The following is a guest blog post by Erin Mackay, Associate Director, Health Information Technology Policy and Programs, National Partnership for Women & Families. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.
The National Partnership for Women & Families recently weighed in on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for 2018 updates to the Quality Payment Program (QPP). In our comments, we express concerns that many of the proposed requirements would have a chilling effect on the country’s badly needed transition to a health care system that rewards quality and value over volume. Of particular concern to us is the proposed delay in clinicians’ transition to the 2015 Edition electronic health record (EHR) certification requirements.
Putting off requirements to use more advanced health IT would be a one-two punch to health transformation. First, new models of care that demand high-quality, efficient practices and coordinated care rely on robust health IT. Likewise, these new models only succeed when patients have the information – about their medications, health status, diagnoses and treatment received – they need to participate in their care and make informed decisions with their health care teams.
Here are three ways the proposed rule would delay critical functionalities that are foundational to a patient and family-centered health care system:
1) Delaying Availability of APIs for Consumer Access
It would undermine the commitment to patient engagement to delay the availability of application programming interfaces (APIs) as a way for patients and their caregivers to access, download and share health data. When available, APIs will let consumers choose from a range of apps that pull in health data from various health care providers and hospitals, helping form a comprehensive picture of their health and health care and facilitating information sharing. Gone will be the days when patients and family caregivers struggled to remember passwords for multiple patient portals, or were able to view only one aspect of their medical history at a time.
2) Slowing More Robust Collection of Demographic Data
To enhance health equity, we must first be able to identify disparities by gathering standardized, granular demographic data. Right now, certified EHRs are not designed to distinguish among Chinese, Indian or Vietnamese patients, for instance, instead collapsing these identities into a single “Asian” category. Similarly, EHRs cannot currently store structured information about patients’ sexual orientation or gender identity. In both these examples, this information has clinical relevance and is vital for improving health outcomes. For example, too often transgender individuals do not receive appropriate “gendered” preventive screenings such as Pap tests, mammograms and prostate exams.
3) Failing to Capture Information on Social Determinants of Health
In addition to better demographic information, to best support providers in delivering patient- and family-centered care, EHRs should also capture information about non-clinical factors pertinent to individuals’ health. The 2015 Edition includes a new criterion to capture relevant social, psychological and behavioral data. This includes information on financial resource strain, educational attainment, stress, depression, physical activity, alcohol use, social connection and isolation, and intimate partner violence. At the individual level, this information could help clinicians and care teams determine treatment options that address the unique needs of the patients and families they serve. To improve population health, clinicians, hospitals and community organizations need this information to identify communities that need additional support in order to get and stay healthy.
Overall, the proposed rule for QPP 2018 raises a number of concerns for the National Partnership, particularly the proposed delay of 2015 Edition certified health IT products. We strongly encourage CMS to maintain the current requirements and timeline for clinicians transitioning to the 2015 Edition to provide the necessary infrastructure for the kind of patient- and family-centered health system our country urgently needs.