How HIEs Can Prepare Clients for the ONC Interoperability Rule

By Christopher Jason

March 19, 2021 – This time last year, the Office of the National Coordinator for Health Information Technology (ONC) dropped the interoperability rule as a part of the 21st Century Cures Act, which primarily focuses on information blocking and patient data exchange.

The rule also supports patients accessing and sharing their electronic healthcare information, which ultimately helps patients coordinate their healthcare.

The rule also forbids information blocking and aims to hold health IT developers, such as EHR vendors, responsible as a condition of certification.

“Delivering interoperability actually gives patients the ability to manage their healthcare the same way they manage their finances, travel and every other component of their lives,” Don Rucker, MD, former national coordinator for health information technology, said of the final rule at the time.

“This requires using modern computing standards and APIs that give patients access to their health information and give them the ability to use the tools they want to shop for and coordinate their own care on their smartphones,” Rucker continued. “A core part of the rule is patients’ control of their electronic health information which will drive a growing patient-facing healthcare IT economy and allow apps to provide patient-specific price and product transparency.”

But due to COVID-19, ONC delayed the information blocking provisions and requirements compliance date until April 5, 2021. Additionally, the 2015 edition health IT certification criteria updates and the new standardized API functionality dates are now mandatory by December 31, 2022.

Not only will providers have to abide by the ONC final rule, but the CMS interoperability rule addresses admission, discharge, and transfer (ADT) notifications. Providers need to fulfill a CMS condition of participation that will require all healthcare facilities to send outbound event notifications by May 2021.

All healthcare facilities must send direct electronic notifications to a patient’s provider once the patient is admitted, discharged, or transferred from another facility.

Health information exchanges are in a prime position to help prepare their clients accordingly.

IMPLEMENTING ADT NOTIFICATIONS

The CMS rule will require all providers to send a notification to a patient’s provider after the patient is admitted, discharged, or transferred from another healthcare facility. HIEs can help enable this by embedding their own ADT notifications structure within the HIE service.

Manifest MedEx (MX), a nonprofit HIE network in California, currently helps facilitate patient data between 120 hospitals, 700 ambulatory care sites, seven health plans, 13 EMS providers, and six EMS agencies.

The California-based HIE currently offers real-time ADT notifications to its connected healthcare organizations and up to seven years of searchable patient medical history to improve clinical decision making, patient care delivery, and hospital savings.

“The great thing about an infrastructure like MX is we do the heavy lifting of going to the ambulatory providers, getting their patient panels, and setting up the panel,” Claudia Williams, Manifest MedEx CEO, said in an interview with EHRIntelligence.

“All the provider needs to do is share an ADT and we make it so the client does not have to figure it all out on their own. Then, sort of magically, when the provider shares the ADT, it gets routed to the right places. I think the rule was very clear in saying, providers don’t have to satisfy every mechanism.”

If a provider is connected to an HIE, then it is likely connected to ambulatory providers, which Williams said should allow the provider to comply with the rules.

“I think that’s really encouraging for those that are participating in those health information exchange networks,” Williams said.

PATIENT DATA EXCHANGE

The ONC interoperability rule primarily focuses on making patient data exchange more fluid for patients, payers, providers, and virtually the entire healthcare network.

To comply with the interoperability rule, communication between HIEs, vendors, and consultants is vital.

“The interoperability rule is one of the agenda items that we are always aware of and talking about,” Randy Thompson, chief health analytics officer at Billings Clinic, said in an interview with EHRIntelligence. “We have some consultants who are making sure that we’re compliant with the interoperability rules. That’s an extremely important area that we want to be compliant with. Our vendor is HITRUST certified, so cyber security is obviously a big concern, as well.”

The ONC rule will require information to be more standardized, integrating terminology standards on the information’s meaning.

“We’re going to focus on far less standard Consolidated-Clinical Document Architecture (CCDA) and more standard United Stated Core Data for Interoperability (USCDI),” Michael Gagnon, executive director for HealtHIE Nevada, explained to EHRIntelligence. “This is not only much more constrained, but it also includes labs that must be coded to LOINC and things like that.”

The rule also requires APIs to open up access to patient data and forces providers to share this access, which ultimately relieves HIEs from this burden.

“One of the burdens we’ve always had in Nevada is that providers needed to pay their EHR vendors a sizeable fee to effectively push their data to somebody else,” Gagnon explained. “They get more value out of the data coming to them and they get less value out of their data going to someone else.”

“Although they want to be good citizens, it’s expensive to be a good citizen, and they’re less incentivized to be one,” Gagnon continued. “The business practices part of the information blocking rule will be just as important as the technology parts of the information blocking role.”

HIEs are in a good position to facilitate patient data exchange because it serves as a business associate, covered under HIPAA, removing the patient privacy risk.

“You come to us [the HIE], and we ensure that the data gets exposed to a particular app, but under conditions where it’s still protected as a business associate,” Gagnon said. “I would create agreements with those organizations to make sure that patient data doesn’t become freely available to everybody. It becomes used for the purpose it was intended for the patient’s needs.”

HIEs contain patient data from diverse sources. An HIE can help aggregate or consolidate data instead of having providers open numerous APIs or connections to vendor applications.

“We’ve struggled with having patient portals because a patient sees multiple providers then has multiple portals,” Gagnon continued. “It just becomes very inconvenient and very just fragmented for them, but the HIE could solve that problem.”

“I’m not saying I’m jumping into the portal market for patients yet, but I’ve always jumped into the market of being the aggregator of the information and pulling it together into a particular singular dataset for all of my participants. That role will just be expanded and enhanced with the new rules.”

With the upcoming compliance dates right around the corner, HIEs, providers, and health IT professionals will be working together to make the transition as smooth as possible.