In comments to be filed today, the nation’s top consumer, patient and labor advocates praise many aspects of the Stage 3 Meaningful Use rules proposed by the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare & Medicaid Services (CMS), describing how they would help ensure that health information technology (IT) meets the needs of patients and families. In the comment letters, the Consumer Partnership for eHealth (CPeH) stresses the role that Meaningful Use plays in ensuring that patients are not just offered access to their health information, but actually use it. CPeH commends CMS and ONC for proposing Stage 3 requirements that enhance individuals’ access to health information and facilitate communication and information sharing with providers. CPeH, which includes more than 50 organizations with a combined membership of more than 127 million people, is filing comments with both ONC and CMS today.

In the comment letters, CPeH also urges CMS to restructure some of the measures to ensure that they assess, and encourage providers to promote, true patient engagement, distinct from communication and coordination of care with other providers. Additionally, CPeH recommends that the Administration enhance critical efforts to identify and reduce health disparities, such as through the capture of data on disability status and sexual orientation/gender identity, to support better care across settings for millions of individuals.

“The ability of patients, families and caregivers to access, understand, use and share health information is fundamental to achieving a health care system that delivers better care, better health and better value. Like physicians, patients and family caregivers need health IT infrastructure and tools that support the partnerships and shared decision-making necessary to achieve those goals. Much remains to be done, and the proposed rules from ONC and CMS, with CPeH’s recommendations incorporated, are important next steps,” said Debra L. Ness, president of the National Partnership for Women & Families, which leads CPeH.

In the comments, CPeH also:

• Urges CMS to maintain the commitment to strong online access requirements, for example by ensuring that patients can view, download and transmit their health information. This is particularly important as a 2014 survey conducted by the National Partnership found that the more frequently individuals access their health information online, the more they report that it motivates them to do something to improve their health (71% for frequent users, compared with 39% for infrequent users).
• Applauds ONC’s requirement to include race and ethnicity at the Institute of Medicine’s recommended level of granularity as a way to help the entire learning health system to identify, understand and reduce health disparities. Supports CMS’ addition of a new requirement to offer patients and caregivers the ability to contribute information to their medical records, sometimes called “patient-generated health data.”
• Recommends strongly that both CMS and ONC require access to health information and education materials in languages other than English, for over 60 million people who use languages other than English at home.
• Supports ONC’s addition of tools and data fields that capture patient goals, patient concerns and family care team members for care plans and transitions of care, thus creating the potential for shared-decision making.
• Applauds ONC for enabling the collection of data on social determinants of patients’ health, such as socioeconomic status, education level, mental health and more.
• Supports CMS’ move to include Application Programming Interfaces (APIs) and applications to improve access to and use of health information, while encouraging CMS to publish guidance on privacy, security and transparency.

<p"Consumers value and use health IT, which provides critical tools for increasing patient and family engagement. The proposed criteria in ONC's 2015 Edition rule and the proposed uses in CMS' Stage 3 rule advance patient engagement and partnership as an essential next step in comprehensive delivery system reform," said Mark Savage, the National Partnership's director of health information technology policy and programs. "We urge ONC and CMS to adopt CPeH's recommendations and resist any pressure to backtrack on progress made thus far in furthering the meaningful use of health information technology in our nation."

The CPeH comments are endorsed by the AARP, American Association on Health & Disability, American Cancer Society Cancer Action Network, Asian & Pacific Islander American Health Forum, Association of Asian-Pacific Community Health Organizations, Caring From a Distance, Center for Democracy & Technology, Consumers’ Checkbook/Center for the Study of Services, Disability Rights Education and Defense Fund (DREDF), Families USA, Family Caregiver Advocacy, Fenway Health, Genetic Alliance, Hannah’s Hope Fund, Healthwise, Hermansky-Pudlak Syndrome Network, Informed Medical Decisions Foundation, MLD Foundation, National Consumers League, National Council of La Raza, National Health IT Collaborative for the Underserved, National Health Law Program, National Partnership for Women & Families, PXE International, RASopathies Network USA, Service Employees International Union, The Children’s Partnership, The Fenway Institute and Universal Health Care Action Network of Ohio.

The comment letter to ONC is available here. The comment letter to CMS is available here.