MACRA / MIPS Comment: We need API Support!

Today is the last day of the comment period for CMS’s MACRA and MIPS proposed rules. Below, we share a comment we submitted promoting the use of APIs for patient and provider access alike.

CMS states that priorities for “Advancing care information” are patient engagement, electronic access, and information exchange:

> These measures have a focus on patient engagement, electronic
> access and information exchange, which promote healthy behaviors
> by patients and lay the ground-work for interoperability.

… but nothing in CMS’s proposed MIPS measurement strategy in fact places an emphasis on these goals. Consider patient API access through third-party apps, which falls squarely in the intersection of these focus areas. Under the proposed scoring rubrics, a provider can earn 100% full marks on “advancing care information” while making API access available only to a single patient!

CMS should take actions to ensure that the “priority goals” are in fact met. One clear way to fix this issue would be to define a scoring function where patient API access is a hard line. For example, MIPS could require providers to offer API access to all patients in order to be eligible for the “base score”. This special-priority treatment is already given to one objective (“Protect Patient Health Information”); it should be extended to other priority items including patient API access. Otherwise, these “priorities” can, in fact, be entirely ignored by MIPS EPs, given the elaborate structure of bonus points and the “ceiling effect” of earning just 100 points out of a possible 131 points.

CMS should also add an explicit requirement for APIs that be used by healthcare providers as well as patients. Current meaningful use requirements focus on patient API access; MACRA should expand access to clinicians as well. To be concrete in advancing interoperability, MIPS could award points for clinicians who run at least one third party application against their EHR data (for example, see the SMART on FHIR open app platform specifications at and at least one third party decision support service (for example, see the SMART CDS Hooks specifications at