When nine organizations -- several of them health IT vendors -- urged Congress in a Dec. 7 letter to resist delaying Stage 3 of the Meaningful Use EHR Incentive Program, the plea came with an outline for strengthening interoperability.

"What is clear to us is that current requirements and pace of the Meaningful Use program have taken away time and valuable resources from fixing our nation's interoperability problem, the organizations -- Apervita, athenahealth, Intel, National Alliance on Mental Illness, New Directions Technology Consulting, Oracle, United Spinal Association and Verizon -- wrote in their letter to Congressional leadership.

In their view, delay of Stage 3 is not the way to go.

[Read: Congress urged oppose Stage 3 delay and Carequality interoperability framework seeks wide appeal.]

"Delay without reform would rob taxpayers and patients of cost savings while doing absolutely nothing to make the program work well for overburdened doctors and hospitals," they wrote.

As they see it, there's a way to get much promised and much needed interoperability.

They provided Congress with a 10-point list, intended to pave the way.

1. Definition of interoperability
Support establishing a common definition of interoperability in statute.
2. Information blocking
Strongly support once and for all ending information blocking in a taxpayer-funded program intended to exchange information.
3. Standards
Support adoption of industry-developed standards - based upon reference implementation models, promotion of open APIs and thorough interoperability testing as a condition of certification.
4. Certification
Congress should provide incentives to vendors to continuously improve their products. We suggest basing full certification of products on performance of those products on key measures of interoperability and usability.
5.Testing
NIST should be charged with testing interoperability of products in test beds, while ACBs should be required to conduct field surveillance to test whether products conform to the standards established in the program.
6. EHR Marketplaces
Physicians should have access to all relevant data about an EHR before deciding to use one in practice, including data on certification, decertification, penalties and information blocking incidents in a way that is usable and easily accessible to stakeholders.
7. Reporting problems
Congress should require HHS to establish a process and online tool for providers and patients to report instances when the provider's EHR is unable or fails to transmit or receive patient information with another provider or when the patient is unable to transmit or receive information from their provider.
8. Enforcement
Support applying civil monetary penalties and decertification - program exclusion - for bad actors, including those who engage in information blocking. However, we believe Congress should enact additional protections for providers' whose products are decertified or who are forced to switch products due to unfair business practices engaged in by vendor companies, such as information blocking.
The group wants Congress to require CMS to provide all providers whose product has been decertified with a hardship exemption, as included in H.R.6. It also urges Congress to establish a hardship fund to aid providers with this transition. The group also urged Congress to make it easier for providers to get access to the full suite of data contained in their EHRs in an interoperable format to facilitate their transition to a new vendor.
9. Penalty structure
Support allowing HHS to charge penalties against vendor companies for bad actions, such as not adhering to interoperability standards or information blocking and use those penalties to assist providers whose EHR systems have been decertified.
10. Operational efficiencies
ONC shouldn't manage grant programs, as it's not in their core set of competencies, and it detracts from what should be their primary focus - achieving interoperability across systems and providers. We suggest transferring grant authority to an alternative agency with experience and dedicated staff capable of administering funding programs.