Executive Summary
For the best clinical and financial results, patients and their families need to be engaged in
their care, to the extent that their conditions permit. Patients do better when they
understand their illnesses and how their own actions can increase the chances of a
favorable outcome. Patient self-efficacy means that patients hold themselves accountable
for what they should do. Patient-provider communication is one way to augment patient
engagement and patient self-efficacy. The relatively recent adoption of electronic health
records has made it possible for patients to access their clinical data, to contribute data
about their conditions to their providers, and to securely exchange messages with
questions to and advice from their providers. Such changes in patient involvement will take
time for broad adoption and we would like to see a continuation of the momentum that has
been established by the HITECH Act.
The industry continues to need impetus for all the established interchange mechanisms
including query by the IHE profiles and FHIR, downloads from patient portals and push by
Direct Exchange. To that end we recommend the following:
• Retain the current 5% thresholds for the View, Download, and Transmit and Secure
Electronic Messaging measures.
• Retain the Patient-Generated Health Data measure.
• Retain the Patient-Specific Education measure.
• Retain the Secure Messaging measure.
• Retain the View, Download, and Transmit measure.
• We support the inclusion of Supporting Electronic Referral Loops as a measure.
• CMS and ONC should endorse all 12 of the standard C-CDA document templates as
an alternative to FHIR as the standard matures.
• CMS and ONC should endorse currently used health data exchange standards but
eliminate optionality and insist on 24x7x365 online conformance testing.
• Modify current EHR certification standards to allow patients to enter their secure
messaging address into their patient portals so they automatically receive their
• CMS and ONC should incrementally, predictably, and annually advance the
standards for electronic health data exchange including the USCDI so that vendors
and providers can adopt more effective information technology without significant
• Patients need to be clearly, securely, and unambiguously identified using standards
found in NIST Publication 800-63-3 to protect against malicious mis-representation.


Click here to read the full response