Guest Post from Danielle Morrison, Health Informatics Analyst, All Covered, IT Services Division of Konica Minolta

The fundamental goal of interoperability within healthcare is to have all entities and information, human and non-human, structured and unstructured, capable of working together to improve the health of patients and populations in a cost-effective manner.

In theory, this is a simple concept like teamwork. If everyone and everything works together efficiently, there will be better outcomes.  Unfortunately, this theory, which received a supporting boost in healthcare with the HITECH Act in 2009, has been caught in a quagmire due to lack of standardization, conflicting or inconsistent policies and countless disparate parties and vendors.

Though most healthcare organizations genuinely understand and appreciate the need for interoperability, achieving it is a significantly more difficult task.  There are a variety of existing challenges to interoperability in healthcare. As an industry, healthcare tends to lag behind others in adopting comprehensive analytics that have both predictive and retrospective usable data, leaving it to often work reactively rather than proactively. Electronic Health Record (EHR) systems hold a vast wealth of information, but exchanging that information in real time, or near real time, and as actionable data for users at multiple levels has proven to be problematic and often costly.

Physician on TabletTwo individual examples of interoperability process challenges are patient referrals and transitions of care. Both are critical components in the success of patient healthcare outcomes and have significant impact on the health of individuals and populations.  They carry so much merit that there are multiple Quality Payment Program (QPP) measures in 3 of the 4 QPP categories, and, though not directly referenced in the QPP cost measures, failure of a referral or transition of care communication can have costly and severe consequences.  Healthcare organizations and providers are painfully aware of the need to seamlessly share this information and the obstacles here are readily identifiable, but not easily remedied. As one healthcare organization progresses with the adoption and implementation of their EHR and workflows, the organization next door can be doing the same but with an entirely different EHR system and its unique workflows.  Due to a few ambiguous standards imposed on these unaffiliated EHR systems, the rapid electronic exchange of patient information, especially that of clinical relevance, is often awkward and, at times, unfeasible.

Additionally, the historical use of healthcare information and data has been focused only on delivery to providers and payers, minimizing the information provided to patients. As a whole, the information and delivery platforms available to patients are most often redundant, not user friendly, segmented or unengaging. Patients expect and want their provider to have a single view of their full medical history, including information from visits and tests completed outside of that particular organization.  But the expectations and what frequently occurs are not necessarily in agreement.  Patients with several key care providers from independent organizations will have processes, document formats and access portals that vary as much as their providers’ specialty or area of expertise.

Those who work within the healthcare industry experience the silos daily and recognize that the individual patient experience iterates the challenges at many levels of the healthcare spectrum. Whether personally or professionally, it can lead to frustration and decreased satisfaction which can further spiral into disengagement and decreased cooperation – the complete opposite to the goals of interoperability.

In March 2020, two final rules were issued by the HHS Office of the National Coordinator for Health Information Technology (ONC) and Centers for Medicare & Medicaid Services (CMS). Now known as the “21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program”, they implement interoperability and patient access provisions of the 21st Century Cures Act.  When finalized in April, these rules were noted as “new policies that help liberate health information and move the healthcare system toward greater interoperability.”

Some of the key highlights from the CMS fact sheet are:

  • CMS-regulated payers are required to implement and maintain a secure, standards-based (HL7 FHIR Release 4.0.1) API that allows patients to easily access their claims and encounter information, including cost, as well as a defined subset of their clinical information through third-party applications of their choice.
  • CMS-regulated payers are required by this rule to make provider directory information publicly available via a standards-based API.
  • CMS-regulated payers are required to exchange certain patient clinical data (specifically the U.S. Core Data for Interoperability (USCDI) version 1 data set) at the patient’s request, allowing the patient to take their information with them as they move from payer to payer over time to help create a cumulative health record with their current payer.
  • CMS will publicly report eligible clinicians, hospitals, and critical access hospitals (CAHs) that may be information blocking based on how they attested to certain Promoting Interoperability Program requirements. Knowing which providers may have attested can help patients choose providers more likely to support electronic access to their health information.
  • CMS will begin publicly reporting those providers who do not list or update their digital contact information in the National Plan and Provider Enumeration System (NPPES). This includes providing digital contact information such as secure digital endpoints like a Direct Address and/or a FHIR API endpoint. Making the list of providers who do not provide this digital contact information public will encourage providers to make this valuable, secure contact information necessary to facilitate care coordination and data exchange easily accessible.
  • CMS is modifying Conditions of Participation (CoPs) to require hospitals, including psychiatric hospitals and CAHs, to send electronic patient event notifications of a patient’s admission, discharge, and/or transfer to another healthcare facility or another community provider or practitioner.

