Premier Responds to Administration's RFI on Improving Technology to Empower Medicare Beneficiaries

Premier submitted comments on a request for information issued by the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) and CMS to solicit input on how best to advance a seamless, secure and patient-centered digital health infrastructure. In its comments, Premier provided detailed recommendations on how CMS and ASTP/ONC can:

• Harmonize interoperability regulations to promote greater market competition;
• Update meaningful use criteria, certification standards for health IT and the overall federally-driven interoperability incentive structure to ensure that data usability for quality and process improvement are adequately incentivized;
• Clearly define information blocking and implement and enforce more stringent information blocking penalties on health data ecosystem participants beyond providers and provider organizations;
• Extend interoperable electronic health record incentives to post-acute and continuum of care providers;
• Develop a holistic framework of both financial and non-financial incentives to promote value-based care participation, which in turn results in greater adoption of tech-enabled solutions;
• Mandate a patient-directed data sharing mechanism such as Blue Button 2.0 in certified electronic health record technology (CEHRT) criteria;
• Require more standardized data sharing by CMS-regulated health plans to providers and patients; and
• Improve Risk Adjustment Data Validation (RADV) audit processes by piloting a program that relies on CMS-approved, real-time self-audit technology rather than perpetuating a pay-and-chase model.