I was reminded of the problem we have with U.S. health system data after reading Restrictions Are Slowing Coronavirus Infection, New Data Suggest last week. The data showed a rapid drop in the number of fevers. And where was the data from? It was from 162,000 daily temperature readings shared by Kinsa Health, a producer of internet-connected thermometers. And that is not a typical source of information on public health. This pandemic emergency demonstrates the health care field’s lack of interoperability, which makes it difficult to have “systemic” data to guide decisionmaking or to get a “complete picture” of an individual’s health at the point of treatment.
Let’s hope we have laid the groundwork for solving this problem in the future. On March 9, two U.S. Department of Health and Human Services (HHS) agencies—the Centers for Medicare and Medicaid Services (CMS) and HHS’ Office of the National Coordinator for Health Information Technology (ONC) unveiled two companion rules, one on interoperability and one on information-blocking, to make it easier for provider organizations, insurers, and consumers to exchange health data and give consumers control of their health records at the same time.
The CMS Interoperability and Patient Access Final Rule is focused on driving interoperability and consumer access to health information by requiring data sharing among Medicare Advantage, Medicaid, CHIP, and qualified health plans sold on federally-facilitated exchanges. It was interesting to note that CMS calls this “liberating” the data.
The ONC Cures Act Final Rule mandates adoption of standardized application programming interfaces (APIs), which will help consumers securely and easily access electronic health information using smartphone applications, at no cost. The rule also implements the information blocking provisions of the Cures Act.
There are three key provisions of particular importance—APIs, information blocking, and hospital conditions of participation.
Standard API—The rules require provider organizations and health care insurers [no directives to tech vendors in the rule] to adopt standardized APIs that connect information systems like electronic health records (EHRs) with apps, smartphones, and wearables so consumers can obtain claims and clinical data and share it. A recent example of how the field is moving in this direction: Humana created its Go365 initiative, which allows more than five million members, including Medicare and Medicaid beneficiaries, to share data from hundreds of tech wearables, health apps, smartwatches, and in-home medical devices, such as glucose monitors (see Validic, Humana Collaboration Targets Growing Accessibility, Connectivity Of Health Incentive Programs).
Prevention of “information blocking” practices—The ONC rule prevents health care provider organizations and developers of certified health information technology, health information exchanges, and health information networks from engaging in anti-competitive behaviors that block information sharing. Many EHR contracts contain provisions that prevent or are perceived to prevent users from sharing information in EHRs, such as screen shots or video. It specifies that certified EHRs will be required to have functionality to provide the transfer of clinical data—including core data classes and elements—between provider organizations.
Fees associated with obtaining information were addressed in the rule, which prevents API vendors from charging “excessive fees” and lists “permitted fees” for developing, deploying, and upgrading API technology (starting on page 445 of 1,244 of the 21st Century Cures Act: Interoperability, Information Blocking, & The ONC Health IT Certification Program). It allows companies to make a “reasonable profit” for accessing, exchanging, and using EHI.
Condition of participation for all Medicare and Medicaid participating hospitals—This aspect of the rule addresses care coordination elements because it requires hospitals to send electronic notifications to other health care facilities, community provider organizations, and clinical professionals when an individual is admitted, discharged, or transferred. This requirement will have a major effect on follow-up and could reduce or avoid costs associated with readmissions. And beginning April 1, 2022, CMS will require states to send consumer data daily for beneficiaries enrolled in Medicare and Medicaid to improve care coordination for this population, which will address some of the confusion surrounding benefits (see The Opportunities In Customizing Care For Dual Eligible Consumers).
I think this is a step forward for consumers, for specialty provider organizations, and for public health. As a consumer, I want access to all of my information in a format that I can use and share, and I want to be able to integrate data from my personal health management technologies. (In the interest of full disclosure, I was one of the early adopters of the now-defunct Microsoft personal health record, HealthVault.) And as my colleague, OPEN MINDS Senior Associate Paul M. Duck predicts, the day is coming very soon where consumers will be able to share their entire treatment history with a health care professional without the burden of requesting a copy of records and/or hoping a previous provider organization shares medical record information within a reasonable time frame.
And these developments are good news for specialty provider organizations. Interoperability has been an “in name only” concept when it comes to provider organizations outside of large health systems. The lack of real-time consumer health data has made it difficult to deliver good consumer care or to succeed with performance incentives and value-based reimbursement. The go-forward question for executives of these organizations will be in the implementation. Determining which APIs are available and how to create needed APIs, setting up parameters for accepting consumer health information from other sources, and developing protocols for sending information to stakeholders will be the big lift.
Finally, on the public health front, the pandemic emergency has pointed out the weaknesses of not having a complete consumer health record in an electronic format. Knowledge of consumers’ health status and history in emergency rooms is currently compromised. And without a complete consumer health record, public health planning is compromised as well – a fact our country has learned the hard way during the last month. These new rules are not the “final answer” to an electronic repository of health data but a step in the right direction.
For more on the issues of privacy and data sharing, check out these OPEN MINDS resources:
- Data Whiplash
- 21st Century Cures Act: Interoperability, Information Blocking, & The ONC Health IT Certification Program
- Using Tech To Bridge Care Coordination Data Silos
- Almost 50% Of Hospitals Use Information Received Electronically From Outside Their Health System
- State Of Interoperability Among U.S. Non-Federal Acute Care Hospitals In 2018
- Integrating Physical, Behavioral & Social Health Data
- EHR Vendor, Epic & 60 Health Systems Urge HHS To Modify Proposed Interoperability Rule
- Making The Many Models Of Integration Work
- Integrating Social Care Into The Delivery Of Health Care: Moving Upstream To Improve The Nation’s Health
- Is The Health Center Of The Future In The Palm Of Your Hand?
OPEN MINDS elite members can register for the web briefing, Going “Virtual Service” – Reaching Consumers Where They Are At With Telehealth And More –An Overview with Steve Remillard, OPEN MINDS senior associate. This web briefing is part of the new OPEN MINDS Executive Blueprint for Crisis Management.