Health IT Now (HITN) is pleased to submit our comments on the Request for Information Regarding Assessing Interoperability for MACRA. HITN is a diverse coalition of health care providers, patient advocates, consumers, employers, and payers who support the adoption and use of health IT to improve health outcomes and lower costs.
HITN believes the free flow of electronic health information is essential to improving health outcomes and lowering costs. We strongly support the widespread interoperability goal set in the Medicare and CHIP Reauthorization Act of 2015 (MACRA). However, we believe that in order for any goal or measure to be successful, ONC must coordinate not only with other departments within the Department of Health and Human Services (HHS), such as the Centers for Medicare and Medicaid Services (CMS), but also with other agencies such as the Federal Trade Commission (FTC). Many of the barriers to widespread interoperability are not the result of technology, and in order to fully achieve the goal of widespread interoperability, HHS will have to coordinate outside of ONC’s narrow jurisdiction over the voluntary Health IT Certification Program.
Healthcare organizations rely on information technology systems from a variety of vendors to support patient care, medical operations, administrative operations, and billing. Very few vendors have integrated enterprise-wide systems, resulting in limited data sharing within and across healthcare organizations. Vendors and healthcare organizations must be able and willing to share information. In order to deliver care in a mobile society and to those with chronic illnesses, information must flow freely between vendor products and across healthcare organizations.