Health IT Now Calls for Reforms to Achieve Interoperability in MACRA Comment Letter

WASHINGTON, DC (August 21, 2017): Health IT Now – a broad-based coalition of patient groups, provider organizations, employers, and payers supporting health information technology to improve patient outcomes – submitted comments today to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule entitled: Medicare Program; CY 2018 Updates to the Quality Payment Program. 

In its correspondence, Health IT Now notes that the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) calls for widespread interoperability by December 31, 2018, but warns that “as that date quickly approaches, it is becoming more apparent that this is yet another deadline that will not be reached.” 

Health IT Now wrote that “Reaching interoperability is crucial for the success of the Quality Payment Program (QPP)” and outlined proposed reforms to achieve this goal, including: 

  • Advancing Care Information: HITN acknowledges CMS’ and the National Coordinator for Health Information Technology’s (ONC) decision to delay requirements that providers report using 2015 certified electronic health record (EHR) technology, and calls on the agencies to use this delay to revisit certification requirements; ensuring that every requirement is critical to providers’ success and reduces provider and vendor burdens under the QPP.
  • Virtual Groups: HITN expresses its support for CMS’ decision to move forward with implementation of virtual groups while noting that the December timeline for providers to elect into a virtual group is very short. HITN writes “We expect that participation will be very low in the first year due to this. Therefore, we encourage CMS to continue building virtual groups throughout 2018 even if participation is low at first.” 

    HITN also expresses concern that virtual groups will not have the capacity for data aggregation for the purposes of reporting to CMS in 2018 and urges a number of regulatory changes in order to allow third party data aggregation moving forward. This includes allowing third-party aggregators to access CMS claims data for beneficiaries attributed to the virtual group, ensuring that aggregators must be explicitly and uniformly required to comply with all applicable HIPAA requirements, and providing waivers to Stark, Anti-Kickback Statute (AKS) and anti-trust laws that work against providers who seek to share savings and maintain a coordinated referral network. 

  • Performance Feedback: HITN writes in support of CMS’ effort to utilize health IT to provide performance feedback while stating that in order for such feedback to be most beneficial, “information blocking must be ended once and for all.” HITN encourage CMS to continue to work with HHS to help address information blocking given that it impedes on the ability of providers to fully utilize health IT to succeed under the QPP.
  • Qualified Clinical Data Registries: HITN laments the lack of an eligible measure applicability (EMA) process for qualified clinical data registries (QCDRs) or EHR reporters and warns that this disparity may unfairly disadvantage providers under the MIPS program. HITN writes that QCDRs can “advance improvements in quality and patient outcomes by providing actionable feedback to participating providers related to their performance on key quality metrics in real-time” and encourages CMS to award 50% of the Quality Category score to active engagement in a QCDR. 


About Health IT Now: Health IT Now (HITN) is a broad-based coalition of patient groups, provider organizations, employers, and payers that support incentives to deploy health information technology to improve care, patient outcomes, and to lower costs. Learn more at