Last updated: 11/14/17

By Dr. Dave Levin

The title may not be very sexy, but the content and direction of CMS’s latest fact sheet on information blocking should grab everyone’s attention. As the fact sheet makes clear, in order to qualify for the Merit-based Incentive Payment System (MIPS), eligible clinicians must attest that they have not knowingly and willfully limited or restricted the compatibility or interoperability of their certified electronic health record (EHR) technology. The fact sheet specifically calls out technical, policy and workflow decisions as the keys to meeting the requirement and, by implication, the ways that providers and EMR vendors might fail to show “good faith efforts” to meet these requirements.

It seems clear that CMS is leveraging the power of MIPS to drive greater data sharing and interoperability of both providers and, through them, EMR vendors.

There’s some intriguing language regarding the expected results when it comes to ease of access buried within Statement 2 of the attestation. When using certified EHR technology (CEHRT) the provider must attest that it was (emphasis added):

  • Implemented in a manner that allowed for timely access by patients to their electronic health information (including the ability to view, download and transmit this information);
  • Implemented in a manner that allowed for the timely, secure, and trusted bidirectional exchange of structured electronic health information with other health care providers, including unaffiliated providers, and with disparate CEHRT and health IT vendors.

Couple this with the new provision in the 21st Century Cures Act that requires electronic records to exchange data with other records in a way that requires “no special effort” and you begin to see a pattern emerging. This builds on the increasing emphasis by Congress and the Office of the National Coordinator (ONC) on robust interoperability solutions that really work and are relatively easy to implement and support.

It is true that the precise meaning of “no special effort” is open to interpretation and the new MIPS attestation is based on “good faith” efforts. It’s also true that current approaches to integration that rely heavily on inadequate and unwieldy, 30-year old technologies like HL7 do require substantial special effort.  Add to that the excessive administrative and legal barriers that some organizations and vendors have adopted and the effort becomes truly special – and not in a good way!

On the other hand, API-based approaches, like the ones we use at Sansoro, more than meet the challenge of being powerful, open and easy to implement and support. If you want to make a good faith effort to meet the MIPS interoperability requirements and unleash the value of health IT investments, Sansoro has the answer.


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Dave Levin, MD is the Chief Medical Officer for Sansoro Health where he focuses on bringing true interoperability to healthcare. Dave is a nationally recognized speaker, author and former CMIO for the Cleveland Clinic. He has served in a variety of leadership and advisory roles for Health IT companies, health systems and investors. You can follow him @DaveLevinMD or email


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