The Consumer Partnership for eHealth (CPeH) submitted comments today urging the Centers for Medicare & Medicaid Services (CMS) to maintain robust objectives and measures for both current and future iterations of the Meaningful Use program. Health information technology (health IT) — and in particular those requirements — will play a critical role in broader health system transformation and interoperability, the comments say. CPeH represents more than 127 million consumers, patients, caregivers, seniors, people in underserved communities, people with disabilities and other stakeholders.

In the comment letter, CPeH praises CMS for furthering patient engagement and care coordination in the final Stage 3 rule by requiring providers to give patients multiple options for accessing their health information (apps and patient portals, for example), incorporating summary-of-care records, and more. CPeH also commends CMS for allowing providers to fulfill patient engagement measures going forward by giving family caregivers access to electronic health records — an important step in recognizing the role of family caregivers as vital members of care teams.

The weakened Stage 2 requirements for patient use of online access and secure messaging are a significant disappointment, the comments say, noting that these reductions “stall progress to change practice workflow and clinical culture to support substantive patient engagement through online access and health information sharing.” CPeH and the Consumer-Purchaser Alliance, a collaboration of leading consumer, labor and purchaser organizations, submitted detailed comments on the proposed rule for Meaningful Use Stage 2 in June, accessible here.

“We must transform our health care system so it delivers better care and better outcomes at lower cost, but we will not be able to do that unless we engage patients as partners in their care in genuine, authentic ways,” said Debra L. Ness, president of the National Partnership for Women & Families, which leads CPeH. “Patients need tools to set health care goals, make informed decisions and communicate with providers and this is where health IT makes a critical difference: It helps connect 21st century patients with 21st century care. The Meaningful Use program has been an important lever for advancing patient- and family-centered health IT, and we urge CMS to maintain that momentum by keeping the program strong, now and in the future.”

The CPeH comment letter closes with recommendations for incorporating robust health IT requirements in new payment and delivery models created under the Medicare Access and CHIP Reauthorization Act (MACRA), including in both the Merit-Based Incentive Payment System and Alternative Payment Models. The letter urges CMS to:

• Retain full-year reporting for 2018 and beyond to support uninterrupted progress for patients and families.
• Require eligible providers to meet all measures and associated thresholds.
• Incorporate patient and family engagement and care coordination measures, such as providing access to and ensuring patient use of view, download and transmit functionalities; using secure messaging; capturing patient-generated health data; and incorporating summaries of care.
• Add requirements for providers to use functionalities from the 2015 Certified Edition of Health IT, including person-centered electronic longitudinal care plans, health information in non-English languages and links to community resources and supports.

The full set of comments can be found here.

The CPeH comments are endorsed by the Alliance for a Just Society; American Association on Health and Disability; Asian & Pacific Islander American Health Forum; Association of Asian Pacific Community Health Organizations; Boston Public Health Commission; California Pan-Ethnic Health Network; Caring From a Distance; Center for Democracy & Technology; Center for Elder Care and Advanced Illness, Altarum Institute; Consumers’ CHECKBOOK/Center for the Study of Services; Consumer-Purchaser Alliance; Disability Policy Consortium; Disability Rights Education and Defense Fund (DREDF); Family Caregiver Advocacy; Healthwise; Informed Medical Decisions Foundation; Lesbian Health Initiative (LHI); National Consumers League; National Health Law Program; National Latina Institute for Reproductive Health; National Partnership for Women & Families; The Children’s Partnership; Universal Health Care Action Network of Ohio and Mary Anne Sterling, Family Caregiver Advocate.