvia Mathews Burwell toward easing interoperability as well as EHR use.

In the RFI, ONC specifically notes that its currently available data sources might not be sufficient to fully measure and determine whether the goal of widespread exchange of health information through interoperable certified EHR technology has been achieved. ONC's currently available data sources are largely limited to eligible professionals, eligible hospitals, and CAHs as defined under the current Medicare and Medicaid EHR Incentive Programs. Therefore, ONC is requesting input on these measures and data sources, and is requesting feedback on additional national data sources which may be available for this purpose.

ONC also lays out several measures currently under consideration:

  • Proportion of health care providers who are electronically sending, receiving, finding, and easily integrating key health information, such as summary of care records. This can be a composite measure (engaging in all four aspects of interoperable exchange) or separate, individual measures.
  • Proportion of health care providers who use the information that they electronically receive from outside providers and sources for clinical decision-making.
  • Proportion of health care providers who electronically perform reconciliation of clinical information (e.g. medications).

 

"ONC recognizes this will require collaboration and coordination with federal entities and stakeholders across the ecosystem including entities that enable exchange and interoperable health information use, such as technology developers, Health Information Organizations (HIOs) and Health Information Service Providers (HISPs)," ONC states.

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