Policy letter to Centers for Medicare & Medicaid Services on CMS’s Proposed Amendments to Quality Payment Program and Promoting Interoperability Performance Category

UCSF’s Center for Digital Health Innovation focuses on proposed changes to the Quality Payment Program’s Advancing Care Information and Promoting Interoperability performance categories because of their central role in building a national digital health ecosystem.  We applaud CMS’s decision not to delay required use of the 2015 Edition of certified EHR technology, which introduces new functionality and standards essential for interoperability and shared care planning.  However, we urge CMS not to drop core measures of meaningful uses such as patient access to view, download, transmit or use apps and APIs with their electronic health information to manage their health, nor secure messaging with doctors, patient-generated health data, and patient-specific education.  Genuine interoperability for patient-centered care and health depends upon such functions and basic use of them.  Congress directed the Secretary to make interoperability and patient access a national priority, not a nationwide repeal.

LettersBryan Mazzarello