Society Joins in Comments on CMS’ Interoperability RFI

June 28, 2018
Policy Snapshot

The Society joined with the LTPAC HIT Collaborative to submit comments in response to CMS’ request for information (RFI) on interoperability. The Collaborative is a public-private group of stakeholder organizations representing associations, providers, policy-makers, researchers, vendors, and professionals with a mission to coordinate the sector and maintain alignment with the national priorities. The Collaborative was formed in 2005 to advance health information technology (HIT) issues by encouraging coordination among provider organizations, policy-makers, vendors, payers, and other stakeholders. Collaborative members include national associations representing clinicians, providers, information technology developers and researchers with expertise in the long-term and post-acute care (LTPAC). The comments stressed that a unified approach to the various current initiatives is necessary to give a clear indication that the LTPAC space can work together with acute care partners to achieve interoperability.

One key piece necessary to improve the workflow of clinicians, reduce errors, and improve patient care is to focus on key information necessary for clinicians to make important decisions in real time. “We recommend that CMS focus on clearly defining ‘medically necessary

information’ to be exchanged as well as ensuring that information can be exchanged in an interoperable manner,” stated the Collaborative letter.

One of the key complaints the Society has heard from clinicians is that they receive hundreds of pages of information and must spend hours figuring out the latest lab results and medication lists. This information usually comes in the form of a .PDF and is not usable in their electronic health records. The Collaborative urged CMS to build on its work with the Data Element Library (DEL) and the U.S. Core Data for Interoperability (USCDI) to define what medically necessary information is needed during care transitions.

The Collaborative urged CMS not to put any interoperability requirements into the hospital conditions of participation and instead to use a more incentive-based approach to timely exchange of information. “While we agree changes are needed, we believe it is premature to pull this policy lever as the infrastructure is not fully in place and there are many more steps to take to incentivize timely exchange of health information before considering changes to CoPs. Therefore, at this time we do not believe that changing the Medicare & Medicaid Conditions of Participation (CoPs) is the best way to encourage more timely exchange of information” stated the Collaborative letter.

The Society looks forward to working with its Collaborative partners, CMS, and other stakeholders to promote HIT adoption and data exchange to improve clinician workflow and patient care.

To read the full comment letter click here.