Dear Dr. DeSalvo and Acting Administrator Slavitt:
The undersigned medical societies are writing in response to your request for information (RFI) assessing
interoperability for the Medicare Access and CHIP Reauthorization Act (MACRA), which directs the
Secretary of the U.S. Department of Health and Human Services (HHS) to establish metrics to determine
if and to what extent interoperability has been achieved.
The physician community appreciates HHS’ evaluation efforts and agrees that wide-spread
interoperability among health information technologies (health IT) is critical to improving health care
delivery. Despite claims by many health IT vendors that their products are interoperable, the vast
majority only exchange static documents in a manner that satisfies minimum Meaningful Use (MU)
requirements. Many in health care view this level of exchange as little more than digital faxing. We are
therefore concerned that both the Centers for Medicare & Medicaid Services (CMS) and the Office
of the National Coordinator (ONC) are misinterpreting the current use of health IT as a
benchmark for successful interoperability.
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