03 Jun Comments on CMS Interoperability Proposed Rule
The Health Care Transformation Task Force (HCTTF or Task Force) responded to the proposed policies to advance interoperability and patient access to health information. The Task Force appreciates CMS’s commitment advancing interoperable data exchange. We support the goals of giving patients ownership over their health data; allowing providers to provide the best care to patients; and supporting payers in providing efficient care coordination and coverage. Our members have deep experience with value-based payment models and have identified effective and timely data sharing as one of the most critical – yet most challenging – factors enabling improved health outcomes, reduced costs, and patient-centered care. As the Task Force has commented previously, access to timely, accurate, and actionable data fuels successful population health management and patient engagement while supporting providers’ and payers’ transition to value-based health care.
Task Force Response Summary
- General Reactions. Provider and payer organizations are concerned that the proposed 2020 implementation date for many of the provisions does not factor in the current limitations and complexity that may hinder value-driven organizations’ ability to comply. Additional time would allow organizations to prepare systems, perform data mapping and testing, allow applicable data standards to be developed and more widely adopted across the industry, and would better align with timing of other related federal policies, such as the Trusted Exchange Framework Common Agreement.
- RFI on Advancing Interoperability in Innovative Models. Ensuring that model participation agreements and other governing documents remain internally consistent with CMS and ONC regulations is critical. We also support and recommend that CMS prioritize solutions that improve cross-sector and nonclinical data sharing in future CMMI models. These data points can provide key information on social determinants of health that often have a more significant impact on outcomes than medical interventions. CMS can support improved interoperability by expanding electronic real-time availability of patient claims and clinical data – such as through a provider portal – to help participants in APMs to drive continuous improvement.
Letter submitted on June 3rd, 2019.