{"id":18790,"date":"2016-06-03T18:25:28","date_gmt":"2016-06-03T22:25:28","guid":{"rendered":"http:\/\/pmedicine.org\/epatients\/?p=18790"},"modified":"2016-06-04T04:10:44","modified_gmt":"2016-06-04T08:10:44","slug":"just-say-no-to-medicares-macra-tokenism","status":"publish","type":"post","link":"https:\/\/participatorymedicine.org\/epatients\/2016\/06\/just-say-no-to-medicares-macra-tokenism.html","title":{"rendered":"Just Say “No” to Medicare’s MACRA Tokenism"},"content":{"rendered":"

On social media and at meetings\u00a0like Health Datapalooza,<\/a>\u00a0our favorite federal bureaucrats\u00a0assure us of their commitment to open data and patient empowerment. But those are just soothing\u00a0words; federal regulations are law.<\/p>\n

On April 30, I posted on e-patients.net an article entitled, \u201cYou Won\u2019t Believe What Medicare Just Did on Patient Engagement!\u201d<\/a>\u00a0In it, I\u00a0showed how\u00a0the long-awaited draft regulations for the implementation of the Medicare and CHIP Reconciliation Act (MACRA) were extraordinarily\u00a0weak in the\u00a0requirements related to using electronic health records for\u00a0patient engagement. I concluded the post by\u00a0pointing out that the comment period on the draft\u00a0rule \u00ad \u2013 that is, the formal opportunity to influence the final rule \u2013 ends June 27. Just to be reinforce the importance of commenting, the physician reimbursement rules Medicare is setting forth in MACRA will play a major role\u00a0in the U.S. health care system\u2019s transformation from fee-for-service to value-based payment.<\/p>\n

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You can read the entire text of the proposed rule here<\/a>, but I\u2019d strongly suggest that you use \u201cSearch\u201d to look only at\u00a0patient engagement-type activities. (My April 30 blog post talks about some of the most important.) The next step is to\u00a0go to www.regulations.gov<\/a> to comment. (Again, use “Search” to can find the\u00a0MACRA draft rule; I put\u00a0\u201cMIPS\u201d into the search box.) Commenting is as simple as placing text into a box and then adding your contact\u00a0information.<\/p>\n

I both\u00a0criticized the draft and suggested replacement language. If you agree with it (see below), you may want to recommend that language, as well. Or you may very well have much better suggestions. In any event, I encourage the Society of Participatory Medicine as an organization and all SPM members \u00a0to make your voices heard.<\/p>\n

Other groups have other agendas. It’s up to us to tell Medicare\u00a0we won’t accept tokenism on MACRA.<\/p>\n

Here is the text of my comment:<\/p>\n

To Whom It May Concern:<\/p>\n

This email is to formally comment on the Centers for Medicare & Medicaid Services (CMS) proposed rule 81 FR 2816, Agency Docket No. CMS-5517-P, related to the Medicare Access and CHIP Reauthorization Act (MACRA).<\/p>\n

As someone who has worked extensively in the areas of informatics and of patient-centered care, I find the proposed standards related to use of certified electronic health records (EHRs) in the section entitled “Coordination of Care Through Patient Engagement” disappointingly weak and unlikely to achieve its goal. As an October, 2015 white paper co-authored by me and Dr. Robert Berenson of the Urban Institute noted, MACRA contains legislative language specifically assigning\u00a0priority to outcomes measures that include patient-reported outcome and functional status measures and patient experience measures. (On the Urban Institute website, see: “The Road to Making Patient-Centered Care Real: Policy Vehicles and Potholes.”) Moreover, patient-centeredness is an official part of the National Quality Strategy to which CMS is supposed to adhere.<\/p>\n

Yet under “patient engagement,” the proposed rule requires the following:<\/p>\n