For more than a decade, the AAFP has been a leader among physician organizations when it comes to promoting the importance of electronic health records (EHRs) in advancing quality health care. From adoption to implementation to usability, Academy experts have guided family physicians and policymakers alike.
So it's no surprise that the AAFP has offered clear direction to the Office of the National Coordinator for Health Information Technology (ONC) regarding its questions about measuring the progress of EHR interoperability related to the Medicare Access and CHIP Reauthorization Act (MACRA).
The ONC's request for information(www.gpo.gov) was published in the April 8 Federal Register.
AAFP Board Chair Robert Wergin, M.D., of Milford, Neb., addressed a number of key topics in a June 3 letter(7 page PDF) to ONC National Coordinator Karen DeSalvo, M.D., M.P.H., who also serves as HHS' acting assistant secretary for health.
- The AAFP recently responded to a federal request for information regarding how best to measure progress on interoperability of electronic health records.
- The AAFP said all measures should be patient-centric and promote coordination of care, and should not add to physicians' administrative burden.
- The Academy also urged HHS and the Office of the National Coordinator for Health Information Technology to use multiple data sources when measuring interoperability.
He provided responses to 14 questions that range from determining the scope of measurement to prioritizing interoperability measures. The following represents a sampling of the AAFP's recommendations.
Scope of Measurement
First off, the ONC asked if the focus of interoperability measurement should be limited to "meaningful EHR users."
Absolutely not, said Wergin. He pointed out that physicians and other health care professionals who have already successfully attested to meaningful use of an EHR undoubtedly would -- in the process of achieving continuity of care, care coordination and the standard of care for any given care encounter -- exchange information with colleagues who have not yet attested to meaningful use.
"For this reason, it does not make sense to limit the focus of measurement to only those who are meaningful EHR users," said Wergin.
And rather than propose different measures and ways of measuring interoperability among different groups, including long-term care facilities, the AAFP recommends that the task of measuring interoperability "be harmonized into a single process to reduce administrative burden," said Wergin.
He listed three principles to guide that process:
- Measures should be patient-centric and promote coordination of care.
- Measures should not add to the administrative burden physicians already carry.
- Multiple data sources should be used to measure interoperability.
Using National Survey Data
The ONC wondered if survey-based interoperability measures, which focus on measurement from a health care provider perspective, would adequately address two components of interoperability outlined in MACRA -- the exchange and use of information.
Medical Specialty Groups Decry Lack of Interoperability
The AAFP recently joined 36 other organizations in a short and to-the-point response to a federal request for information (RFI) about the establishment of metrics by HHS to determine if and to what extent interoperability of electronic health records (EHRs) has been achieved.
A June 3 letter(3 page PDF) to Karen DeSalvo, M.D., M.P.H., the National Coordinator for Health Information Technology, (ONC) and CMS Acting Administrator Andy Slavitt, the organizations agreed that widespread interoperability of EHRs was "critical to improving health care delivery."
But they expressed concern that CMS and ONC were "misinterpreting the current use of health IT as a benchmark for successful interoperability."
They said meaningful use measures related to data exchange were a poor metric for interoperability and "too focused on the quantity of information moved" rather than the relevance of the exchanges.
The letter chided CMS for "continuing a policy of 'counting physician clicks'" and said it would only serve to push health IT developers to "build EHRs that simply meet federal reporting requirements that focus solely on data exchange."
The ultimate goal of health IT should be to improve the care and wellness of patients, said the organizations. However, "We strongly believe that moving forward with measuring interoperability in its current form, without changing the objectives themselves, will undermine advances in health care and will hinder a successful implementation of MACRA (the Medicare Access and CHIP Reauthorization Act)," they concluded.
Wergin noted that claims data was an important tool for measuring interoperability but said it should be combined with survey data "that expresses physician and provider perspectives" on key components.
He urged the ONC to utilize data gleaned from surveys conducted by the AAFP and others and called such an approach "responsible and prudent."
"The perceptions of physicians and providers, as front-line users of the technologies intended to enable interoperability, provide context and meaning to the otherwise cold and meaningless numerical measurements of the current percentage of interoperability achieved," he added.
A second question related to national surveys asked if they provided adequate information to determine why health information was not being widely exchanged electronically.
Wergin responded in the affirmative.
"When a nation of physicians and providers is interested, most particularly, in the many positive outcomes possible from the promise of interoperable health information exchange, yet is overwhelmingly frustrated by the lack of technology which meets their natural workflows and needs to achieve desired interoperability, it is prudent and responsible to look to multiple national survey sources that provide physician provider perspectives," said Wergin.
Furthermore, he added, perspectives from those "front-line users" of technology are key to understanding what is and is not working in terms of functionality and achieving interoperability goals.
EHR Incentive Program Measures
Wergin took full advantage of an ONC question about whether potential measures related to the Medicare and Medicaid EHR Incentive Programs would adequately address the "exchange" component of interoperability as required by MACRA.
He used a good portion of his response to push back against any notion of piling additional administrative burdens on physicians.
Wergin agreed with the ONC that, for now, the potential measures address that exchange component as related to interoperability.
However, "As the nation determines what is adequate in the measurement of interoperability, we must consider the burdens on clinicians and their practices in reporting measures data. We do not want to siphon off resources from patient care to fulfill the documentation requirements of the measures," he added.
In the event that the number of measures would need to be limited, the ONC sought input on which measures should be given the highest priority.
Wergin pointed out that continuity of care already was occurring. "Care coordination, however, is an area that clinicians struggle with, especially when required to coordinate care efficiently with clinicians outside their own practice or within the larger community."
For that reason, "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," said Wergin.
"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," he concluded.
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