The Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health IT (ONC) have published several proposed rules, draft guidance documents, and requests for information (RFIs) – as well as one final rule – over the last several months. By and large, these measures have focused on supporting the shift to a value-based care delivery model, and away from a fee-for-service, volume-driven environment.
HIMSS continues to pay close attention to these government actions and is looking for opportunities to ensure that health information and technology are appropriately positioned in these efforts. Here is a roundup of some of my key takeaways thus far from these government actions.
It’s Not Business as Usual Anymore
The Trump Administration has spent its first 20 months in office re-evaluating every policy decision made during the Obama Administration and determining if there is a different approach they want to take. In addition to their work on the Affordable Care Act, President Trump’s Department of Health and Human Services (HHS) has undertaken extensive changes for other programs, such as the Meaningful Use Program (now Promoting Interoperability), Quality Payment Program (QPP), Medicare Shared Savings Program, quality reporting paradigms, and interoperability/data sharing initiatives. HHS is headed toward finalizing significant modifications of previous policies – for many of the reasons discussed below – and exhibiting a real openness to consider new directions.
Many changes have been legislatively driven (through enactment of the 21st Century Cures Act, for instance), but there has also been a real willingness to re-interpret existing statute. Thus far, changes that have been implemented on telehealth and remote patient monitoring in the 2018 Physician Fee Schedule (PFS) – with potentially more adjustments on the way in the 2019 QPP/PFS Proposed Rule – and, CMS is considering far-reaching changes to the Medicare/Medicaid Conditions of Participation as well as the Physician Self-Referral Rule. Evaluating changes in many of these areas is long overdue, but I think that it’s taken a fresh perspective from a new Administration to even ponder publication of these RFIs and to consider future modifications.
The Patient is Paramount
One cross-cutting theme has been a real focus on the patient – activating, engaging and prioritizing the needs of patients. A major part of this work is reliant on greater data exchange by breaking down the barriers that prevent patients from having electronic access and true control of their own health records from the device or application of their choice. This theme is being operationalized in several programs, including:
- MyHealthEData Initiative: Empowers patients by giving them control of their healthcare data, and allowing it to follow them through their healthcare journey
- Medicare’s Blue Button 2.0: Creates a new and secure way for Medicare beneficiaries to access and share their personal health data in a universal digital format, by enabling traditional Medicare beneficiaries to connect their claims data to the secure applications, providers, services and research programs they trust
The overarching focus that CMS and ONC are putting on the patient is impressive and will likely continue to be built upon in future actions.
Looking to Leverage Information and Technology
Most of the topics that I have raised are dependent upon information and technology – whether its data exchange, telehealth, the promise of electronic health records, or Blue Button 2.0, each plays an important part in supporting the shift to value as well as delivering even better and safer care. The portfolio of issues that we must address in health IT advocacy is ever-expanding given the growing importance of information and technology across the entire healthcare sector. CMS, ONC, and the entirety of agencies within HHS, are finding new and innovative ways to leverage health information and technology across their programs and increase its applicability in burgeoning areas.
Clinician Burden is Front and Center Across All Programs
The path that HHS is pursuing to implement all these programs is extremely cognizant of minimizing or reducing the burdens that are placed on clinicians, which the Department is referring to as the Patients Over Paperwork Initiative. CMS and ONC are looking at this issue holistically, and are including regulatory, administrative, documentation and reporting burdens in their review and action plans (HIMSS collaborated to submit comments on some potential solutions in June 2018).
The idea behind minimizing burden is very patient-focused – with relieving burden defined as an opportunity to spend more face-time with patients and eliminating the unnecessary actions that occur in the course of clinical practice.
CMS has already recommended great strides to reduce burden, especially in the 2019 PFS/QPP Proposed Rule, by streamlining Evaluation and Management documentation and payment processes as well as other changes on the QPP side.
Overall, CMS and ONC are using their burden-related actions to help practitioners deliver better care by allowing them to focus their time on actions that make sense and appropriately using information and technology.
So, What is HIMSS Doing?
The HIMSS team continues to build up our portfolio on all these issues, trying to understand the specifics and nuances so that we can not only advise the government, but inform our members on HIMSS’s perspective and help them magnify our advocacy messages across the community.
We want to continue to position HIMSS as a thought leader and advocate for supporting the shift to value-based care and how information and technology contribute to that future state, as well as more ubiquitous and seamless interoperability, greater innovation in the field, and better engagement and activation of patients.
We’re on the right path – and, we’ll keep working to ensure that we’re heard and at the forefront of any government policy actions.
If you have comments, further thoughts, or want to get involved in our advocacy activities, please feel free to reach out via email.