The Partnership to Empower Physician-Led Care (PEPC) is pleased to submit our comments on the Request for Information Regarding Interoperability and Health Information Exchange. PEPC is a coalition of stakeholders supporting independent physicians and practices in the movement to value-based care.
General Comments
We believe that the physician-patient relationship is most transformative when there is patient choice and provider competition within local markets. Independent physicians and practices are a key part of any value-based care system, and health information exchange – especially exchange across organizational boundaries – helps spur competition while improving quality, encouraging coordination, and reducing costs. Timely access to critical health information is also fundamental to value-based care, and independent physicians and practices seeking to adopt these models must have access to important clinical information about their patients to succeed under new models.
Given this backdrop, we believe it is appropriate for CMS to use health and safety standards to encourage hospitals to electronically share information with community providers to support safe, effective transitions of care between hospitals and community providers; and to encourage hospitals to notify community providers when their patients present in the emergency room. Conditions that link participation in public programs to electronic, real-time information sharing should be phased in over time and flexible enough to allow providers sending and receiving information to use their preferred technological approach for doing so, including community networks where they exist. New requirements should not place additional cost or burden on community providers, but rather build on investments that have already been made in IT infrastructure and workflow improvements.
Read our comment letter.