In comments filed today, leading consumer, patient and labor advocates commend the Centers for Medicare & Medicaid Services (CMS) for advancing person-centered uses of health information technology (health IT) in programs under MACRA (the Medicare Access and CHIP Reauthorization Act) and recommend ways to strengthen the proposed requirements to better support well-coordinated, patient- and family-centered care. Led by the National Partnership for Women & Families, the Consumer Partnership for eHealth (CPeH) includes more than 50 top consumer, patient and labor organizations that collectively represent more than 127 million Americans.

“Health IT can help patients and caregivers make better informed decisions; connect with health care providers; generate and share important health information; and set, track and achieve personal health and wellness goals,” said National Partnership President Debra L. Ness. “This kind of engagement is fundamental to leveraging MACRA to create a health care system that delivers high-quality, coordinated care and improved health outcomes, while also lowering costs. To achieve this, CMS must set strong requirements that ensure person-centered health IT is fully integrated into new models of health care delivery and payment. The proposed rule is on the right track, and changes like those we recommend will improve its ability to truly transform care and enhance the overall health of patients.”

In its comment letter, CPeH strongly urges CMS to retire the “one patient” requirement, which applies to functions like electronic prescribing, patient electronic access and secure messaging, for calculating providers’ base score in the Advancing Care Information (ACI) category of the Merit-Based Incentive Payment System. CPeH recommends increasing the threshold to five percent of all patients in 2019, noting that keeping the “one patient” threshold would “undermine CMS’ commitment to make patients and family caregivers true and equal partners in improving health through shared information and shared decision-making.”

CPeH offers enthusiastic support for CMS’ focus on patient and family engagement, care coordination and health information exchange in the ACI performance score, noting the specific value of measures that include authorized family caregivers, patient-generated health data and data from non-clinical settings. The letter also urges CMS to increase the impact of ACI performance measures over time by rewarding clinicians for improvement through bonus points.

In the comments, CPeH also encourages CMS to:

• Improve the structure and reporting of Clinical Practice Improvement Activities (CPIA) and add activities that leverage health IT in new and innovative ways.
• Add a single, more robust shared care planning CPIA that leverages the information and activities patients and families want and need to help with their care.
• Add key functionalities to the definition of Certified EHR Technology (CEHRT), including incorporation of social, psychological and behavioral data; care plans; and accessibility-centered requirements.
• Help clinicians new to using health IT fulfill the requirements within the ACI category and provide timely feedback on how all clinicians are fulfilling relevant measures.
• Retain a robust definition of “Meaningful User.”
• Retain the proposal to prevent information blocking, and enforce patients’ timely access to and use of their electronic health information, since patients too often face obstacles to accessing and using their health data.

The full comment letter is available here.

The CPeH comments were endorsed by AIDS Alabama, American Association on Health and Disability, American Federation of State, County and Municipal Employees, Asian & Pacific Islander American Health Forum, Association of Asian Pacific Community Health Organizations, California Pan-Ethnic Health Network, Caregiver Action Network, Caring From a Distance, Center for Independence of the Disabled (NY), Center for Medical Consumers, Consumers’ Checkbook/Center for the Study of Services, Consumers for Affordable Health Care Foundation, Consumers Union, Disability Rights Education and Defense Fund, Families USA, Family Caregiver Advocacy, Fenway Health, Genetic Alliance, Healthwise, Informed Medical Decisions Foundation, NAACP, National Consumers League, National Health IT Collaborative for the Underserved, National Health Law Program, National LGBTQ Task Force, National Partnership for Women & Families, New Yorkers for Accessible Health Coverage, Pacific Business Group on Health, PXE International, Summit Health Institute for Research and Education, The Children’s Partnership, Mary Anne Sterling, Family Caregiver Advocate, Lucy Johns, member of the Board of Directors and Co-Chairs, Patient and Consumer Participation in Direct Work Group, DirectTrust, and Renee Smith, member of the Board of Directors and Co-Chairs, Patient and Consumer Participation in Direct Work Group, DirectTrust.