Measuring Interoperability: Listening and Learning

In April we asked for your input and comments on ways for us to measure how well our nation’s health care system is doing in achieving “widespread interoperability,” as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Separate from the provisions that the Department of Health and Human Services (HHS) has proposed to implement through the Quality Payment Program for payment of office-based Medicare physicians, MACRA specifically calls on HHS to establish metrics for the exchange and use of clinical information to facilitate coordinated care and improve patient outcomes between participants in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs and others nationwide.

We received nearly 100 comments from organizations and businesses all across the health and health information technology (health IT) landscape in response to our Request for Information and found that many of the comments related to four topics:

  • Burden: Do not create significant additional reporting burdens for clinicians and other healthcare providers.
  • Scope: Broaden the scope of measurement to include individuals and providers that are not eligible for the Medicare and Medicaid EHR Incentive Programs.
  • Outcomes: Identify measures that go beyond exchange of health information. Although measuring the flow of information is important, it is also critical to examine the usage and usefulness of the information that is exchanged as well as the impact of exchange on health outcomes.
  • Complexity: Recognize the complexity of measuring interoperability. Multiple data sources and more discussions are needed to measure interoperability fully.

Based on internal analysis, external feedback, and MACRA’s specific definitions of “widespread interoperability” and the relevant population to be measured, we have identified two measures in particular that satisfy both the feedback we received and MACRA’s specific parameters:

  • Measure #1: Proportion of health care providers who are electronically engaging in the following core domains of interoperable exchange of health information: sending; receiving; finding (querying); and integrating information received from outside sources.
  • Measure #2: Proportion of health care providers who report using the information they electronically receive from outside providers and sources for clinical decision-making.

Importantly, these measures do not add to providers’ reporting burden as part of their participation in federal health care programs like Medicare or Medicaid, but rather come from existing national surveys of hospitals and office-based physicians.  These surveys are the American Hospital Association’s AHA Information Technology Supplement Survey and the Center for Disease Control and Prevention’s (CDC) National Center for Health Statistics’ annual National Electronic Health Record Survey of office-based physicians. Both surveys have relatively high response rates and convey health care providers’ perspectives on exchange and interoperability.  As these surveys touch providers across the country in a variety of practices, they are not limited to the Medicare and Medicaid EHR Incentive Programs.

Although the MACRA requirement for measuring interoperability largely focuses on “meaningful users,” we are committed to advancing interoperability of health information more broadly. We will be expanding our measurement efforts to include populations across the care continuum in the near-term, as well as an increased focus on outcomes in the longer-term.  This measurement strategy is described in the Shared Nationwide Interoperability Roadmap – a collaboration with the private sector, states, and federal partners to identify near-term actions to advance an interoperable health system – and the Federal Health IT Strategic Plan [PDF- 1.8MB] – a joint effort by more than 35 federal offices and agencies that use or influence the use of health information technology on person-centered care, advancement of science and overall health. We look forward to engaging with stakeholders from across the health IT landscape in further depth on these efforts to provide insight into the nation’s progress in ensuring that health data will flow seamlessly and securely where and when it is needed.

Ultimately, these metrics will help inform the wide range of efforts underway to achieve a learning health system where information flows seamlessly and securely, including:

  • The pledges made earlier this year by many private sector market leaders to make electronic health information flow better by not blocking data, implementing and using federally recognized standards, and helping consumers easily and securely access, use and share their electronic health information;
  • Updated information from health IT developers about potential costs and implementation issues that is posted online for providers to use when purchasing health IT, and
  • Recent challenges we have issued to spur innovation of market-ready, user-friendly apps for consumers and providers and to make it easier for individuals to send their data where they wish.

Fulfilling Section 106(b)(1)(C) of the Medicare Access and CHIP Reauthorization Act of 2015 [PDF-260KB]


  1. Catherine Zuniga says:

    Thank you for your continued publications. I find them very helpful in understanding these programs. That said, I am still so very confused in the number of programs that I see, such as the CPC, ACO’s, BPS and a whole host of other programs that are asking for data submission from practices either P4P or penalties for not submitting. My job specifically is an EMR support tech, which has quickly become a P4P specialist. I spend less time fixing EMR issues and more time trying to figure out the latest program that has now been imposed on practices, and how the EMR is to crank out the report to fulfill the request for these programs.
    My question in all of this, is exactly what programs are essential for a practice to report, and what programs are the same. I understand PQRS – MU is being rolled up into MACRA/MIPS, I get that because I have been deeply involved in MU reporting and PQRS reporting with sites, but what about all of these others I hear about? Is there something out there that shows all of these programs and how they relate? A simple “What do I need to report”? I have viewed some of the CPC standards, and it does appear some of the NQF measures are reported, but then there is a whole host of other items that should be reported on that are not part of MU measures or PQRS measures. Where do these programs fit, and does a Practice have to participate to avoid penalties? Any info you could assist with would be gratefully accepted and appreciated!
    “Caz” Zuniga

  2. Paul H. Keckley, Ph.D says:

    Thanks for update and responsiveness to industry feedback. Assuming there is a mechanism to gauge provider survey responses to verifiable activity for each measure?

  3. Peter J. Liepmann MD FAAFP says:

    The Emperor has NO CLOTHES!!
    Interoperability is total fiction.
    Create a USG data exchange that all EMRs MUST read and write to and have done with it. Make it compatible w VISTA/CPRS, and administer it federally, maybe as part of the VA system. That’s the one part of the VA that works well.

    Otherwise we’ll be horsing around with this 100 years from now. Vendors DON’T want their data sharable. Unless they absolutely have to, they won’t do it.

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