As of April 15th CMS has opened up their direct comment button - it is critical if you want to change the rules to comment directly to them

https://www.federalregister.gov/articles/2015/04/15/2015-08514/medicare-and-medicaid-programs-electronic-health-record-incentive-program--modifications-to

CMS is proposing to roll back the patient engagement rules via the Medicare and Medicaid Programs; Electronic Health Record Incentive Program--Modifications to Meaningful Use in 2015 through 2017 to only require 1 patient per provider vs the very low 5% threshold we currently have and to change secure text message to a yes/no threshold as well. 

We all know of people like Regina Holliday's husband Fred - who died to soon in 2009 at age 39 and other friends and family members who have suffered medical errors, gotten the wrong or too little treatment or been unable to make an informed decision about their care because they didn't have access to their health information.

We also know of people like my friend Dave DeBronkart or my mom Carol who not only overcame metastatic cancer but are thriving because they were able to be included in their care and had the health information they needed to make the informed decisions that ultimately saved their lives.  

Patients are critical members of their own care teams and we need full and equal access to same health data that everyone else on our care team has and much of that information is now contained in EHR's.

CONSUMER DEMAND: A Harris Poll in March 2015, showed that 84% of people say their doctor’s offices have a patient portal and 3 in 5 (60%) people are likely to schedule appointments with their doctors via a patient portal or other secure website, if it was available.

CMS INVESTMENT: CMS has already invested over 28 billion in taxpayer money in EHR technology and 94% of hospitals and 77% of Physicans have EHR's. The average MU Stage 2 patient engagement numbers for the early adopters are already over 20% so we know that 5% is achievable. 

CURRENT TECHNOLOGY: Over 1/2 of all patients records are on the same EHR - Epic (which has a patient portal module which has been around for 10+ years) so this isn't a technology problem for more than half the patients in the country.

In addition, many health care systems from the VA to small rural solo providers who are using other EHR systems have demonstrated that it is possible for millions of patients to use a wide range of patient portals and secure messaging to improve their health, manage chronic conditions and stay engaged with the rest of the care team.

REGULATIONS The proposed change to roll back patient engagement in EHR Meaningful Use Stage 2 for 2015 to 2018 to "1 patient per Physician" would gut the very low 5% benchmark we currently have and remove the motivation for Physicians and Hospitals to truly engage with their patients via health IT and potentially deny millions of patients from being able to make informed decisions in their or their family members healthcare. 

SOLUTIONS: You could clarify this rule to remind physicians that they can initiate communications with their patients;  show them how to engage patients by giving them their labs and direct them to the tools ONC has already developed on patient engagement.  You could also apply a sliding scale to the payments to reward those that implement a comprehensive engagement strategy and exceed the 5% threshold vs an all or nothing approach  

ASK: Therefore, we the undersigned request and demand that HHS via CMS Meaningful Use Policy for Stage 2, continue to support a patient centered health care system that treats all members of the health care team (which includes patients) equally. "Nothing done to me without me"

We respectfully demand, that you continue to ensure that patients have access to both their care team and their health information by continuing to insist that at a minimum providers engage with at least 5% of their patients via health technology.

 NOTE: After April 15th you can give your comments directly to CMS here https://www.federalregister.gov/articles/2015/04/15/2015-08514/medicare-and-medicaid-programs-electronic-health-record-incentive-program--modifications-to