When it comes to accessing nationwide healthcare interoperability progress, the measurement should not only be the exchange and use of electronic health information, but whether there are standards, technology and infrastructure in place to facilitate exchange, according to the American Hospital Association (AHA).
In a letter to Karen DeSalvo, M.D., U.S. Department of Health and Human Services (HHS) Acting Assistant Secretary and National Coordinator for Health Information Technology (ONC), the AHA offered recommendations on how best to access progress on achieving interoperability and the sharing of health information. The comments are in response to ONC’s request for information, issued back in April, for public input on how to measure interoperability.
In a blog post in April, Seth Pazinksi, director of ONC’s Office of Planning, Evaluation and Analysis, and Talisha Searcy, director of research and evaluation at OPEA, wrote, “The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) declares it a national objective to achieve the widespread exchange of health information through the use of interoperable certified electronic health records and directs the HHS to establish metrics in consultation with you—the health IT community—to see if that objective has been met.”
Specifically, ONC is asking for input on three topics—the populations and elements of information flow that should be measured, how to use current data sources and associated metrics to address the MACRA requirements and additional data sources and metrics that should be considered to measure interoperability more broadly.
In the letter, written by Ashley Thompson, senior vice president of public policy analysis and development at AHA, the organization says it supports ONC’s efforts to measure interoperability progress, yet recommends that the agency “expand its scope of measurement beyond just the exchange and use of electronic health information to include whether we have the standards, technology and infrastructure needed to support these goals.”
Specifically, AHA recommends that ONC consider developing measures about the extent to which the health IT community has the standards, technology and infrastructure in place to facilitate exchange.
“Data have shown that we do not currently have a sufficiently robust infrastructure to support exchange. For example, in the 2015 Health IT Supplement to the AHA Annual Survey, 51 percent of more than 3,500 respondents (unweighted data) indicated that they face challenges exchanging data across different platforms, suggesting lack of standardized approaches. In addition, 52 percent (unweighted data) reported that they have difficulty locating the address of a desired recipient, due to the lack of widely available provider directories. These are just two of the infrastructure items that must be in place for providers to effectively exchange and use electronic health information,” Thompson wrote.
AHA also recommends that ONC broaden the scope of data sharing it measures beyond data that’s exchanged.
Thompson wrote, “Exchange, or the transmittal of information from one place to another, is an important means of sharing health information and is worth measuring to some extent. However, other mechanisms also can be used to accomplish the goal of ensuring that providers have access to the information they need for care.”
Thompson cites, as an example, hospitals and health systems sharing information with clinicians and post-acute care providers by offering access to shared data systems. “This type of sharing can be more efficient and effective than exchange, as the latest data are always available and clinicians with appropriate access rights may access it whenever needed. The RFI does not contemplate this type of sharing, although it clearly fulfills the goals of ensuring data are available for care. We recognize that this type of sharing will be challenging to measure, and may not be available in a quantifiable format. However, we believe that the true extent of information sharing should be reflected in ONC’s assessments,” Thompson wrote.
And, AHA also recommends that ONC look to large proxies of “use” of electronic health information, as “use” of health information will be challenging to measure, beyond receipt of information. The AHA notes that hospitals and health systems are building information systems needed to share data in order to support new models of care. Therefore, Thompson wrote, expanded participation in alternative payment models (APM) could be considered an outcome measure for interoperability.
With regard to data sources and metrics that HHS should consider to measure interoperability, AHA suggests using the AHA Health IT Supplemental Survey. In addition, AHA cautions the agency against using meaningful use data to measure interoperability, as the “meaningful use exchange requirements really only reflect the exchange of a specific electronic document to provide a summary of care, using a specific type of exchange standards,” Thompson wrote. “As a result, these measures do not reflect the true extent of information sharing that is happening.”
The AHA recommends ONC look at success with meaningful use, the Merit-Based Incentive Payment System (MIPS) and alternative payment models “rather than assessing specific measures within those programs.”
With regard to ONC’s request for input on how the agency should best determine whether the nation has achieved “widespread” interoperability, Thompson wrote, “Given that our abilities to share information are evolving, the AHA recommends a nuanced view that balances what we have achieved against what is currently possible, rather than a numeric cut-off.”