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Interoperability Rules!

May 30, 2019

By: Victor Lee

In a blog from last year, I summarized a variety of national and local efforts to hasten the interoperability of healthcare data. In this entry, I’d like to focus on a few new developments from the U.S. Department of Health & Human Services (HHS).

data brief from the Office of the National Coordinator for Health Information Technology (ONC) was published in November 2018 and showed that U.S. non-federal acute care hospitals made progress with interoperability of electronic health information between 2014 and 2017.

Figure 1: Percent of U.S. non-federal acute care hospitals that electronically find patient health information, and send, receive, and integrate patient summary of care records from sources outside their health system, 2014-2017. Source: ONC Data Brief 42, November 2018.

However, another ONC data brief from May 2019 focused on office-based physicians and revealed that interoperability remained stagnant between 2015 and 2017.

Figure 2: Percentage of office-based physicians engaged in interoperable exchange of patient health information from outside sources, 2015-2017. Source: ONC Data Brief No. 47, May 2019.

Given these results, our nation clearly has room for improvement, and HHS is setting policies to advance its interoperability agenda. Let’s take a closer look at some recent regulatory activities.

First, the Centers for Medicare & Medicaid Services (CMS) Promoting Interoperability program (formerly known as the “EHR Incentive Programs” or “Meaningful Use”) is adjusted annually through federal (Medicare) and state (Medicaid) regulations. While Medicare and Medicaid requirements may differ across eligible hospital (EH) and eligible professional (EP) participants, in general the requirements fall into a subset of the following objectives and measures:

  • Protecting patient health information
  • Electronic prescribing
  • Clinical decision support
  • Computerized provider order entry
  • Patient electronic access to health information
  • Coordination of care through patient engagement
  • Health information exchange
  • Public health and clinical data registry reporting

For more details, the 2019 specifications for each program can be accessed here: 2019 Medicaid EH2019 Medicaid EP, and 2019 Medicare EH. What happened to the Medicare EP component? If you recall from a previous discussion, this was morphed into the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act of 2015 where Medicare EPs enroll in either the Merit-based Incentive Payment System or Advanced Alternative Payment Model track.

Second, on February 11, 2019, CMS and ONC simultaneously released proposed rules to advance interoperability of patient health data. Highlights of the CMS proposed rule include patient access through application programming interfaces (APIs), health information exchange and care coordination across payers, API access to published provider directory data, care coordination through trusted exchange networks, improving the dual eligible experience by increasing frequency of federal-state data exchanges, public reporting and prevention of information blocking, advancing interoperability in innovative models, and more. The full text of the CMS proposed rule is available here.

The ONC proposed rule implements provisions in Title IV of the 21st Century Cures Act. It addresses API certification criteria for “API Technology Suppliers” (as defined by the proposed rule), electronic health information export for patient and provider access, further modifications to the U.S. Core Data for Interoperability (USCDI), information blocking provisions (including reasonable and necessary activities that do not constitute information blocking), and numerous other provisions. The full text of the ONC proposed rule is available here.

Finally, a second draft of the Trusted Exchange Framework and Common Agreement (TEFCA) was released by ONC on April 19, 2019 for public comment. TEFCA addresses certain interoperability requirements of the 21st Century Cures Act and aims to provide a single “on-ramp” to nationwide connectivity, ensure that electronic information follows patients when and where it’s needed, and supports nationwide network connectivity. Details of TEFCA draft 2 are available here.

Clinical Architecture believes that CMS and ONC are addressing the key interoperability issues that impact patients, providers, and payers. The common thread across all of these proposed regulations is that HHS advocates not just interoperability but also patient empowerment, transparency, and marketplace competition. We feel that this is a good recipe for success, and we eagerly await the final rules following closure of the public comment periods. We encourage you to comment as well, both on our blog and to HHS.

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