ONC RFI Assessing Interoperability for MACRA - part 1 - MACRA text

On April 8, 2016, The Office of the National Coordinator for Health Information Technology (ONC) issued a Request for Information (RFI) regarding assessing interoperability for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Comments are due by 11:59pm ET on June 3, 2016.

The MACRA legislation lays out a timeline for defining, assessing and acting on barriers to widespread interoperability.
July 1, 2016: Establish metrics for widespread interoperability
December 31, 2018: Determine if widespread interoperability has been achieved

December 31, 2019: Identify barriers to widespread interoperability and recommend actions to address 

Here's the relevant section of MACRA.  

Medicare Access and CHIP Reauthorization Act of 2015

https://www.congress.gov/114/plaws/publ10/PLAW-114publ10.pdf

SEC. 106. REDUCING ADMINISTRATIVE BURDEN AND OTHER PROVISIONS.

(b) PROMOTING  INTEROPERABILITY OF  ELECTRONIC HEALTH RECORD  SYSTEMS

(1) RECOMMENDATIONS FOR ACHIEVING WIDESPREAD EHR INTEROPERABILITY

1. OBJECTIVE .—As a consequence of a significant Federal investment in the implementation of health information technology through the Medicare and Medicaid EHR incentive programs, Congress declares it a national objective to achieve widespread exchange of health information through interoperable certified EHR technology nationwide by December 31, 2018.
2. DEFINITIONS .—In this paragraph:

(i) WIDESPREAD INTEROPERABILITY .—The term ‘‘widespread interoperability’’ means interoperability between certified EHR technology systems employed by meaningful EHR users under the Medicare and Medicaid EHR incentive programs and other clinicians and health care providers on a nationwide basis.

(ii) INTEROPERABILITY .—The term ‘‘interoperability’’ means the ability of two or more health information systems or components to exchange clinical and other information and to use the information that has been exchanged using common standards as to provide access to longitudinal information for health care providers in order to facilitate coordinated care and improved patient outcomes.

3. ESTABLISHMENT OF METRICS .—Not later than July 1, 2016, and in consultation with stakeholders, the Secretary shall establish metrics to be used to determine if and to the extent that the objective described in subparagraph (A) has been achieved.
4. RECOMMENDATIONS IF OBJECTIVE NOT ACHIEVED .— If the Secretary of Health and Human Services determines that the objective described in subparagraph (A) has not been achieved by December 31, 2018, then the Secretary shall submit to Congress a report, by not later than December 31, 2019, that identifies barriers to such objective and recommends actions that the Federal Government can take to achieve such objective. Such recommended actions may include recommendations—

(i) to adjust payments for not being meaningful EHR users under the Medicare EHR incentive programs; and

(ii) for criteria for decertifying certified EHR technology products.

Health = Being + Doing + Environment

A framework for exploring health

Health is a function of Being, Doing and Environment. I want to encompass the many ways we might define health, what we do about it and the activities that address health. The larger environment in which we live is also important. These interact and further shape each other.

Health

Health is a way of being and an attitude as well as a result of the actions we take or don't take and the environment in which we live.

To say "I am healthy" is itself complex. Does it mean I feel well? That I have no limitations on my activity? That I am free of disease or disability? Or that I have accommodated and compensated for my various diseases and disabilities?

Health is both broad and specific with a wide range of determinants of health. Here are a couple of examples work on this: Healthy People 2020 and Schroeder: We Can Do Better, Improving the Health of the American People, NEJM 2007.

Being

Who and what we are at this moment and the personal history that got us here.

• Personal values and goals - what health is to us, what's important to us, what we want to experience, what we want to leave as our legacy.
• Spirit - the innermost aspects of our being
• Mind - our state of mind, attitude, outlook, intellectual capabilities, interests, desires, mental health.
• Body - our physical body, it's current condition and history, our genetic inheritance, our various diseases and disabilities.

Doing

What we're doing now, our actions with ourselves, with others and in the larger world.

• Plans - in the boundary between Being and Doing, our plans are how we go from our intentions to action, although not everything we do is planned.
• Actions - what we're actually doing, with or without planning. The "behaviors" that are high on the list of health determinants and those that have no known effect on our health. 

Included in here are the things we do to manage our health, from immunizations to exercise, from medication that changes our biochemistry to meditation that changes our mind, from surgery to assistive devices.

Our actions affect others as well as ourselves. They also shape the larger environment, our own and others.

Environment

We live in an environment. The boundary between self and other is very fluid. We're completely interdependent with our environment. It's the context in which our actions take place. We can't take one breath without it. When we take advantage of it, the environment can make it easy to do the right thing, keep us safe and healthy, with no extra effort. On the flip side, the environment can be a real killer, from toxins that poison us to cultural norms that encourage risky behavior.

• Physical Environment - from our housing and food, from our zip code to climate zone - the place where we live, work and play - and the physical forces that surround us. 
• Social Environment - our family, friends and neighbors. We can't life without other people, from our conception and birth through the whole of our life. The social forces that we interact with our powerful in shaping our behavior and our health. 
• Access to Resources and Services - access is a combination of what's available and at what cost... including healthcare, education, employment.
• Public Policy and Public Health - what we collectively decide to do as a society
• Extrasomatic Intelligence - a fancy way to say that using our environment well can make us vastly smarter, from the written word to the most advanced analytics.

There's a lot being written about geography and health. Here's a start (Health Affairs Blog, August 6, 2015).

A work in progress

This is all a developing set of thoughts. I've had feedback about the diagram at the beginning of this post. More is welcome. I've received suggestions about the content. I'm not sure that Environment is the right label for the third section. Perhaps Connecting or Interacting or some other word that speaks to the interplay with the world around us.

Feel free to comment here or on Twitter or LinkedIn. Thanks.

Introduction to Agile Alchemy - a trial run

My friend, fellow meditator and Agile software wizard, Stephen Starkey, and I are piloting a training program that combines meditation and Agile to help people be more present, better connected to the people and task at hand, and as a result, brilliant and productive.

This first run will be a series of five Thursday evenings, April 14 through May 12, 2016. We'll meet in the West Loop at the Chicago Shambhala Center.

This is a “beta” program. We are teaching something fresh, extending and combining elements we know well in a new way. We are looking for a small group of pioneers to join us in this exploration.

Introduction to Agile Alchemy

Agile Alchemy is for anyone who must collaborate with others to be successful. We take the world, full of chaos and change, and build on the natural strength and flexibility of mind, to fully engage with the present situation. Then we leverage that brilliance. We use the wisdom of the ages and modern times to work with complex situations with precision and grace.

Agile Alchemy teaches:

• Meditation and contemplation practice as a basis for deeper awareness and opening to possibilities
• Tools for personal and organizational growth in areas such as:
• Process design and stewardship,
• Conflict resolution,
• Leadership, and
• Change management
• Simple and powerful techniques for creating and maintaining clarity, momentum, and adaptability.

This training program uses multiple perspectives:

• The brain and individuals’ ability to think creatively,
• Teams’ ability to deliver quality work, and
• Organizations’ ability to set and achieve their goals.

Program registration at Chicago Shambhala.