In comments filed today, leading consumer, patient and labor advocates urge the Office of the National Coordinator for Health Information Technology (ONC) to incorporate robust measures of patient-to-provider interoperability and electronic health information exchange in payment and delivery models rolling out under MACRA (the Medicare Access and CHIP Reauthorization Act). The comments, from the Consumer Partnership for eHealth (CPeH), note that patients and family caregivers are key partners in health care delivery and information sharing and use. Led by the National Partnership for Women & Families, CPeH includes more than 50 top consumer, patient and labor organizations that collectively represent more than 127 million Americans.

“MACRA offers an unprecedented opportunity to transform our health care system into one that delivers higher quality, value-based care and significantly better patient outcomes – but harnessing that opportunity requires authentic partnership with patients and family caregivers,” said National Partnership President Debra L. Ness. “Robust electronic health information exchange and interoperability enable and support that partnership by ensuring that individuals, their families and their care providers can send, receive, find and use their electronic health information. We encourage ONC to emphasize the critical role that appropriate, secure, timely and reliable patient use and exchange of health information plays as it assesses interoperability under MACRA.”

In its letter, CPeH emphasizes that measures of electronic health information exchange and interoperability in MACRA must look beyond certified electronic health record (EHR) systems and EHR users to capture the role that patients and family caregivers play as key exchange partners. CPeH writes, “Individuals cannot possibly be active partners in care, effectively achieve health goals and treatment plans, or make informed decisions without accessible, electronic information about their health and health care, and a corresponding ability to share such information.” In turn, active, engaged patients can facilitate care coordination and participate in shared decision-making with providers, helping to achieve value-based care and better patient outcomes.

CPeH also urges ONC to take a broader approach to measuring information exchange that includes connections between the clinical care setting and community-based health and social service settings that influence patients’ ability to get and stay healthy – an approach that aligns with MACRA as a whole. For example, including a measure of exchange between nursing homes and hospitals would help move us toward a system in which any treating clinician in any setting can access, use and update a patient’s care profile.

In the comments, CPeH encourages ONC to:

• Make clear that interoperability with patients is a core requirement of being a meaningful EHR user.
• Incorporate measures of certified EHR technology use that emphasize patient access and use of their own health information, including: view, download and transmit (VDT); secure messaging; patient-generated health data; and use of third-party applications connected to open application programming interfaces (APIs).
• Stratify metrics of individuals’ exchange and use of information by demographic variables to help ONC identify and address disparities in interoperability and information exchange across patient populations.
• Implement regulations for both the Meaningful Use and Merit-Based Incentive Payment System (MIPS) programs in a timely fashion that supports widespread interoperability.
• In any reports to Congress on barriers to widespread information exchange, include information on complaints filed with the Office of Civil Rights regarding violations of HIPAA’s Right of Individual Access.

With regard to provider-to-provider interoperability metrics, CPeH commends ONC’s plans to measure the incorporation of summary of care records and reconciliation of clinical information, noting that these measures can help “maximize the utility and usability of data for all exchange partners.”

The CPeH comments were endorsed by AARP, American Association on Health and Disability, American Cancer Society Cancer Action Network, Asian & Pacific Islander American Health Forum, California Pan-Ethnic Health Network, Center for Medical Consumers, Consumers’ Checkbook/Center for the Study of Services, Consumers Union, Disability Rights Education and Defense Fund, Family Caregiver Advocacy, Healthwise, Informed Medical Decisions Foundation, National Partnership for Women & Families and The Children’s Partnership.

Read the full comment letter here.