Measuring interoperability as required by the Medicare Access and CHIP Reauthorization Act (MACRA) calls for a “patient-centric” and flexible strategy, wrote the American Medical Informatics Association (AMIA).

In a letter to the Office of the National Coordinator for Health IT (ONC) on how the agency can meet the MACRA requirement to develop interoperability standards by July 1 and achieve interoperability by 2018, AMIA recommended a different approach than what ONC has proposed. Rather than measuring whether organizations are meeting interoperability standards, AMIA asked for the agency to look at standards “retrospectively.”

“Rather than try to develop measures for the myriad of ways interoperability may be occurring, we recommend an approach that looks to understand where interoperability is needed, and then assess whether or not it is occurring,” wrote AMIA President and CEO Douglas B. Fridsma, MD, PhD, and AMIA board chairman Thomas H. Payne, MD.

The pair said this approach, relying on claims and statistical samples, would allow ONC to find out why expected data sharing didn’t occur in some situations “without creating burdens on providers and healthcare organizations.”

The letter warned against ONC’s emphasis on volume-based measures in its request for information, arguing those sources wouldn’t provide enough data.

Despite their recommendation, Fridsma and Payne said it wouldn’t be possible to integrate this retrospective strategy into interoperability standards in time for the July deadline set by Congress.

“In the near-term, we urge ONC to pursue an interoperability measurement strategy that focuses on the providers who share the greatest volume of patients, and therefore have the greatest need to engage in interoperable data sharing, and to focus on priority use cases where interoperability could be reasonably expected to be occurring, notably care coordination and patient engagement,” they wrote.

ONC asked for answers on several other matters surrounding the standard. Here are some of the AMIA’s notable responses:

• How should eligible professionals under the Merit-Based Incentive Payment System (MIPS) and eligible professionals who participate in the alternative payment models be addressed? AMIA recommended eligible clinicians participating in MIPS should be treated as “meaningful EHR users” for the purposes of measurement, as should other qualified professionals who report on measures similar to what is required by Meaningful Use.
• Should the focus of measurement be limited to use of certified EHR technology, and should measurement of exchange or use outside of certified EHR be considered? AMIA said to stick to certified EHR for the initial ONC measurement, while adding future measurement efforts should consider “remote patient monitoring and consumer health informatics tools.”
• Do survey-based measures adequately address the two components of interoperability (exchange and use)? AMIA said yes, provided the surveys use a broad set of data and offer specificity. In a separate answer, AMIA said national surveys shouldn’t be used, as they’re “not likely to provide adequate information on why electronic health information may not be widely exchanged.”
• If ONC seeks to limit the number of measures selected, which are the highest priority measures to include? The letter said measures should be focused on interoperability across providers, not within organizations, arguing exchange between providers is the “is the larger policy concern.”