National Gap Analysis and Readiness Assessment for the Health Information Technology Infrastructure to Enable the Electronic Exchange of Quality Measures as part of EHR Meaningful Use Questions for Industry
Background: This is Request for Information (RFI) only. It does not constitute a commitment that the Centers for Medicare & Medicaid Services (CMS) or the Department of Health and Human Services (HHS) will undertake a procurement action in this matter. Further, the Department will be engaging in notice and comment rulemaking regarding the incentive payments for meaningful use of electronic health record (EHR) technology under Medicare and Medicaid, as authorized by the American Recovery and Reinvestment Act of 2009 (ARRA), Pub. L. 111-5, and nothing in this RFI should be viewed as indicating the final policies that will be adopted pursuant to such rulemaking. Finally, respondents should be aware that that the Federal Government is not responsible for any costs you incur in furnishing information in response to this RFI.
In preparation for the implementation of the healthcare segment of ARRA, HHS wishes to conduct a national scan of the electronic infrastructure available among all entities sharing a role in the reporting of measures, including quality measures, to potentially support meaningful EHR use in the near term and the broader exchange of health information expected with health care reform. These entities include federal agencies, such as CMS, Health Resources and Services Administration (HRSA), the Centers for Disease Control and Prevention (CDC), State Medicaid agencies, other State agencies (e.g. public health departments), Health Information Exchanges/Health Information Networks, and healthcare providers. This work is foundational for health reform and may help to guide the design and implementation of grant programs under the Health Information Technology for Economic and Clinical Health Act (HITECH), as well as the requirements for the public and private infrastructure that may be needed for the Medicare and Medicaid incentives program for meaningful use of EHRs.
Plans for the implementation of the healthcare segment of ARRA may be informed by the public documents produced by, but not limited to: the American Health Information Community Quality Workgroup; Federal Health Architecture (FHA); CMS Medicare, Medicaid and CHIP programs; National Qualify Forum's (NQF) Health Information Technology Expert Panel (HITEP); Healthcare Information Technology Standards Panel (HITSP) and Certification Commission for Healthcare Information Technology (CCHIT) panels; the Office of the National Coordinator's Health Information Technology (HIT) Standards and Policy Advisory Committees and recent public testimony from the National Committee on Vital and Health Statistics (NCVHS) hearing on Meaningful Use of Health Information Technology.
RFI Questions: CMS is requesting industry feedback regarding the following: 1. Describe, in a list of alternative options to HHS, the tasks, general levels of effort, high-level deliverables and timelines required to generate an initial national strategic framework for a national health information infrastructure, describing the functions and roles of various HIT applications and processes, including EHRs, health information exchanges (HIEs), and data aggregation processes, validation methods, and reporting, acknowledging the relationship to HITECH sections 3011, 4101, 4102, and 4201. These options should address both short-term and long-term objectives and identify which of those objectives would have the greatest impact on the successful implementation of HITECH Sections 3011, 4101, 4102, and 4201. This description shall include the following:
a. A synthesis of the relevant, existing work products, including, but not limited to those produced by: 1. American Health Information Community (AHIC); 2. Federal Health Architecture (FHA); 3. CMS Medicare/Medicaid/CHIP Programs (including Medicare Advantage, Medicare Part D, Medicaid Managed Care External Quality Review Reporting, Medicaid Transformation Grants, State Listening Sessions, the Multi-State Collaboration for Medicaid HIT/Transformation, etc.); 4. National Quality Foundation's (NQF's) HITEP; 5. HITSP & CCHIT panels and work groups; 6. ONC's HIT Standards and Policy Advisory Committees; 7. Nationwide Health Information Network (NHIN)/NHIN Connect; 8. Public testimony from the recent NCVHS Hearings on Meaningful Use of Health Information Technology and the States' Medicaid HIT Plans; and 9. All available public sessions, panels, white papers, and Congressional testimony that have contributed relevant information. b. Interoperability standards. c. Security and privacy standards and discussions, including but not limited to two factor experiences and methods. d. Capacity Planning. e. Existing resources from Federal and State investments in HIT infrastructure and service-oriented architecture. f. A draft outline of a long-term national strategy for a health information infrastructure.
2. Describe tasks and general levels of effort, high level types of deliverables and timelines required to convene a team of health information and quality experts from across the public and private sectors to validate a national strategic framework approach that is based on existing efforts, including organizational capacity, and experience.
3. Describe the tasks, high level types of deliverables, general levels of effort and timelines associated with developing an operations plan with sufficient information to inform the electronic reporting, transmission, and collection of quality data. Of high importance is the focus on the most efficient utilization of ARRA funding aimed at building the capacity for automating quality measurement and reporting across health care providers eligible for the incentives for meaningful use of EHRs, which includes consultations with identified experts in relevant fields.
4. Describe the tasks, high level deliverables, general levels of effort and timelines associated with developing and operations plan with enough detail to inform the implementation of the Children's Health Insurance Program Reauthorization Act (CHIPRA) such that quality measure reporting and pediatric EHR development aligns with efforts of HITECH.
5. Describe the ideas and suggestions around the development of a draft strategy that encompasses all required processes, procedures, policy decisions, gap analyses, and organizational capacity, to include HIT applications, in support of electronic reporting, transmission, and collection of quality data across providers eligible for Medicare and Medicaid meaningful use.
6. Describe the ideas and suggestions around the delivery of an operations plan that specifies the process steps, roles, and responsibilities that support the automated health and quality exchanges beginning in 2012 and beyond.
7. Describe how the information infrastructure to enable electronic exchange of quality measures would need to accommodate a health plan perspective. The perspective should consider/incorporate the following: what variables about a service could be collected by an electronic health record that would be of unique interest to health plans and payers of health plans; what indicators and other fields would be required in an electronic health care record to allow provider performance data to be attributed to a specific health plan; what information could be collected to control for duplication concerning quality incentive payments; how would data flow between providers, plans and payers; how would relevant verification information be shared with plans/payers; what transaction standards would be needed to permit data exchanges; and, can the data be disaggregated by the health plan in order to assess correlations between outcomes and differential payer participation requirements or payment incentives.
8. Describe the problems and barriers among Medicare fee-for-service, Medicare Advantage, Medicaid and other payers in aligning measurement and data requirements, as well as data transfers. Describe strategies what would facilitate ameliorating these problems and barriers.
9. Describe the problems and barriers with current forms of validation methods, manual chart collection and abstraction, sampling, etc. Describe suggested strategies that may facilitate ameliorating these problems and barriers.
Responding to this RFI:
Please provide your response to this Request for Information (RFI) to Scott Filipovits at email@example.com no later than close of business Thursday, October 1, 2009. Responses should be submitted as an email attachment in Microsoft Word 2003 format.
For purposes of this RFI, the term "vendor" refers to those members of industry providing responses to this RFI. Vendors may label information as "confidential" or "proprietary", and explain the reason for such labeling.
CMS will use the information submitted in response to this RFI at its discretion and will not provide comments to any vendor's submission. However, responses to the RFI submitted may be reflected in future solicitation(s). CMS reserves the right to contact any vendor that responds to this RFI for the sole purpose of enhancing CMS' understanding of your RFI submission.
This notice is for informational purposes only and does not constitute a solicitation or Request for Proposal. This RFI is not to be construed as a commitment by the Government. The Government will not pay for any information provided as a result of this RFI and will not recognize or reimburse any cost associated with any RFI submissions.