The US Department of Health and Human Services (HHS) is seeking public input in an effort to accelerate the growth in electronic health information exchange between healthcare entities to advance health information exchange and data interoperability beyond what is currently being done through current government programs such as the Medicare and Medicaid EHR Incentive Program. HHS is requesting comments on leveraging existing and potential policies and programs.
B. Proposed Strategies:

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* 1. How would you rate the following in terms of barriers to adoption of health information technology (HIT) in the Medicaid Home and Community-Based Services (HCBS) programs? Please rank the following barriers in terms of their impact
(5-extreme barrier, 4-significant barrier, 3-somewhat of a barrier, 2-minor barrier, 1-no barrier)

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* 2. What strategies do you recommend be employed to address these barriers?

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* 3. Should HHS require new clinical standards:
- in the form of “conditions of participation”
or
- requirements to ensure timely, electronic exchange of health information in order to support patient admissions, discharge, and transfers as well as care planning
in order to ensure care continuity as patients receive care across inpatient, post-acute and long-term care providers?

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* 4. Please rate the following strategies for their ability to assist in accelerating the adoption of HIT in long-term care facilities.
(5-extremely helpful, 4-very helpful, 3-somewhat helpful, 2-a little helpful, not helpful at all)

  not helpful at all a little helpful somewhat helpful very helpful extremely helpful
Increased grants on the part of CMS and ONC
Increased technical assistance
Investments in the technical infrastructure (i.e., broadband Internet), especially in rural and under served areas
Development of additional national standards to provide consistency across clinical data exchange entities.
ONC/CMS examples of ways to accelerate HIE across providers

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* 5. How would you rate the following list of proposed ONC/CMS recommendations to accelerate HIE use across healthcare settings?
(5-extremely helpful, 4-very helpful, 3-somewhat helpful, 2-a little helpful, not helpful at all)

  not helpful at all a little helpful somewhat helpful very helpful extremely helpful
HHS collaboration in the development of new e-specified measures of care coordination that encourage electronic sharing of summary records following transitions in care.
HHS to require Medicare Accountable Care Organizations (ACOs) to exchange health information as a part of coordination of care across aligned providers or patient engagement strategies. (Currently, meaningful use of EHRs is treated as a measure of quality and used to determine ACO eligibility for the shared savings and/or shared losses.)
Encourage the use of HIE in support of care coordination such as the Bundled Payments for Care Improvement Initiative, Comprehensive Primary Care Initiative, the Pioneer ACO model and the State Innovation Model Initiative.
Under the Capitated Financial Alignment model, HHS will contract with states and health plans, with the health plans receiving a prospective, blended payment to provide comprehensive, coordinated care. HHS could address requirements, expectations, and/or the role of HIE in these new arrangements.

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* 6. Please rate the following programs for their impact on accelerating electronic health information exchange.
(5-Extreme impact, 4-significat impact, 3-somewhat of an impact, 2-minor impact, 1-no impact)

  No impact Minor impact Somewhat of an impact Significat impact Extreme impact
Hospital readmission payment adjustments
Value-based purchasing
Bundled Payments
ACOs
Medicare Advantage
Medicare and Medicaid EHR Incentive Programs (Meaningful Use)
Media/Health Homes

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* 7. Do current HHS payment policies encourage or impede electronic information exchange across healthcare provider organizations?

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* 8. Please describe specific recommendations that you may have in which providers and vendors could be encouraged to send, receive, and integrate health information from other treating providers outside of their practice or system.

C. Low Rates of Consumer and Patient Engagement.

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* 9. Do you agree that increasing the ability of the patient/beneficiary to access their health records electronically should be a key HHS strategy?

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* 10. If applicable, approximately what percentage of your organization’s patients/beneficiaries currently can access their medical record electronically?

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* 11. Are you in favor of pursuing the use of “Blue Button” (ability of a patient/beneficiary to down load their medical record by clicking one button, with appropriate security) as an HHS strategy at this time?

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* 12. How important do you believe it is for patients/beneficiaries to have the ability to download a copy of the health record from their healthcare entity

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