This past month, the Centers for Medicare and Medicaid Services and the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology put out a request for information from the broader healthcare and health IT community.
The goal, for an HHS newly restructured under Robert F. Kennedy, Jr., was to gather data to help “inform CMS and ASTP/ONC efforts to lead infrastructure progress,” boosting Medicare beneficiaries’ access to tools that will help them make better health decisions, and “increasing data availability for all stakeholders contributing to health outcomes.”
CMS and ASTP set out a series of use cases corresponding to different groups – patients, providers, payers, vendors, value-based care organizations – and also encouraged patient advocates and other stakeholders to share feedback.
This week, several leading healthcare technology groups offered their perspectives.
Vendor perspectives
The HIMSS EHR Association – which represents nearly 30 member companies that develop, implement and support certified health IT for hospitals and ambulatory providers nationwide – had some thoughts for how the agencies could help industry stakeholders succeed.
In its 25-page letter to CMS Administrator Dr. Mehmet Oz, the association offered detailed feedback on a wide array of health IT use cases and priorities.
One of the areas it emphasized was the need for patient matching: “CMS should prioritize national strategies to enhance patient identity resolution. Digital identity management plays a crucial role in this, but reliable matching and linking to the actual record is the most critical aspect to ensure accurate access to the patient’s complete record across data holders.”
Another was the need for more easily shareable social determinants of health data: “Non-medical factors that strongly influence health, such as food security, transportation access, and family support, are rarely captured in structured, exchangeable formats. Even when this data is collected by community-based organizations, it is not routinely shared with patients or integrated into clinical systems, limiting its utility for care coordination and app developers.”
EHRA also called on CMS to be attuned to burdensome reporting requirements for providers and the IT developers who serve them, noting that “frequent updates to quality measures and reporting expectations, often with limited implementation timelines, create challenges for development and lead to workflow disruptions. More predictable schedules and alignment across payment programs would help developers build sustainable, usable solutions that providers can more easily integrate into care delivery.”
“We are committed to working towards a healthcare ecosystem that leverages the capabilities of EHRs and other health IT to deliver higher-quality care to patients efficiently and in a productive and sustainable manner,” EHRA leaders said, adding that it shares in the agencies’ belief that “practical and responsible adoption of health IT can empower patients to make better decisions about their health and overall well-being.”
APIs and TEFCA
For its part, the American Hospital Association outlined several recommendations to help ASTP and CMS improve on health IT standards and infrastructure, and boost patient access to effective digital health tools and advance data availability to improve health outcomes.
Among just some of its many recommendations to the two agencies, AHA offered these suggestions:
Collaborate across agencies to address broader infrastructure challenges associated with health IT adoption, such as lack of broadband, digital literacy training and reliable Wi-Fi access for rural and underserved communities.
Support reimbursement for the use of health technology by clarifying guidance on digital health and interprofessional consultation billing codes, and develop pathways to provide provisional payment for new technologies.
Promote accountability and engagement from payers on interoperability by requiring that impacted payers adopt and use certified payer application programming interfaces (APIs) and developing safety and security requirements for the Provider Directory APIs.
Repeal provider disincentives in the June 2024 final rule “21st Century Cures Act: Establishment of Disincentives for Healthcare Providers That Have Committed Information Blocking.” Under the final rule, hospitals and providers found to engage in information blocking may face excessive reductions in payment, which threatens access to services (particularly in rural and underserved areas).
Build additional infrastructure to provide oversight for Trusted Exchange Framework and Common Agreement (TEFCA), including establishing an attestation schedule for all qualified health information networks (QHINs).
Provide protections to ensure hospitals or health systems that have a QHIN that is suspended or terminated are not held liable for information blocking claims.
“We look forward to the opportunity to work with CMS, ASTP/ONC and the Department of Health and Human Services (HHS) to help realize technology’s full potential for improving health outcomes, fully engaging patients in managing their health and reducing administrative burden,” said Ashley Thompson, AHA’s senior VP for public policy analysis and development.
Patient-directed sharing
Premier, meanwhile, offered its own perspective on the imperatives of interoperability and patient access in a 20-page letter to Dr. Oz. Among its recommendations for CMS:
Harmonize interoperability regulations to promote greater market competition.
Update meaningful use criteria, certification standards for health IT and the overall federally driven interoperability incentive structure to ensure that data usability for quality and process improvement are adequately incentivized.
Clearly define information blocking and implement and enforce more stringent information blocking penalties on health data ecosystem participants beyond providers and provider organizations.
Extend interoperable electronic health record incentives to post-acute and continuum of care providers.
Develop a holistic framework of both financial and non-financial incentives to promote value-based care participation, which in turn results in greater adoption of tech-enabled solutions.
Mandate a patient-directed data sharing mechanism such as Blue Button 2.0 in certified electronic health record technology (CEHRT) criteria.
Require more standardized data sharing by CMS-regulated health plans to providers and patients..
Improve Risk Adjustment Data Validation (RADV) audit processes by piloting a program that relies on CMS-approved, real-time self-audit technology rather than perpetuating a pay-and-chase model.
“Premier supports the Administration’s efforts to empower patients through the effective and responsible adoption of technology in healthcare,” officials said, and “looks forward to continuing to work with CMS and ASTP/ONC on implementing these recommendations to unleash innovation and improve efficiency in healthcare delivery.”
Automated data exchange
In its comments to CMS and ASTP, the Workgroup for Electronic Data Interchange emphasized that more work needs to be done to meet the goals of the 21st Century Cures Act, and to further implement the CMS Interoperability and Prior Authorization Final Rule.
WEDI called on CMS and ASTP to explore opportunities to improve the health technology environment by:
Ensuring that the health information needs of the patient and their caregivers are at the center of the ecosystem.
Promoting seamless, automated data exchange through mature, clear, and unambiguous standards that have been thoroughly tested and demonstrate meaningful return on investment.
Integrating data exchange efficiently within the health plan, provider and other end users’ workflows.
“WEDI’s work is driven by easing administrative burden, putting patients at the center of their care, implementing consensus based, mature standards that support automation, and maintaining appropriate safeguards for privacy, security, and confidentiality,” said WEDI Executive Director Robert Tennant. “We look forward to continuing our work with CMS and ASTP as they review industry feedback on this RFI and begin implementing these initiatives.”
Telehealth flexibilities
And in its comments, the American Telemedicine Association’s ATA Action trade group focused on virtual care. Among some of its asks for CMS, as outlined in a 10-page letter:
Collaborate with Congress to ensure continuation of Medicare telehealth flexibilities and make certain telehealth flexibilities permanent.
Address outdated Medicaid in-state location requirements.
Promote digital health innovation through appropriate reimbursement.
Adopt reasonable durable medical equipment requirements for software products.
ATA Action is focused on ensuring all individuals have permanent access to digital health products and services across the care continuum,” said Executive Director Kyle Zebley. “ATA Action supports the enactment of state and federal digital health coverage and appropriate payment policies to secure digital health access for all Americans, including those in rural and underserved communities.
“ATA Action recognizes that digital health products and services have the potential to truly transform the health care delivery system – by improving patient outcomes, enhancing safety and effectiveness of care, addressing health disparities, and reducing costs – if only allowed to flourish,” he added.
Mike Miliard is executive editor of Healthcare IT News
Email the writer: [email protected]
Healthcare IT News is a HIMSS publication.