In finalizing these policy changes, the concept of interoperability presented in the HITECH Act and further expanded upon in the Cures Act has been given a huge push forward. It incorporates an aspect of healthcare interoperability that had been often previously left out – the patient.

The final rule states that providers will be required to connect their EHR to third-party apps using secure APIs and these APIs must be built using FHIR standards. Thus, it allows patients to access their health information, presented by their provider’s EHR, into a third-party app of their choosing. For payers, this final rule calls on Medicare, Medicaid and CHIP health plans, as well as those sold on the federal exchanges, to grant electronic access to patient claims data. Patient claims data must be shareable with patients via a third-party app powered by a FHIR-based API.  The days when the only information exchange that mattered was between two providers are gone. The number of stakeholders that have been identified as valuable exchange partners has just grown exponentially.

In spelling out the interoperability transport mechanism and standard data set, while explicitly calling out data blockers or those who do not actively support the rules intent on sharing patient’s records in a standardized way, the path for the vendor community to building an interoperability roadmap of exchange has finally been created.

Organizations such as DirectTrust and projects akin to 360X have a longstanding appreciation for the full breadth of historic information exchange challenges. They have been spearheading the development of standards and protocols to resolve them in a vendor-agnostic manner for years. Platforms that facilitate the automation of key provider-to-provider communications and include clinical information, essential to the progression of interoperability, particularly relating to the flow of provider referrals and transitions of care, is already in progress.

Requirements of both public and private entities to share health information between patients and other parties, while maintaining privacy and security, and presenting it in an understandable and usable format to the appropriate end-user, will pose its own new set of challenges. And the changes to the Cures Act are no panacea for the current interoperability impediment. Still, they will likely compel healthcare organizations, payers, vendors, and even possibly patients or patient advocacy groups, to expedite solutions. Embracing the momentum these policies impose is a positive step in achieving interoperability.

If your organization is experiencing any IT challenges or concerns, All Covered, IT Services Division of Konica Minolta, can help. Our Healthcare Practice team is available to guide you in the best way possible.  We have a longstanding legacy of successfully assisting healthcare organizations in many areas: selecting, implementing and optimizing EHR systems, achieving interoperability, shifting to value-based care, assessing and mitigating security and compliance risks, implementing cloud services, reducing IT expenditures and improving operating efficiencies.  We continue to work in close collaboration with healthcare organizations and vendors that result in advanced co-innovations to help the healthcare landscape reach desired outcomes. Our full portfolio of services, solutions and products can truly guide your organization in positively adopting these new policy changes in an effective and timely manner and ultimately improve patient care.

(Note there are many other finite points to CMS Fact Sheet, even in reference to who is considered to be a CMS regulated payer within each API and Exchange and due to COVID -19 CMS is making frequent new announcements extending implementations or delaying enforcement of these requirements. To access the CMS Fact Sheet, go to www.cms.gov/newsroom/fact-sheets/interoperability-and-patient-access-fact-sheet. To view the full CMS Interoperability and Patient Access final rule, visit www.cms.gov/Regulations-and-Guidance/Guidance/Interoperability/index)

Konica Minolta All Covered Danielle Morrison PhotoAbout the author:

Danielle Morrison, BSN, RN is a Healthcare Systems Analyst with Konica Minolta’s IT Healthcare Services Division, All Covered. Danielle has been a Registered Nurse for over 20 years and began her career after earning a Bachelor of Science in Biology followed by a Bachelor of Science in Nursing.  As a Health Informatics Analyst, Danielle has experience in performing information analysis and managing incentive programs directed at moving healthcare organizations into value-based care. She also ensures the systems and solutions meet the needs of healthcare organizations and business.