Executive Summary
For the best clinical and financial results, patients and their families need to be engaged in their care, to the extent that their conditions permit. Patients do better when they understand their illnesses and how their own actions can increase the chances of a favorable outcome.
For the best clinical and financial results, patients and their families need to be engaged in their care, to the extent that their conditions permit. Patients do better when they understand their illnesses and how their own actions can increase the chances of a favorable outcome. Patient self-efficacy means that patients hold themselves accountable for what they should do. Patient-provider communication is one way to augment patient engagement and patient self-efficacy. The relatively recent adoption of electronic health records has made it possible for patients to access their clinical data, to contribute data about their conditions to their providers, and to securely exchange messages with questions to and advice from their providers. Such changes in patient involvement will take time for broad adoption and we would like to see a continuation of the momentum that has been established by the HITECH Act.
The industry continues to need impetus for all the established interchange mechanisms including query by the IHE profiles and FHIR, downloads from patient portals and push by Direct Exchange. To that end we recommend the following:
- Retain the current 5% thresholds for the View, Download, and Transmit and Secure Electronic Messaging measures.
- Retain the Patient-Generated Health Data measure.
- Retain the Patient-Specific Education measure.
- Retain the Secure Messaging measure.
- Retain the View, Download, and Transmit measure.
- We support the inclusion of Supporting Electronic Referral Loops as a measure.
- CMS and ONC should endorse all 12 of the standard C-CDA document templates as an alternative to FHIR as the standard matures.
- CMS and ONC should endorse currently used health data exchange standards but eliminate optionality and insist on 24x7x365 online conformance testing.
- Modify current EHR certification standards to allow patients to enter their secure messaging address into their patient portals so they automatically receive their data.
- CMS and ONC should incrementally, predictably, and annually advance the standards for electronic health data exchange including the USCDI so that vendors and providers can adopt more effective information technology without significant burden.
- Patients need to be clearly, securely, and unambiguously identified using standards found in NIST Publication 800-63-3 to protect against malicious mis-representation.