Washington, DC (May 31, 2019) – The American College of Physicians (ACP) thanked the Office of the National Coordinator for Health information (ONC) and the Centers for Medicare and Medicaid Services (CMS) for taking steps to improve interoperability, promote patient access to their health information, address information blocking, and revamp the ONC electronic health record (EHR) certification program.
“ACP appreciates CMS and ONC working together to promote health IT standards,” said Zeshan Rajput, MD, MS, chair of ACP’s Medical Informatics Committee. “Effective interoperability is crucial to improving the patient experience, reducing burden on physicians, restoring the patient-physician relationship and, in turn, improving the quality of care.”
In letters submitted today, and outlined below, ACP discussed a number of recommendations to further improve both agencies’ proposed rules, and expressed concerns.
Promoting Data Access while Upholding Patient Privacy, Security, and Patient-Centered Care
- Efforts to promote access to data and improve interoperability should be done in stages so that their effects on patient care, privacy, and security are adequately demonstrated and the risks of data overload and data without context are mitigated.
- ACP commended both ONC and CMS for promoting modern interoperability standards and the use of apps to access data, but highlighted a number of patient privacy issues that could arise when allowing third-party app developers to access sensitive and private health information on behalf of the patient.
- ACP emphasized how promoting patients’ rightful access to their health data without requiring necessary privacy and security controls presents a very real risk and will ultimately affect the patient-physician relationship.
- When promoting price information access and transparency, ACP reiterated that price should never be used as the sole criterion for selecting a physician or service; it should always be accompanied by performance information critical to understanding the total value of care, such as metrics about patient safety and health outcomes.
Reducing Unnecessary Burden in Meaningful Ways
- ACP expressed appreciation for ONC’s extensive work to describe information blocking activities and exceptions to information blocking, but expressed concerns around the downstream, and likely burdensome, effects these provisions will have on physician practice.
- The information blocking provisions and exceptions are complicated and overlap with long-standing federal and state privacy laws. ACP warned it will be extremely difficult for physicians to understand and establish policies to adhere to these regulations.
- Instead of focusing on sharing every piece of health information ever collected, ACP recommended focusing on access to a core set of accepted data elements at first, and continue to evolve that data set to include the meaningful, high-yield data that have shown to be the most useful in current health information exchange practices.
Establishing Reasonable Timelines
- ACP emphasized that physicians need adequate time to test new health IT systems and train clinical staff – for that reason, ACP recommended physicians be given at least six months, if not a full year, to implement upgraded systems once it is made available to them by their vendors.
“ACP appreciates CMS’ efforts to bring key payer, physician, hospital, and patient players to the table to address this important issue,” said Dr. Rajput. “We look forward to working with both agencies to improve patient care and make sure that these proposed rules help clinicians find and use patient information without increasing cost or administrative burdens.”
About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 154,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter, Facebook, and Instagram.
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