The AAFP made detailed suggestions to improve CMS’ recently announced initiative to improve patients’ access to and control of their electronic health data.
March 22, 2018 04:11 pm News Staff – The AAFP is working to propel a new CMS initiative meant to give patients better access to — and control of — their health care data into action that improves patient care and reduces physicians’ administrative burden.
CMS Administrator Seema Verma, M.P.H., publicly unveiled the MyHealthEData Initiative(www.cms.gov) on March 6 during a speech(www.cms.gov) at the Healthcare Information and Management Systems Society annual conference in Las Vegas.
She told her audience the United States will never achieve the long-sought goal of value-based care “until we put the patient of the center of our health care system.”
Verma said the Trump administration is determined to ensure that patients “have the information they need to be engaged and active decision-makers in their care.”
A CMS press release(www.cms.gov) noted the initiative is headed up by the White House Office of American Innovation with active participation from HHS, CMS, the Office of the National Coordinator for Health IT, NIH and the Department of Veterans Affairs.
- The AAFP recently responded to CMS’ announcement about its MyHealthEData Initiative with a letter outlining suggested improvements.
In a letter to CMS Administrator Seema Verma, M.P.H., the AAFP urged CMS to require vendors to provide any new government-required updates to electronic health records systems without additional cost to medical practices.
- The letter also urged the agency to utilize the AAFP’s Principles for Administrative Simplification to reduce physician documentation requirements.
- Midway through her speech, Verma related a personal story about a recent out-of-town health emergency in her family that led to her husband’s hospitalization. After his discharge, Verma asked for a copy of the complete medical record amassed during the inpatient stay to ensure that doctors back home had all the information they would need for follow up care.
“After the federal government has spent more than $30 billion on EHRs (electronic health records), I left with paper (five sheets) and a CD-ROM” that was both difficult to utilize and incomplete, said Verma.
“I couldn’t help but contemplate the disconnect between the genius of the medical system that used the latest technology and science to save my husband’s life but didn’t have the tools available to just give me his medical records, which I thought would have been the simplest task out of all they had performed,” she said.
Verma also announced an update to the agency’s Blue Button initiative, calling the new Blue Button 2.0(bluebutton.cms.gov) a developer-friendly, standards-based application programming interface “that enables Medicare beneficiaries to connect their claims data to secure applications, services and research programs that they trust.”
AAFP Weighs In
The AAFP has advocated long and hard for interoperability of EHRs and supports certain portions of the new initiative; however, other key points raised eyebrows among Academy leaders.
In a March 14 letter(4 page PDF) to Verma signed by AAFP Board Chair John Meigs, M.D., of Centreville, Ala., the AAFP weighed in on important portions of the initiative during its formative stages to ensure the final program doesn’t create more obstacles to already overburdened family physicians.
The AAFP noted its approval of agency efforts that “encourage patients to have meaningful control of their data” and to improve interoperability and administrative simplification.
“We would, however, object to placing responsibility for the adoption of interoperable systems on physician practices,” the Academy stated. “The creation of standardized interoperable systems should instead be the responsibility of vendors.”
The AAFP pointed out that physicians were promised EHR interoperability and secure patient access when they purchased certified EHR technology or upgraded their existing systems; however, many systems do not meet this standard.
Lack of this promised interoperability leaves physicians beholden to EHR vendors — a situation that has allowed vendors to engage in price gouging when peddling software upgrades and maintenance.
“We strongly urge CMS to require EHR vendors to provide any new government-required updates to such systems without additional cost to the medical practice,” said the AAFP.
Multiple studies have shown that physicians spend far too much time — up to 50 percent of their workday and even after clinic hours — using their EHRs, said the AAFP, referencing a Feb. 7 letter(6 page PDF) to Verma.
“CMS must take the time and financial costs physicians endure into account while addressing improved patient access to health care data,” said the Academy in its most recent comments.
Stop Information Blocking
In her speech, Verma zeroed in on CMS’ intent to prevent providers and hospitals from blocking patients — and their physicians — from seeing personal health data. “We will not tolerate this practice anymore,” she said.
In response, the AAFP noted that too often physicians receive summaries of care that are too long and “filled with clinically irrelevant information.” Indeed, said the letter, unnecessary information often is inserted into summaries by automated processes “designed to ensure compliance with CMS regulations and requirements for the MU (meaningful use) and ACI (advancing care information) programs.”
The AAFP told CMS to improve its regulatory requirements and focus on “how and when data is exchanged rather than focusing on the data in the exchange.”
Furthermore, the AAFP called on CMS to use the authority it was granted in the 21st Century Cures Act(www.fda.gov) to penalize health care organizations that are not sharing information.
“Policies should be focused on penalizing bad actors blocking information,” the Academy said in its letter.
Streamline Documentation, Billing Requirements
The AAFP pointed out that the level of documentation required of physicians has escalated in recent years despite the widespread adoption of EHRs. In particular, the Academy took issue with CMS’ documentation requirement guidelines for evaluation and management (E/M) services.
The letter argued that the guidelines, written for use 20 years ago in a paper-records era, “do not reflect the current use and further potential use of EHRs or team-based care.”
CMS should recognize and adhere to the AAFP’s Principles for Administrative Simplification to reduce documentation requirements. In these principles, the AAFP calls for
eliminating documentation guidelines for E/M codes 99211-99215 and 99201-99205 for primary care physicians;
applying a new standard to all public and private payers to allow medical information to be entered into a patient record by any care team member related to a patient’s visit;
discarding data templates and box-checking requirements that do not enhance patient care; and
redesigning and optimizing EHR systems through the collaborative efforts of physicians, vendors and workflow engineers.
Improve Related Programs
The AAFP addressed additional points in its letter to CMS, including suggestions related to
streamlining requirements associated with meaningful use and the Quality Payment Program’s advancing care information component;
interoperability of quality measures, including elimination of all health IT utilization measures and implementation by all payers of the Core Quality Measures Collaborative’s core measures sets championed by the AAFP;
widescale interoperability of patient admission, discharge and transfer data in as close to real time as possible; and
reducing hospital admissions and readmissions, and duplicative testing.
“With the modifications we have suggested and attention to other overarching health care IT issues as outlined above, we believe these programs will lead to great success for our patients by catalyzing better, more efficient quality care,” concluded the AAFP.
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