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September 14, 2021 

The Honorable Micky Tripathi, PhD, MPP
Administrator
National Coordinator for Health Information Technology 
U.S. Department of Health and Human Services
330 C Street, S.W.
Washington, DC 20201 

Submitted electronically via [email protected] 

RE: Request for Public Feedback on Draft Developer-Reported Measures for the EHR Reporting Program 

Dear Dr. Tripathi: 

The National Association of ACOs (NAACOS) is pleased to submit comments in response to the Request for Public Feedback on Draft Developer-Reported Measures for the Electronic Health Record (EHR) Reporting Program. We appreciate the efforts of the Office of the National Coordinator for Health Information Technology (ONC) to provide input on the voluntary user measures for the EHR Reporting Program, designed to provide publicly available, comparative information on certified electronic health record technology (CEHRT) products to inform users’ purchasing and implementation decisions. 

NAACOS represents more than 370 ACOs participating in a variety of value-based payment and delivery models in Medicare, Medicaid, and commercial insurers. Serving more than 12 million beneficiaries, our ACOs participate in models such as the Medicare Shared Savings Program (MSSP), the Next Generation Model, the Direct Contracting Model, and other Alternative Payment Models (APMs). NAACOS is a member-led and member-owned nonprofit organization that works to improve quality of care, health outcomes, and healthcare cost efficiency. 

As stated in the proposed 2022 Medicare Physician Fee Schedule, the Centers for Medicare & Medicaid Services (CMS) has a goal to move to a fully digital quality measurement system for value-based purchasing programs by 2025. While NAACOS believes that timeline is overly ambitious, the move to a more streamlined form of reporting and measuring quality is inevitable and necessary as our health system mores to one that better rewards value and outcomes. Measuring the quality of care that providers deliver to patients is a hallmark of value-based care and should be optimized as payers, including CMS, move toward a value-based care system. 

As with many other aspects of our health system, this move to a fully digital quality measurement system is both dependent on a well-functioning health information technology (IT) system and limited when that health IT system fails. For example, ACOs, which are the predominant APM in existence today, are held to quality standards but must be able to aggregate data from disparate providers in order to report to payers. According to a NAACOS survey of ACOs from earlier this year, nearly half of ACOs’ participating practices use 11 or more EHRs, and the biggest barrier cited for movement to electronic Clinical Quality Measure (eCQM) reporting was the lack of EHR standardization.