There are big changes in the midst for EHR incentive programs. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was passed by the Senate on April 14, 2015 (92–8) and was subsequently signed into law by President Barack Obama just over a year ago. MACRA’s primary function is to establish new ways to pay doctors who treat Medicare patients, and it has many provisions relating to health IT programs, such as Meaningful Use.
In MACRA, HHS was required to submit a report to Congress on methods to aid providers in comparing and selecting certified EHR technology. To do this, The Office of the National Coordinator (ONC) created a Joint Health IT Policy and Standards Committee Certified Technology Comparison (CTC) Task Force. The task force was charged with providing recommendations on the benefits of, and resources needed to develop and maintain, a certified health IT comparison tool.
The CTC Task Force mandate was to:
- Identify the different health IT needs for providers across the adoption and implementation spectrum, with particular focus on providers with limited resources and/or lower adoption rates
- Identify user needs for a comparison tool
- Identify gaps in the current tool marketplace, and the barriers to addressing those gaps
This process is of significant importance to AmericanEHR. We’ve been providing clinicians with free EHR satisfaction comparison tools and rating data since 2010. In those 6+ years we’ve had hands on experience with every aspect of technology comparison, including: site governance; comparison platform and rating system development; community building; data management; API integration; feedback management; data visualization; mobile responsiveness; and so much more.
AmericanEHR was invited by ONC to participate in a CTC Task Force Virtual Hearing held on Jan. 15, 2016. We presented verbal testimony, and made a written submission which you can view here.
There was also valuable feedback from representatives of some AmericanEHR supporting organizations during the hearing:
Steve Waldren, Director, Alliance for eHealth Innovation, American Academy of Family Physicians (an AmericanEHR Partner Organization) said: “Doctors need to be paired up with peers in like practices.” He also stressed some key elements for success in Health IT Comparison:
- It requires a strong social component
- It requires compatibility information
- Focus should be on outcomes
- The government should support a common infrastructure
- Transparency is needed
Todd Rothenhaus, SVP/Chief Medical Officer, athenahealth (an AmericanEHR Participating EHR Vendor) said: “We can’t envision the government as a consumer reports for Health IT.” He also stated that there are already well-respected companies providing health IT comparison data, including AmericanEHR, and that government provided comparison data like “CHPL [Certified Health IT Product List] is confusing, and difficult to navigate,” and that “too much of the data currently available is focused on CIO’s and there isn’t enough focus on doctors.”
Note: All of AmericanEHR’s ratings come from actual EHR system users: physicians, nurse practitioners, and physician assistants. You can learn more about our rating methodology here.
I’ve spoken publicly on the topic of Heath IT Comparison and Ratings on numerous occasions. On September 11, 2012 I presented at the Health IT Meaningful Usability Summit in Washington DC alongside representatives from Congress, The Office of the National Coordinator, The Institute of Medicine, Caregivers and Healthcare Providers. After presenting AmericanEHR data, I put forward some suggestions at that summit that I believed would promote greater health IT usability:
- Providers need to share experiences openly
- Incentive funding could be linked to mandatory product ratings
- Certification should incorporate benchmarks for satisfaction
- Transparency should be facilitated by disallowing “gag orders” for certified products
- Vendors should be able to leverage user feedback in order to make product and support improvements
These themes are still relevant today, and they have shaped our direction over the years. In order to develop our tools, AmericanEHR spent a year working with our medical society partners developing governance prior to collecting our first satisfaction survey. We facilitated feedback across multiple specialties, and also engaged an EHR Vendor Advisory, and a Clinical Advisory to ensure that the tools we developed would meet a gold standard that would have the highest level of confidence. All ratings can be deemed “subjective” which is why we worked diligently with some of the best minds in health IT to ensure that AmericanEHR’s data would stand the test of time. It goes without saying that it would be extremely ambitious, expensive and time consuming to try to replicate the best efforts of AmericanEHR, our advisories, and our 18 medical society partners.
AmericanEHR frequently reviews our core EHR satisfaction survey questions to ensure that all questions remain timely and relevant. Most recently, we collaborated with ACP, AMA, AAFP and several advisors (including Dr. Michael Furukawa from ONC and Dr. Michael Barr from NCQA) on the most current iteration of our survey. The data we are collecting has been vetted thoroughly.
This brings me back to our update on the CTC Task Force and the ONC report. In April of 2016, ONC released their report to Congress titled: “Report on the Feasibility of Mechanisms to Assist Providers in Comparing and Selecting Certified EHR Technology Products.” In the report, ONC shared some concerns about the “lack of specific comparative information on certified health IT products such as costs, usability, and quality reporting capabilities and functionality, as well as on the ability of these products to integrate with other health IT.”
One of the reasons that much of this data isn’t available is because it doesn’t exist (at least not in a usable or accessible format). While we have already done considerable research around EHR usability, and have integrated third party data sources like Meaningful Use Attestations into our rating platform, reliable sources for data on EHR pricing and interoperability are much more elusive. There are many barriers at play here, and this is truly a systemic issue.
Here’s the exciting news, ONC’s report opens the door for the government to collaborate with existing tools such as AmericanEHR:
Mechanism 4: Collaborate with Stakeholders and Comparison Tool Developers
The current comparison tool marketplace addresses the needs of providers across the care continuum but gaps remain for providers and hospitals, particularly those who may be under-resourced. A first step in collaboration with tool developers should be guidance from ONC on what data are publicly available from the new CHPL that could enhance existing comparison tools, and how those data can be accessed.
HHS gains insights and better understanding of specific certified health IT needs from the diverse health care community through interactions with grantees, other technical assistance efforts, and stakeholder partnerships. These needs can be compiled and shared as educational “best practices” with the comparison tool marketplace so that the private sector may take steps to better address the needs of all comparison tool users, including those smaller and under-resourced provider groups. If those suggestions are not adopted or if private sector comparison tools remain challenging to use by vulnerable provider groups, additional steps could be explored that would ensure that vulnerable providers have access to the comparative information they need. A strategy recommended by the CTC Task Force was that the federal government contract with one or more tool developers to ensure that the necessary support is available to those providers. This strategy could necessitate federal staff time, contractor time and materials development, and pilot testing of tools, among other resources.
We’ve long strived for an opportunity to collaborate with the Office of the National Coordinator and AmericanEHR’s relationship with ONC stems all the way back to our first webinar with Dr. David Blumenthal who was the National Coordinator for Health IT at the time. Our founding partners at ACP have been diligent in keeping a dialogue open between ONC and AmericanEHR, as we all recognize the tremendous value that they bring to the table.
This report outlines numerous other ways in which ONC can provide support, including: providing enriched data; generating market awareness about HIT comparison platforms, providing staff resources; contracting time; materials development; pilot testing; etc. These are all things that would be great to see put into action.
We’ve accomplished a lot with AmericanEHR to date. We’ve amassed 26,000+ members from all 52 states and jurisdictions that collectively represent 70 medical specialties, and we have rating and/or attestation data on over 750 certified EHR products. We are hopeful that the recommendations being forwarded to Congress will provide an opportunity to rally the medical community to embrace health IT ratings and comparison as a vital component of their ongoing decision making processes.
Providing user feedback may seem like one more encumbrance on a busy clinician, but peer reviews are the best path for product recommendations on systems critical to practicing medicine. Other industries such as automobiles and electronics are strongly driven by consumer rating data—it’s time for health IT to recognize that ratings aren’t just nice to have—they are a necessity.