The Cures Act Final Rule’s technical requirements call for radical changes in electronic Patient Health Information Exchange (ePHI). Care providers must adhere to the CoP requirements for patient event notifications (ADT Notifications) and the real-time exchange of ePHI through APIs in 2021. In addition, payer organizations must facilitate the electronic exchange of ePHI between other payers and healthcare providers through a patient access API. They must also provide patients with a list of care providers to choose from for medical services by compiling the provider directory API.
These technical requirements are driven by the CMS’s pursuit of seamless semantic interoperability of healthcare systems and the ONC’s specifications for 2015 requirements of Certified Electronic Health Record Technology. While they affect care providers and payers, health IT developers (HIT vendors) are the catalyst to facilitate the patient centric care.
HIT vendors must swing into action to adhere to their regulatory requirements and enable providers and payers to do so in the process. The stifling competition that is already upon them only lifts the normal for innovation and reflex time. HIT software development requires specialized skill sets and exhaustive processes that escalate costs. In a bid to rein in these costs and adhere to regulatory requirements, HIT developers tend to dilute their competitive edge.
On Mar. 9, 2020, the U.S. Department of Health and Human Services (HHS) finalized “two transformative rules that will give patients unprecedented safe, secure access to their health data.” Issued by the Office of the National Coordinator for Health Information Technology (ONC) and Centers for Medicare & Medicaid Services (CMS), the Final Rules implement interoperability and patient access provisions of the 21st Century Cures Act and support President Trump’s MyHealthEData initiative.
In its release announcing the Final Rules, HHS noted that together “these final rules mark the most extensive healthcare data sharing policies the federal government has implemented, requiring both public and private entities to share health information between patients and other parties while keeping that information private and secure, a top priority for the Administration.”
Cures Act Final Rule implements the interoperability provisions of the 21st Century Cures Act, passed by Congress in 2016 to promote patient control over their own health information while still allowing providers to choose the IT tools that let them provide the best care for patients without excessive costs or technical barriers.
Specific to patient matching, the Cures Act Final Rule adopts as standard the first version of the United States Core Data for Interoperability (USCDI v1), making its use a requirement as part of the new application programming interface (API) certification criterion.
According to ONC, adoption of the USCDI standard “supports improved patient matching through the exchange of USCDI and its patient demographic data elements.” The Final Rule integrates additional data elements to the patient demographics data class to improve patient matching:
Current Address
Previous Address
Phone Number
Phone Number Type
Email Address
Karen Proffitt
“Any improvement strategy must include data standardization and promote a more consistent, comprehensive collection of patient data at all entry points,” said Karen Proffitt, MHIIM, RHIA, CHP, vice president of industry relations and chief privacy officer, Just Associates. “The Final Rule requirement for adoption of USCDI standards, including historical data and more relevant data elements such as phone number and email address, represents a significant step toward improving interoperability and minimizing MPI errors overall.”
Interoperability and Patient Access Final Rule gives patients access to their health information when they most need it, in a way they can best use it. It is focused on driving interoperability and patient access to health information by leveraging CMS’s regulatory authority over Medicare Advantage, Medicaid, CHIP, QHP issuers and FFEs to free patient data.
Specific to patient matching, which was one of two requests for information included within the proposed rule, CMS noted that while “accurate patient identity management is critical to successfully delivering the right care to the correct patients,” patient matching challenges are beyond the scope of the current rule. However, the comments provided will be taken into consideration for potential future rulemaking.
“As a healthcare community, we must recognize the critical role improved data capture and MPI data quality play in enabling patients to have more comprehensive access to their health information by ensuring complete and accurate data is available for viewing or transmitting,” said Proffitt.
She adds, “any process to incorporate patient verification of data along the way could be very beneficial.”
