Electronic Health Reporter

If for no other reason, the following open letter seems worthy of publication. It was sent by HIMSS to HHS’ secretary Sylvia Mathews Burwell on Sept. 30, 2014. The four-page letter, published below for your review, lays out the organization’s professional and political goals for the near term.

HIMSS makes three specific recommendations to HHS, suggesting to the feds where their attention should focus. HIMSS’ recommends immediately pulling three key policy levers: the EHR incentive program, interoperability leading to secure electronic exchange of health information, and electronic reporting of clinical quality measures (CQMs).

HIMSS also makes the strong recommendation for one three-month reporting period in 2015 for meaningful use, as well as publicly reminding HHS that there continues to be support efforts for interoperability. The letter does little than offer a pat on the back to HHS for its efforts, and says that HIMSS offers its support for everything HHS is doing, but the letter also serves as a real reminder that HIMSS is willing to flex a little muscle on behalf of its members if HHS doesn’t listen up or do a little falling in line.

To be clear, I have nothing against HIMSS; if they can get away with telling a federal organization how it is, that’s admirable. However, the letter is soaked with arrogance and bullishness, as if HIMSS is intentionally telling all in healthcare just how big and powerful it is, dammit. No doubt, this is the type of thing that’s gone on for years. I understand how lobbyists work; in fact, I’ve worked with them and understand their game. This is probably just the first time in a while I’ve seen such a blatant outreach effort. After all, it’s not like HHS doesn’t know who or what HIMSS as an organization is, but it seems strong in a nuanced way.

Judge for yourself and read the letter below. Are you a HIMSS member? What do you think of the organization’s power push?

Here’s the letter in full:

On behalf of the Healthcare Information Management and Systems Society (HIMSS), we would like to express our commitment to working with you to ensure Department of Health and Human Services (HHS) programs fully utilize the tools offered by health information technology (health IT). Health IT is an essential, foundational element of any meaningful transformation of the nation’s healthcare delivery system. With this foundation in mind, we suggest that what is needed now in the lifecycle of the health IT environment is a holistic review and strategy for all the relevant, crosscutting programs and initiatives.

HIMSS is a cause-based, global enterprise producing health IT thought leadership, education, events, market research and media services around the world. Founded in 1961, HIMSS encompasses more than 57,000 individuals, of which more than two-thirds work in healthcare provider, governmental and not-for-profit organizations, plus over 640 corporations and over 400 not-for-profit partner organizations that share this cause.

Overall, providers and IT professionals continue to strive to harness the power of IT to improve the experience of care, improve the health of populations, and reduce per capita health care costs. However, we are increasingly concerned; we are witnessing mounting frustration across the healthcare community that HHS’ expectations are not realistic. While we champion a vision of coordinated care leading to a positively transformed health system in the United States, we want to express our concerns that the road to that goal has become rocky and offer solutions to address these concerns.

To help re-establish manageable expectations, HIMSS offers to work with HHS to devise a comprehensive plan to address all health IT issues germane to transforming the nation’s health care system. The National Coordinator’s intent to revise the Federal Health IT Strategic Plan presents such an opportunity, and we welcome the opportunity to work with ONC to review the multitude of overlapping programs, determine how they currently fit into the larger health IT blueprint and formulate a best approach to revising expectations and timelines working within congressional and Administration intent.

HIMSS recommends focusing on the three key policy levers: the EHR Incentive Program, interoperability leading to secure electronic exchange of health information, and electronic reporting of clinical quality measures (CQMs).

Meaningful Use/EHR Incentive Program

There are profound challenges associated with the transition to 2014 certified EHR technology and requirements for preparing the data to be transmitted, particularly as they relate to view/download/transmit and transitions of care. For eligible hospitals, eligible professionals, and critical access hospitals not in their first year of the program, the 2015 requirements for 12 months of MU reporting are daunting.

HIMSS urges CMS to adjust the 2015 requirement to one three-month quarterly reporting period versus a full year.

As originally envisioned by Congress in 2009, the Meaningful Use program serves as a means of creating the IT infrastructure necessary to improve the quality of care, population health, and cost containment in the United States. Due to the census-level data available via the HIMSS Analytics Electronic Medical Record Adoption Model (EMRAM), we can show hospitals and tethered ambulatory facilities’ dramatic growth in adoption of technologies that support care coordination.

HIMSS has consistently communicated to HHS that the MU program must be reasonable and manageable for all affected stakeholders. In multiple MU-related comments submitted to your agencies, we have urged flexibility in the timeline, urged addressing certification challenges, and expressed concern over the increasing fluidity of the quality reporting structure. Such challenges present barriers to greater success in the program.

We are increasingly concerned that policymakers and providers are losing confidence in the program.

Because it increases the odds of most US-based providers being able to coordinate a patient’s care, HIMSS believes it is important to maximize the number of providers involved in the MU program. As mentioned above, our most immediate concern is the timeline for participation in MU during in 2015, particularly the requirement for year-long reporting. Based on current program requirements, we are facing a situation in which providers may be facing a choice of either ensuring patient safety or complying with regulatory guidelines: because 2015 MU requires too much in too-short a timeframe, rushed IT implementations could result in patient harm. No provider would choose such an outcome; hence, our concern that many may decide to not participate further in the program.

