CMS, ONC interoperability regs are the floor, not the ceiling for health plans, hospitals, survey finds

The Centers for Medicare & Medicaid Services and the Office of the National Coordinator for Health IT published proposed rules back in February designed to drive the industry toward widespread interoperability. (Profit_Image/Shutterstock)

Nearly two-thirds of health plans (63%) say they are using recently proposed federal interoperability regulations as the first step toward broader strategies on interoperability, according to a new survey.

This suggests compliance with the new standards will be seen as the bare minimum in healthcare interoperability programs, according to a survey from the Deloitte Center for Health Solutions. Forty-three percent of health system chief technology officers or chief information officers also said the proposed interoperability standards will the baseline for broader strategic interoperability initiatives.

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) published proposed rules back in February designed to drive the industry toward widespread interoperability.

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CMS' proposed rule (PDF) would require Medicaid, the Children’s Health Insurance Program, Medicare Advantage plans and Qualified Health Plans to make enrollee data immediately accessible via application programming interfaces (APIs) by Jan. 1, 2020.

RELATED: HIMSS19: ONC, CMS officials outline the framework for interoperability, the use of APIs, FHIR

ONC also unveiled its information blocking rule (PDF) that defines exceptions to data blocking and fines that may be associated with the practice. The rule was mandated by the 21st Century Cures Act.

Many healthcare groups and stakeholders have voiced concerns about the interoperability rules, urging CMS to take a phased approach to implementing the standards, saying the proposed 2020 implementation timeline is "unrealistic." Some groups, like the Health Innovation Alliance, have called for the recently proposed interoperability rules to be scrapped and rewritten.

Federal policymakers are using multiple regulatory levers to advance interoperability such as new payment models, the Trusted Exchange Framework and Common Agreement and a recent executive order on transparency.

"Taken together, these initiatives showcase the administration’s continued push to make health care information more accessible by encouraging plans and providers to share data with each other to improve the quality and efficiency of health care and with patients to help them make informed decisions," Deloitte Center for Health Solutions executives wrote in a report about the survey results.

The survey found that some healthcare organizations are just ticking off the boxes before moving on to other priorities. Nearly half of health systems (49%) and 34% of health plans say they have no plans to go beyond compliance requirements as part of the new interoperability rules. Eight percent of health systems and 3% of insurance technology executives said they have not read the proposed rules or are still determining the implications of the rules.

RELATED: Health IT stakeholders calling for ONC, CMS to 'go back to the drawing board' on interoperability rules

The survey also revealed that most healthcare organizations are going beyond the interoperability solutions provided by their vendors. Half of health system (55%) and 60% of health plan executives say they are either building their own API solutions or are doing so even while they work with a vendor to build solutions.

About 40% of healthcare organizations are using vendors and have access to APIs provided by vendor applications or packages. Only about 3% of healthcare executives say their organizations currently do not use APIs.

"By 2040, we expect the system to be dramatically different than it is today," wrote the report authors. "Health will likely be driven by digital transformation enabled by radically interoperable data and open, secure platforms. Moreover, consumers will own their health data and play a central role in making decisions about their health and well-being."

Organizations that develop and implement a strategic approach to interoperability are likely to have a competitive advantage with insights, affordability and consumer engagement in the future of health. Healthcare organizations that fail to see beyond compliance deadlines will fall behind, Deloitte executives said.

The report authors recommend three key steps for healthcare organizations to consider when developing an interoperability strategy:

  • Define the interoperability vision for the organization—Organizations should leverage the regulatory requirements on interoperability as a jumping off point for their broader strategy for sharing data with industry stakeholders and with patients. Establish an initial interoperability governance structure, and develop a business case and key business/technology benefits. Also, identify high-value use cases such as enhanced care management and/or improved consumer and patient engagement.
  • Assess the current state—Evaluate the organization's current interoperability capabilities and define the desired future state, then conduct a gap analysis between current and future state. Develop an external engagement plan; for example, forge partnerships and encourage collaboration with external entities to better enable the interoperability vision.
  • Develop an execution road map—Prioritize a set of initiatives and road map to achieve compliance by the proposed Jan. 1, 2020, deadline. Identify longer-term goals beyond the Jan. 1, 2020, compliance date around data exchange, digital tool adoption and enhanced consumer engagement. Assign “high priority” to the must-do/critical capabilities.

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