Earlier this week the Society provided comments on proposed changes by the Centers for Medicare and Medicaid Services (CMS) regarding the interoperability of electronic health records (EHR). The proposed rule seeks to improve the interoperability of EHRs by requiring payers to make patient health information available through a standardized interface, promoting data exchange between payers, requiring providers to comply with new notification requirements, promoting better care coordination for dual-eligible beneficiaries and disclosing when providers inappropriately restrict the flow of information. The rule applies to beneficiaries of Medicare, Medicaid, Children’s Health Insurance Program, Medicare Advantage and those who receive coverage on the federal exchanges.
There is also a companion rule on information blocking that deals with more of the technical requirements not covered by the interoperability rule. The Society’s Innovations in Health Care Task Force reviewed the proposed rules in April and was instrumental in drafting the Society’s position.
EHRs and their documentation requirements have been highlighted by the Society as one of the major drivers of physician burnout and administrative burden. Throughout its comments the Society highlighted the need to reduce physician and patient burden, particularly for EHRs, highlighting that any new requirements should not be “passed down” to physicians for compliance. The Society also advocated that physicians not be publicly shamed for not disclosing their digital contact information as required by the rule. Further, the Society advocated for the security of sensitive patient information particularly as it changes hands between payers and data systems, while highlighting that under no circumstances should patients be denied care retroactively or discriminated against as they move between payers.
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