Among other stakeholders to submit comments this month were those from CHIME, whose chief recommendations included advancing the availability and utility of data by

• Developing data standards and robust testing requirements for certified EHR technology and other components of health IT referenced in federal policies;
• Adopting a national patient matching strategy;
• Harmonizing privacy laws to reduce burdens on providers attempting to exchange data

"(P)atient data-matching continues to be a dangerous and costly process for hospitals and health systems," CHIME argues. "As data exchange increases among providers, patient data-matching errors and mismatches will become exponentially more problematic and potentially dangerous. CHIME calls on Congress to remove the prohibition baring federal regulators from developing and requiring adherence to standards for a unique patient identifier as a means to dramatically enhance the sharing of healthcare data."

In its comments, the National Committee for Quality Assurance pointed to HEDIS – the Healthcare Effectiveness Data and Information Set, stewarded by NCQA – as "a prime example of both what we are and are not able to do with data today."

The widely-used quality measurement tool "assesses more than 70 areas where there is strong scientific evidence and consensus on what constitutes high-quality care," NCQA's letter points out. "Public reporting of HEDIS results helps regulators and purchasers hold plans and providers accountable for quality, which drives improvement. We continuously update HEDIS for new scientific evidence and to promote further improvement.


"However, HEDIS can only measure quality where there is strong scientific evidence, broad consensus on its meaning, readily available data to accurately assess and audit, and sufficient numbers for statistical significance. The majority of healthcare services provided today do not meet some or all of those essential criteria for valid quality measurement. For example, the most readily available data is in claims, which often lack the detailed, outcomes-oriented metrics that can be found only with greater effort through medical record review."

EHRs could help address some of these challenges, NCQA argues, "by providing easier access to medical record data. They also can provide additional evidence on effective care by aggregating data on how various treatments affect outcomes in unique populations, such as individuals with differing specific chronic conditions, vulnerabilities, and health disparities."

For its part, the American Hospital Association urged Congress to direct CMS to release certain Medicare data on Part  B carriers, Part D prescription drugs, Medicare Advantage enrollees, and inpatient hospital discharges, while still maintaining the privacy and security of individual patient information.

"To accurately assess performance, support risk-based contracting and identify opportunities for improvement, it has become increasingly important to collect and analyze data along every point of the care continuum," wrote AHA Executive Vice President Rick Pollack.

However, he also sounded a cautionary note:

"The demand for data from providers and health care plans is rapidly growing, as the era of 'big data' is at hand," Pollack wrote. "Hospital discharge data sets have been around for decades, while all-payer claims data sets are just beginning to be developed at the state level or through private initiatives. As these resources are expanded, caution must be exercised to ensure privacy and security is maintained.


"Some entrepreneurs and data-mining companies seek access to individual and facility-level data for commercial purposes," he added. "However, we caution that the privacy rules for these relatively new entrants in the health care field are different from those that govern health care providers, and are generally less rigorous."

Other groups weighing in on Wyden and Grassley's request for input include the Bipartisan Policy Center, West Health Institute, Pew Charitable Trusts, the American Medical Group Association and the Healthcare Leadership Council.