On May 29, WHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC), urging CMS and ONC to advance interoperability in a way that reduces the burden on providers of using electronic health records (EHRs).
WHA’s comments were submitted to the two agencies in response to a request for comments on two proposed rules related to health care interoperability, which refers to the capacity to send and receive a patient’s health information from multiple sources between different systems and locations.
In its letters, WHA voiced its support for interoperability as a way to improve health care coordination, safety, and quality; to empower patients; and to increase efficiency. WHA recommended that as CMS and ONC work to advance our mutual goals of interoperability, they do so in a way that reduces the burden on providers of using EHRs and aligns mandated EHR use with provider workflow and patient need.
“Because regulatory burden creates additional health care costs and limits provider productivity, reducing EHR-related burden on physicians and hospitals is a priority for WHA,” the two letters say. “We believe that [CMS and ONC] should minimize EHRrelated regulatory burdens and ensure that any additional EHR investments, additional time spent using EHR technology, or adjustments to workflow that are necessary to comply with regulatory requirements are outweighed by health care cost savings and improvements in patient outcomes.”
Highlights of the two WHA letters include the following recommendations to CMS and ONC:
- WHA urged CMS not to finalize its proposal to amend the hospital, psychiatric hospital, and critical access hospital Conditions of Participation to require such hospitals to send patient event notifications for admission, discharge, and transfer. The proposed mandate would create significant burden for hospitals without meaningfully improving health care quality, safety, and efficiency.
- While WHA supported CMS’ intention to promote adequate pathways for sharing administrative data by health care insurers, the proposed 2020 effective date for CMS’ proposals to require insurer data-sharing may be too aggressive to ensure payers have sufficient time to be able to share such data safely and securely.
- WHA urged ONC not to mandate that hospitals and other health care providers disclose price information and instead urged ONC to work together with insurers and providers to determine the best way to bring price information to consumers in a way that improves access to health care in a free market.
See WHA’s comment letter to CMS
, WHA’s comment letter to ONC
, and the CMS proposed rule
For more information, contact WHA Assistant General Counsel Andrew Brenton at 608-274-1820.