In comments filed today, powerful and diverse leaders representing tens of millions of Americans expressed deep disappointment with the proposal from the Centers for Medicare & Medicaid Services (CMS) to reverse key patient-engagement criteria in meaningful use for 2015 to 2017. The comments warn that reducing the requirements for health care providers — from 5 percent of patients to merely showing that one patient used online access to view, download or transmit health records — will undermine and thwart progress on patient and family engagement. CMS also proposes to drop the threshold on secure messaging, allowing providers to simply turn on the secure messaging function, rather than showing that 5 percent of patients actually used it.

The comment letter was organized by the Consumer Partnership for eHealth (CPeH) and the Consumer-Purchaser Alliance (C-P Alliance). In it, leading national organizations warn that weakening the requirements would undermine efforts to make patients and family caregivers true and equal partners in improving health through shared information, understanding and decision-making. The letter was signed by 50 groups representing consumers, employers, seniors, underserved communities, patients, people with disabilities, labor, caregivers and others.

The CMS proposal also fails to align with what consumers say they want. According to a national survey commissioned by the National Partnership for Women & Families, 86 percent of patients with online access use it, and 55 percent use it at least three times per year. Most patients (56 percent) want the ability to email their providers.

“What CMS is proposing is a dramatic, unwelcome and unjustified retreat from its commitment to promote patient and family engagement,” said Debra L. Ness, president of the National Partnership, which helps lead both CPeH and the C-P Alliance. “Delivery system reform cannot succeed without active engagement of patients and family caregivers, and online access is a critical tool for many. Simply offering, but not necessarily using, online access will not improve care and health; we must promote active engagement if we are to achieve the goals of delivery system reform. We urge CMS to keep the existing patient-engagement thresholds.”

CPeH and the C-P Alliance have helped drive a lively conversation on this issue since the proposed rules were issued in April. In addition to the comments, today the National Partnership for Women & Families will also submit more than 5,000 individual comments to President Obama, Health and Human Services Secretary Sylvia Burwell, CMS Administrator Andy Slavitt and National Coordinator for Health Information Technology Karen DeSalvo urging CMS to reverse its decision, and nearly 400 six-word memoirs from consumers describing the importance of access to electronic health records to them.

The comments emphasize that the 5 percent threshold is achievable, citing research conducted by CMS on current performance on Stage 2 of Meaningful Use. They state, “CMS itself reports that median performance is 32 percent of patients for doctors and 11 percent of patients for hospitals on Stage 2’s measure of actual online access.”

“Empowering patients and their family caregivers with electronic access to and use of their health information is also a critical step toward interoperability throughout the health care system,” said Bill Kramer, co-chair of the C-P Alliance and executive director for National Health Policy at the Pacific Business Group on Health. “Interoperability will enable the efficient collection, sharing, and use of health information by patients, providers, purchasers, and other health system stakeholders to achieve the triple aim of better care, smarter spending, and healthier people.”

The CPeH comments are endorsed by the AARP, American Association on Health and Disability, American Cancer Society Cancer Action Network, 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 Democracy & Technology, Center for Medical Consumers, Colorado Consumer Health Initiative, Connected Health Resources, Consumer Federation of America, Consumers’ CHECKBOOK/Center for the Study of Services, Disability Policy Consortium, Disability Rights Education and Defense Fund (DREDF), Families USA, Genetic Alliance, Healthwise, Health Policy Corporation of Iowa, Informed Medical Decisions Foundation, Iowa Health Buyer’s Alliance, Justice in Aging, Lakeshore Foundation, Lehigh Valley Business Coalition on Healthcare, Lesbian Health Initiative (LHI), Louisiana Housing Alliance, Maine Health Management Coalition, March of Dimes, Minnesota Health Action Group, Momentum Health Strategies, Mothers Against Medical Error, National Alliance for Caregiving, National Center for Lesbian Rights, National Center for Transgender Equality, National Consumers League, National Health Council, National Health IT Collaborative for the Underserved, National Health Law Program, National Partnership for Women & Families, Pacific Business Group on Health, PULSE of America, Service Employees International Union, St. Louis Area Business Health Coalition, Summit Health Institute for Research and Education, Inc., The Alliance, The Children’s Partnership, The Empowered Patient Coalition, United Church of Christ, OC Inc. and Wyoming Business Coalition on Health.