With the publication of the Interoperability and Patient Access Final Rule, the Centers for Medicare and Medicaid Services (CMS) set into motion a journey toward a connected healthcare system where patients, providers and payers can easily exchange information to improve outcomes. To reach this goal, CMS established policies designed to advance interoperability and access to health information for all stakeholders.
As patient health data begins to flow through and across the healthcare system using APIs, CMS has specified Health Level 7 (HL7) Fast Healthcare Interoperability Resources (FHIR) Release 4.0.1. as the data exchange standard. FHIR enables flexibility and reduces friction as information is transmitted between systems.
While complying with the FHIR standard is essential, it is important for states and healthcare organizations to regard the rule as not just a requirement they must meet, but rather a catalyst for truly interoperable, patient-centered healthcare. And while CMS has exercised enforcement discretion with regard to certain provisions and deadlines, organizations should not interpret that as a green light to delay implementation.
Really, the rule is not just about changing technology; it’s also about changing our perspectives. CMS wants to break down barriers to allow for the free and secure flow of data, which will result in reduced costs and improved outcomes — the very same goals of states and payers. But we’re not going to get there if all stakeholders aren’t fully committed to changing course.
Making Data Accessible
In a siloed healthcare system, when an individual visits their dentist, their general practitioner or a specialist, providers run their own tests and record their own observations. Then, much of that data stays locked away in their systems, leaving patients unable to take it with them wherever they go. Not only are patients unable to access the different pieces of their health or clinical data, they’re also unable to give these pieces to someone who can stitch them together into a cohesive whole.
The intention of the final rule is to address these issues by increasing and advancing healthcare data exchange. If the goal is to liberate data, making systems interoperable is the obvious start. But it’s hardly the end. At some point, organizations are going to have to exchange that data — perhaps to the member or perhaps to another organization. Now is the time to prioritize data governance, to ensure entities are able to effectively exchange clean and accurate data when the time comes. Otherwise, they’re at risk of exposing their data quality issues.
Extracting More Value
If compliance is Phase 1, data governance should follow quickly as Phase 2. Organizations should look closely at the quality of data they ship out, performing regular quality checks and determining if the data is complete.
There is no advantage to waiting. After all, once the data is clean, that’s when it really starts to provide value. The type of value that leads to greater efficiency and better decision-making.
Getting a Head Start on Innovation
States and payers are currently racing to comply with the interoperability ruling. Nobody wants to be fined or miss out on federal funding. Given the situation, it’s tempting for organizations to resolve to comply to the letter of the law — to use the proper framework and required APIs — and be done with it. But to view the rule as just a technology implementation is a short-sighted interpretation.
There’s the short-term goal of compliance and then there’s the ultimate goal of a truly connected healthcare system. What happens in between is innovation.
The best course of action, then, is to start addressing issues now and evolve with the market and technology as it is being implemented.
Taking an Incremental Approach
One of CMS’ stated goals for the final rule is to “improve interoperability and unleash innovation.” CMS has made the rules clear for improving interoperability, but those for “unleashing innovation” are ambiguous. And therein lies the excitement and the opportunity.
Interoperability will allow for systems that can take in data from different sources. We’ll be able to use artificial intelligence. We'll be able to run analytics to provide end users with better outcomes.
Once clean data flows between entities, organizations can start layering in value adds like machine learning and predictive analytics to extract greater value from the data. If organizations wait to start enhancing their systems, or delay their focus on data governance, they’ll have a steeper learning curve when it comes to innovation.
At that point, they will also face a bigger price tag. Organizations should start this value-added work now, as it's cheaper and easier to do it incrementally, rather than relying on a big-bang implementation.
Winning the Race
With deadlines looming, the realities of compliance are drawing closer. But so are the opportunities for innovation.
In the end, it’s not really a race to compliance. It’s a race to value.