The Consumer Partnership for eHealth (CPeH) is urging the Centers for Medicare & Medicaid Services (CMS) to maintain robust objectives and measures that promote health information access and exchange between patients and eligible hospitals. In comments submitted today on proposed modifications to the rules governing Stages 2 and 3 of the Electronic Health Record Incentive (Meaningful Use) program, CPeH notes that measures designed to give individuals access to their health information and help them use it are critical enablers of high-quality care and delivery system reforms. If kept strong, CPeH writes, the Meaningful Use program holds great promise for improving the quality of care and health outcomes for patients. CPeH represents more than 127 million consumers, patients, caregivers, seniors, people in underserved communities, people with disabilities and other stakeholders.

“The national imperative to transform our health care system into one that delivers better care and better outcomes at lower cost cannot possibly succeed without the active engagement of patients and family caregivers,” said Debra L. Ness, president of the National Partnership for Women & Families, which leads CPeH. “The ability to access and share health information online is an essential tool. We urge CMS not to retreat on measures in the Meaningful Use program so we can realize its full potential to help patients and family caregivers access and use critical health information to improve care and health.”

In the comment letter, CPeH expresses concern with CMS’ decision to reduce Stage 3 thresholds back to the Modified Stage 2 thresholds, describing it as a “retreat from the very activities that hold the most promise for improving the quality of care and health outcomes for patients.” In response to CMS’ rationale that the proposed changes can reduce hospital administrative burden and allow hospitals to focus more on patient care, CPeH writes that, far from being administrative burdens or inconveniences, these activities are integral to developing more collaborative and engaged relationships among patients, their family caregivers and their care teams in the mutual pursuit of better care and improved health outcomes.

In its comments, CPeH specifically urges CMS to:

• Abandon the “one patient” threshold – where hospitals need show that just one patient uses online access (View/Download/Transmit) – and instead keep the threshold at 5 percent of patients. CMS’ own data in October 2015 showed that hospitals already well exceeded this threshold for Stage 2;
• Keep Stage 3 thresholds strong to prepare providers for new models of care, rather than backtracking to Stage 2 thresholds on measures of patient electronic access, secure messaging, patient specific education materials and health information exchange;
• Preserve but modify a clinical decision support measure (CDS) to encourage greater use of patient-facing CDS that engages patients and families in treatment decisions; and
• Maintain full-year reporting in 2016, rather than only 90 days in a year, to maximize the benefit to patients and encourage providers to make sustained changes to workflow and organizational procedures that support interoperability and patient engagement.

The full set of comments can be found here. An online version of this release can be found here.

The CPeH comments are endorsed by the AARP, American Association on Health and Disability, American Federation of State, County and Municipal Employees (AFSCME); Asian & Pacific Islander American Health Forum; California Pan-Ethnic Health Network; Center for Democracy & Technology; Center for Independence of the Disabled, NY; Center for Medical Consumers; Consumers’ Checkbook/Center for the Study of Services; Consumers Union; Family Caregiver Advocacy; Genetic Alliance; Healthwise; Hepatitis Foundation International; Informed Medical Decisions Foundation; NAACP; National LGBTQ Task Force; National Partnership for Women & Families; New Yorkers for Accessible Health Coverage; Pacific Business Group on Health; PXE International; The Children’s Partnership; MaryAnne Sterling, Family Caregiver Advocate; and Christine Bechtel, Consumer Advocate.