Shared decision making (SDM) continues to gain great momentum through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and Meaningful Use (MU), but a proposed change to the MU requirement for Stage 3 threatens that progress. Last month, the Centers for Medicare and Medicaid Services (CMS) proposed a modification: to retire the Clinical Decision Support (CDS) measure, which includes tools for shared decision making, because it’s “topped out.”
So what does “topped out” mean exactly? According to CMS, 90% of hospitals have met the CDS measures for MU in previous years—but that high performance measure doesn’t tell the whole story. These hospitals have successfully implemented provider-facing alerts. But CDS also includes patient-facing tools, and that part of the measure has been underutilized. This narrow interpretation of the CDS requirement puts patients at a disadvantage. After all, isn’t the goal to provide the best care possible? Achieving that goal starts with getting the right information to the right patient at the right time.
A broader view of patient-facing CDS is defined in regulations from the Agency for Healthcare Research and Quality (AHRQ). This broader view includes patient education, health risk appraisals, diagnostic decision support driven by patient-specific data, secure messaging, patient reminders, medication instructions, pre-visit preparation, disease management interventions, and CDS within the patient portal. All of these CDS tools help put the patient at the center of their own care.
Removing the CDS measure not only would take away opportunities for shared decision making and patient education, but also would jeopardize future implementations by removing the measure from MACRA. We are so encouraged that the MACRA categories of transformation—Quality, Clinical Practice Improvement Activities, and Advancing Care Information—integrate the patient as an active, engaged stakeholder. MACRA offers a new paradigm to support, engage, and inform patients outside the traditional healthcare settings with the use of technology, shared decision making, engagement, measurement, and payment innovation. To remove CDS in its entirety is a short-term success with long-term repercussions: patients will lose. A Pyrrhic victory.
It’s time for a clear statement of support for patient-facing CDS to ensure that the momentum for shared decision making continues.
Comments on the proposed modification are due to CMS by September 6. Join us in making the case by submitting your own comments, sharing this blog post, or sending one of the following tweets to CMS.
#CDS isn’t ready to see the sunset @CMSGov #toppedoutthinkagain
#CDS objectives belong in #MU measures @CMSGov #toppedoutthinkagain
Keep #CDS in #MU measures @CMSGov #toppedoutthinkagain
Removal of #CDS objectives as a whole jeopardizes #patientengagement @CMSGov #toppedoutthinkagain