National healthcare entities are teaming up and speaking out on how to make healthcare better.

EDITOR’S NOTE: The following was discussed by Nachimson during last Tuesday’s Talk Ten Tuesdays live broadcast.

There are two major and complementary rules to advance interoperability being proposed by U.S. Department of Health and Human Services (HHS) subsections, the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare & Medicaid Services (CMS), agencies clearly cooperating to have a consistent approach.   

“Patients should have the ability to move from health plan to health plan, provider to provider, and have both their clinical and administrative information travel with them throughout their journey,” CMS said in a press release on the proposals issued last month.

The ONC has been focusing on providers and electronic health records (EHRs), while CMS is focusing on health plans.

Some basic ONC proposals include:

  1. Deregulatory actions to simplify the EHR certification program
  2. Updates to certification criteria
    1. Adopting the United States Core Data for Interoperability (USCDI) as a standard
    2. Establishing and following a predictable, transparent, and collaborative process to expand the USCDI, including providing stakeholders with the opportunity to comment on the USCDI’s expansion
    3. New e-Rx standards eventually becoming the baseline for certification
    4. Removing the HL7 Quality Reporting Document Architecture (QRDA) standard requirements from the 2015 Edition “CQMs – report” criterion and, in their place, requiring health IT modules to support the CMS QRDA Implementation Guide (IG)
    5. Implementing criteria to enable data export for a single patient and for groups of patients
    6. Standardizing API for patient and population services’ certification criterion to require the use of Health Level 7 (HL7®) Fast Healthcare Interoperability Resources (FHIR®) standards
    7. Implementing the Standards-Version Advancement Process, which would permit health IT developers to voluntarily implement and use a new version of an adopted standard, such as the USCDI, as long as the newer version was approved by the National Coordinator through the Standards-Version Advancement Process for use in certification
    8. Introducing two new privacy and security transparency attestation certification criteria, which would identify whether certified health IT supports encrypting authentication credentials and/or multi-factor authentication
    9. Implementing real-world testing requirements
    10. Introducing information-blocking prohibitions and exceptions

CMS’s proposed rule:

  • Requires Medicare Advantage (MA) organizations, state Medicaid and Children’s Health Insurance Program (CHIP) fee-for-service (FFS) programs, Medicaid managed care plans, CHIP managed care entities, and Qualified Health Plan (QHP) issuers in Federally Facilitated Exchanges (FFEs) to implement, test, and monitor openly published Health Level Seven (HL7®) Fast Healthcare Interoperability Resources (FHIR®)-based application programming interfaces (APIs) to make patient claims and other health information available to patients through third-party applications and developers.
  • Requires MA organizations, Medicaid managed care plans, CHIP managed care entities, and QHP issuers in the FFEs to support electronic exchange of data for transitions of care as patients move between these plan types.
  • Requires MA organizations, state Medicaid and CHIP FFS programs, Medicaid managed care plans, and CHIP managed care entities to make their provider networks available to enrollees and prospective enrollees through API technology.
  • Requires MA organizations (including MA-PD plans), Medicaid managed care plans, CHIP managed care entities, and QHP issuers in the FFEs to participate in trust networks to improve interoperability.
  • Requests for information (RFIs):
    • CMS is looking for ways to facilitate private sector work on a practical and scalable patient-matching strategy. Together with the Office of the National Coordinator for Health Information Technology (ONC), CMS is requesting feedback on how it can leverage its authority to improve patient identification and safety to encourage better coordination of care across different healthcare settings while advancing interoperability.
    • CMS is also exploring how it can promote wide adoption of interoperable health IT systems for use across healthcare settings, such as long-term and post-acute care, behavioral health, and settings serving individuals who are dually eligible for Medicare and Medicaid and/or receiving home and community-based services.

The National Committee on Vital and Health Statistics (NCVHS) in a letter to CMS provided its own recommendations for improving the ICD update process:

  • HHS should use sub-regulatory processes to make version updates to the International Classification for Diseases (ICD) in the same way it handles updates to all the other named HIPAA code set standards.
  • HHS should invest now in a project to evaluate ICD-11 and develop a plan that will enable a smooth and transparent transition from ICD-10 to ICD-11 at the optimal time.
  • HHS should clarify that ICD-10-PCS is completely separate from ICD-10 and will not be updated with the transition of ICD-10 to ICD-11.

Recommendations for improving the HIPAA standards implementation, update, and enforcement process included the following:

  • Remove the regulatory mandate for modifications to adopted standards and move towards industry-driven upgrades.
  • Promote and facilitate voluntary testing and use of new standards or emerging versions of transactions or operating rules.
  • Improve the visibility and impact of the administrative simplification enforcement program.
  • Provide policy-related guidance from HHS regarding administrative standards adoption and enforcement.
  • Re-evaluate the function and purpose of the Designated Standards Maintenance Organizations.

Stanley Nachimson, MS

Stanley Nachimson, MS is principal of Nachimson Advisors, a health IT consulting firm dedicated to finding innovative uses for health information technology and encouraging its adoption. The firm serves a number of clients, including WEDI, EHNAC, the Cooperative Exchange, the Association of American Medical Colleges, and No World Borders. Stanley is focusing on assisting health care providers and plans with their ICD-10 implementation and is the director of the NCHICA-WEDI Timeline Initiative. He serves on the Board of Advisors for QualEDIx Corporation. Stanley served for over 30 years in the US Department of Health and Human Services in a variety of statistical, management, and health technology positions. His last ten years prior to his 2007 retirement were spent in developing HIPAA policy, regulations, and implementation planning and monitoring, beginning CMS’s work on Personal Health Records and serving as the CMS liaison with several industry organizations, including WEDI and HITSP. He brings a wealth of experience and information regarding the use of standards and technology in the health care industry.

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