In a May 7 letter to CMS Acting Administrator Marilyn Tavenner, the Consumer Partnership for eHealth said that the EHR incentives should not just promote health IT but should also help to achieve such goals as promoting partnerships between patients and care teams, improving the coordination of care, increasing health equity, and enabling new payment and care delivery models.
Before explaining how CMS' MU Stage 2 proposal could be improved to meet these goals, the Partnership's letter sought to squelch calls from the AHA and other healthcare associations for a 90-day reporting period in the first year of Stage 2, instead of a full-year period. While that would allow doctors and hospitals more time to prepare, the consumer coalition noted that they'd already been granted a one-year postponement from 2013 to 2014 and argued that that was enough.
The Partnership also implored CMS to hold fast to its proposal that providers be held accountable for ensuring that at least 10% of their active patients view, download, and/or share their online medical records. The AHA says this is not feasible for hospitals, and the AMA also objects to making physicians responsible for the actions of their patients.
This is much ado about nothing, in the view of Christine Bechtel, VP of the National Partnership for Women & Families (NPWF), a coalition member. A recent NPWF survey showed that 80% of consumers with online access to electronic health records used it, Bechtel told InformationWeek Healthcare. "If providers put the right workflow in place and they have the right conversations with their patients," getting 10% of patients to view this data "should be a layup," she said.
The consumer coalition also suggested shortening the proposed time frame for requiring that health records be made available online to patients from 36 hours to 24 hours after a hospital discharge or an office visit. The AHA, in contrast, proposed lengthening the period to 30 days--a position that has drawn fierce objections from Bechtel and other consumer advocates.
Speaking to InformationWeek, Bechtel said, "When you're discharged from a hospital, the clock is ticking, and there are certain things you need to know and do to prevent going back to the hospital unnecessarily. Time is really of the essence, and no provider disputes that."
Since hospitals attesting to Meaningful Use are using EHRs, she added, they should be entering data as patients are diagnosed and treated, and it should be no problem to make that information available online within 24 hours of a visit or discharge.
The Partnership also wants CMS to beef up its health information exchange (HIE) criteria. For providers attesting to Stage 1 of Meaningful Use in 2013, it would have CMS replace the current requirement to test HIE capability with at least one case of actual transmission of a care summary from one provider to another. In Stage 2, the coalition would raise the threshold for electronic exchange of care summaries during transitions of care from 10% to 50% of patients.
"Having to only send 10% of care summaries electronically and let the rest be on paper is too low of a bar," because it doesn't support effective care coordination, explained Bechtel, who is a member of the Health IT Policy Committee that advises CMS on Meaningful Use requirements. One way for providers to meet the higher threshold, she suggested, is for providers to use the direct messaging protocol to exchange clinical summaries with providers that are not Meaningful Users, including nursing homes and home health agencies.
In addition, the Partnership argues that CMS should scrap most of the clinical quality measures in its proposal that address processes of care, such as whether a patient with diabetes received an eye exam or whether a heart attack victim was given aspirin in the hospital. Instead, the consumer advocates want CMS to focus on outcomes-related measures such as functional status assessments after knee and hip replacements and whether caesarian sections were appropriately done.
Although outcomes measures are limited today, Bechtel insisted that it's feasible to use them where they exist. "We're saying, 'Don't include measures that are basic standards of practice. Instead, just include measures that are tested and validated but are oriented to outcomes.' Because that's what the HITECH Act requires--using an EHR to actually improve outcomes."
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