As we prepare for MU Stage 3, we want to keep the government and the private sector focused on practical and realistic expectations, thus enhancing the probability of achieving the intent of the MU program in supporting healthcare transformation. We support the notion that the next phase of the program should include a less prescriptive measure set that fosters data sharing and programmatic growth.

Interoperability

There continues to be widespread, bipartisan support for efforts to move toward a secure, interoperable healthcare system that rewards efficiency and quality outcomes by enabling providers and patients to secure access of the right information at the right time.

We appreciate your comments during National Health IT Week on the important role interoperable systems have in advancing care coordination. We share your vision that the nationwide adoption of EHRs and health information exchange enables the positive transformation of the American healthcare system, including encouraging greater patient engagement and empowerment, expanding access, improving quality, and helping to control costs.

As an organization, HIMSS is committed to supporting and educating all stakeholders in the utilization of secure health information exchange to improve the quality and cost effectiveness of care delivery. We are committed to continuing leveraging our resources and the subject matter expertise of our diverse stakeholders to ensure all communities have access to the tools necessary to share health information in a secure and appropriate manner. We will continue

to leverage our strength as a convener to bring the health community together to identify and execute on an achievable interoperability roadmap.

To that end, we appreciate ONC’s ongoing efforts to identify potential solutions, and we pledge to continue working with ONC to achieve a nationwide, interoperable health IT infrastructure. Overall, HIMSS supports ONC’s vision and the creation of its five building blocks, published in June, 2014. We offer several recommendations refining ONC’s framework and areas of emphasis, including:

• Work with stakeholder organizations to recognize and manage the complexity of a diverse healthcare system;
• Focus on being a convener to drive consensus;
• Consider incentives for providers that implement certified products that achieve the specified aspects of interoperability and information exchange beyond MU;
• Support the use of public and private policy levers beyond MU to foster interoperability and exchange;
• Encourage non-federal incentives and market imperatives to ensure greater community engagement;
• Leverage HIMSS’ definition of interoperability (foundational; structural; and semantic);
• Bring resources to bear for information security; and,
• Facilitate use of patient privacy preferences.

We are committed to working with HHS to further an interoperable, secure health IT environment. We are submitting detailed comments to ONC on its interoperability vision, and look forward to working collaboratively with ONC on Version 1.0 of a nationwide interoperability roadmap.

Clinical Quality Measures (CQMs)

HIMSS appreciates the several revisions that CMS has made to CQM reporting requirements for MU to ease the reporting burden on providers. However, there are several actions that need to be taken.

Since the publication of the Medicare and Medicaid EHR Incentive

Program Stage 2 Final Rule in September 2012, providers and vendors have reported significant challenges associated with

eCQM reporting requirements. Some of the specific challenges that have been identified include:

• eCQMs introduced without prior robust testing for validity, accuracy and feasibility, and, as a result, numerous errors uncovered in real time requiring specification updates;
• CMS has updated every MU eCQM specifications at least twice, and in some cases, up to four times;
• The published specifications include no indicator of changes;
• eCQM specifications are hard to find and they are lengthy;
• There is no “single source of truth”–currently, eCQM definitions and specifications sit on three different HHS websites.

On the eve of MU Stage 3 and the continued alignment between other CMS quality improvement and quality reporting programs, HIMSS will develop a multi-stakeholder IT roadmap for overcoming these key barriers.

To maximize impact, HIMSS welcomes the Department’s involvement. Our goals include:

• Review and refresh current recommendations for overcoming key barriers to robust electronic reporting of clinical quality measures that build upon the current collaborative work being conducted by ONC, CMS, and the National Quality Forum.
• Develop a roadmap for transitioning to mandatory HER-enabled CQM reporting for all CMS quality reporting and value-based purchasing programs, including the development of measure sets consisting only of eCQMs specifically designed to capture critical data as part of the normal clinical workflow.

HIMSS is committed to working with you to identify the programs, help determine how they can interact more effectively, and communicate the issues that stakeholders have identified where they need resolution to ensure the success of the individual programs as well as the overall field of health IT.

We look forward to the opportunity to meet with you and your team to discuss these issues in more depth and determine a path forward. Please feel to contact Thomas M. Leary, Vice President of Government Relations, at 703.562.8814, or Jeff Coughlin, Senior Director of Federal & State Affairs, at 703.562.8824 with questions or for more information.

Sincerely,

Paul Kleeberg, MD, FAAFP, FHIMSS

Chairman, Board of Directors

Chief Medical Informatics Officer

Stratis Health

H. Stephen Lieber, CAE

President & CEO

cc:

Marilyn Tavenner, RN, Administrator, Centers for Medicare and Medicaid Services

Karen DeSalvo, MD, MPH, MSc, National Coordinator for Health IT