Data is the lifeblood of the value-based payment environment. Every time a doctor takes care of a patient, we have an opportunity to use information in ways that help patients get better care. The goal is to use the information from each patient encounter to make the next encounter better — across the entire health care system. But it is easier said than done. As we prepare to transition from this administration, we’d like to take stock of what our nation has accomplished and to lay out a potential roadmap for the next administration.
Making data easy to use begins by putting it into secure, private, digital form. During the past seven years, we’ve made remarkable progress towards this goal: in 2015, over 77 percent of office-based physicians reported using a certified electronic health record (EHR) to inform clinical care, while the percentage of office-based physicians with any EHR has doubled since 2008. As we hoped, digital tools have helped us reduce medical errors by, for example, e-prescribing and having fewer follow-up items fall between the cracks. But we still have a lot of work to do.
While the tools are improving, some clinicians remain frustrated by the limited usability of their technology and data, from their inability to easily enter and access key information when and where they need it at the point of care to challenges in accessing timely feedback on the quality of care in their practice. We need 21st century information technology, enabling ready and secure data access, to support a modern, value-based health care system.
One obstacle is the efforts of some vendors to put up barriers to sharing data. Fortunately, the bipartisan 21st Century Cures Act, which was enacted in December 2016, takes a significant step toward overcoming that obstacle. The Act advances interoperability through several provisions including the prohibition of information blocking and authorization of penalties of up to $1 million per violation. The law also gives the Office of the National Coordinator for Health Information Technology (ONC) new authority to address usability and interoperability through additional conditions of certification for health information technology (health IT) developers related to: access, use, and exchange of electronic information; usability, security, and business practices; real-world testing; and publishing application programming interfaces (APIs).
We have also launched new tools to address these challenges under the recently established Quality Payment Program (QPP). This program created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) uses a number of tools to reward Medicare clinicians for quality of care over quantity of services provided. These tools include a web application and public API designed to help clinicians, registries, and others in the CMS vendor community more easily share and receive feedback about performance. By consolidating previous programs such as the Physician Quality Reporting System (PQRS) and the EHR Incentive Programs (Meaningful Use); creating more ways for clinicians to participate; significantly reducing requirements by reducing the number of measures; and providing additional flexibility in selecting meaningful measures, QPP also reduces administrative burden.
Yet the Department of Health and Human Services (HHS) recognizes that clinicians work with many payers, not just Medicare alone; in fact, the average physician practice now contracts with 12 different insurers. And that can lead to an additional set of challenges: access to data across disparate payers and settings is variable; the lack of comparability from multiple sources makes it hard to obtain actionable insights to inform care; and clinicians face increased administrative complexity if they participate in alternative payment model programs tied to different payers, each with unique requirements around quality measures, formats, and submission methods.
A Vision For The Future
We must overcome these challenges to enable clinicians to continuously improve quality and to ensure the nation gets more value from each health care dollar. That’s why the Department of Health and Human Services (HHS) envisions a future where clinicians in a multi-payer environment obtain actionable, reliable, and comprehensive feedback data regardless of who pays for their patients’ care. HHS also envisions streamlined quality reporting, where clinicians collect data as part of the normal course and share it at the push of a button with any authorized party. Finally, HHS will continue to work towards minimizing the financial and administrative burden of collecting and reporting information on clinicians and practices, especially small practices and those in rural and underserved areas.
The federal government should only play a modest role in the ecosystem necessary to support patients and physicians. We believe that ecosystem requires the following six elements to ensure a data-rich, patient-centered, and value-based health care system:
Seamless interaction between point of care solutions and other entities, including through the use of standard APIs
Health IT developers can play a key role in this vision by making it easier for clinicians to share data between their EHRs and other applications or services, such as registries, empowering clinicians to assemble the right tools and services for their practice.
Growth of third-party entities that can meet provider data access and reporting needs
Clinicians will benefit from a robust marketplace of trusted entities that can perform core functions like facilitating quality reporting to all payers, combining data from disparate sources of care in a medical neighborhood and presenting it in a usable way, and helping clinicians to understand data on their patients — at a reasonable cost. For instance, vendor partners working with select regions participating in the Comprehensive Primary Care initiative have made important progress in recent years by providing aggregate feedback reports including data from both Medicare and commercial payers.
Use of low-cost shared services necessary for aggregating and linking data
Value-based payment relies on a variety of core services, such as accurate information on the identity of patients and providers to carry out key tasks like attributing patients to providers. Stakeholders could realize significant efficiencies by coming together around shared governance and financing for such services. Many of the participants in the Center for Medicare and Medicaid Innovation (CMMI) State Innovations Model have taken just such an approach.
Greater data transparency and data consolidation
Efforts like state All-Payer Claims Databases and Medicare Qualified Entities that bring together data from multiple payers in one place can provide stakeholders with a single place to go for data, while reducing the burden on the payers who want to make their data available.
Standardization of key patient data needed for quality measurement
ONC and CMS can assist in fostering ongoing standardization of data for measures as well as development of related tools, such as libraries of data elements that allow new electronic measures to be easily captured, calculated, and reported for use by clinicians and consumers.
Alignment around how quality is measured and reported across payers
By coming together around common quality measures and reporting mechanisms payers can ensure clinicians have access to more useful, aggregated performance feedback, while increasing the comparability and auditability of measurement results. Efforts such as the Health Care Payment Learning and Action Network, and the Core Quality Measurement Collaborative (which identified seven core sets of quality measures that CMS and commercial payers have committed to using) have begun to make such alignment possible.
HHS has heard a great deal about the challenges clinicians are facing as they look towards value-based care. As HHS leaders continue this crucial dialogue, we look forward to hearing from you about what’s working today and what’s not, as well as your ideas about what the Federal Government and the private sector can do to make progress in this area.
It’s been a great honor working with the health care community and serving the American public. Working together across the health care landscape, the nation can move towards a truly 21st century data infrastructure that frees clinicians to confidently transition to value-based payment and realize better care, smarter spending, and healthier people.