Navigating Cancer’s Official Comments on the Merit-based Incentive Payment System (MIPS)

To:        Centers for Medicare & Medicaid Services
Date:    November 17^th, 2015
Re:     Comments on the Centers for Medicare Medicaid Services (CMS) Request for Information Regarding Implementation of the Merit-based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models


Navigating Cancer is a HITECH-certified, modular EHR vendor that provides oncology patient portals and care management solutions to over a million cancer and hematology patients and over a thousand healthcare professionals. It is from this experience, and our unique focus on helping patients and healthcare providers fight cancer better, that we offer the following recommendation:

We urge CMS to establish explicit interoperability requirements for all IT products that are eligible for use as part of the Merit-based Incentive Payment System (MIPS) or relevant physician focused payment models (PFPMs).

The Report on Health Information Blocking, submitted to Congress in April of this year, describes how the business models of some entities have incentivized them to exercise control over electronic health information in ways that unreasonably limit its availability and use.

If we expect healthcare providers to meet value-based payment requirements and develop the nationwide benchmarks that will be fundamental to addressing population health, it is critical that we address this issue now, and align payment incentives towards advancing and sustaining a health IT ecosystem with durable interoperability.

In the recently released 10-year Interoperability Roadmap, the Office of the National Coordinator of Health Information IT (ONC) outlines how health IT interoperability will lead to better care and better health by way of explicit standards, and by motivating the use of those standards through appropriate incentives. This should not take 10 years.

The way to move forward now is to enforce explicit requirements for application program interfaces (APIs) in the context of any payment model that is designed to improve the quality of healthcare. With the MACRA, congress is taking a first step by stating that doctors and hospitals that receive EHR bonus payments cannot deliberately block the sharing of information. But these requirements need to center on EHR vendors, not providers.

While the definition of the API should be left to the EHR vendor, we recommend that the following broad requirements be part of the IT certification:

1. The delivery mechanism of the API should be a RESTful web service.
2. The API must implement clear error handling.
3. The API must come with a clear outline of the interface itself – inputs, output and errors.
4. The API must come with sample code and applications that demonstrate a successful use of the API calls.
5. The API should come with a support channel – community forum (at minimum) and/or ideally dedicated support staff.

At Navigating Cancer, we have seen information blocking firsthand, as some of our practices were made to invest considerable time and energy into getting their current EHR vendors to allow interoperability with ours. At times, EHR companies have flat out refused to interface with our application, even with signed contracts in place from healthcare professionals. Just as this restricts patients who want to access their electronic health information to the use of suboptimal products today, it impedes practices that want to meet the requirements of new payment models sooner instead of later.

We agree with the American Medical Association and the 111 medical societies that joined together in a letter to Congress on November 2^nd, 2015, asking that the Meaningful Use program be recast with “…a laser-like focus on promoting interoperability and allowing innovation to flourish.”

Implementation of the MIPS poses a major opportunity to transform healthcare delivery to value. Yet to achieve this transformation, physician practices and hospitals need technologies that enable the nationwide sharing of health information, analytics and benchmarks. Explicit interoperability and API requirements for all certifiable IT products will revolutionize product development in healthcare technology, spur innovation and competition among software developers and dramatically improve the patient experience.

Thank you for this opportunity to submit our comments.

Sincerely,
Gena Cook
Founder & CEO
Navigating Cancer, Inc.
1200 Post Alley, Seattle, WA
Comment Tracking #: 1jz-8mb5-l7sq