By Jerry Rankin, strategy director of healthcare interoperability, Infor.
The unrelenting if unpredictable movement of continental plates builds new mountain ranges and reshapes continents, but for the most part, we do not notice their progress. Such a shift has come to healthcare.
This spring two US Federal agencies, ONC and CMS, announced complimentary Final Rules, signaling tectonic movement in healthcare interoperability. These rules are very consequential for the industry, but while no one can claim that they went unnoticed, the industry has been understandably instead fixated on responding to the COVID-19 pandemic. In response, the federal agencies involved have pushed the implementation timelines back by roughly six months.
The Final Rules
On May 1, 2020, the ONC published a Final Rule implementing provisions of the 2016 21st Century Cures Act. Known in the industry as the “Information Blocking and Health IT Certification” Final Rule, the Provider and EHR focused rule requires developers of Certified Health Information Technology (e.g. EHRs) to make standard APIs available for the delivery of individual and population records, as well as defines the data set and transaction standards of the APIs to be United States Core Data Set for interoperability (USCDI) and FHIR, respectively.
In a parallel action, the CMS issued a ruling implementing provisions of the Cures Act, known as the “Interoperability and Patient Access Rule,” leveraging “Conditions of Participation” in Federal Health programs. The finalized rule requires payers to provide a Patient Access API which gives patients access to certain health data including personal data.
These rules represent an important federal nudge to the industry to move in the next few years to implement and adopt standard, digital friendly APIs for the exchange of key patient information, eliminate policies and practices of health IT vendors, providers and other data holders that constrain the free flow of healthcare data, and, importantly, bring payers and consumers into the interoperability discussion, enabling data to flow across the healthcare ecosystem.
These rules are just the tip of the iceberg, though. The industry has been hard at work for years developing the FHIR API standard, and there are abundant examples of voluntary industry led collaborations working to improve and streamline healthcare leveraging FHIR. For example, the HL7 Da Vinci Project sponsors collaboration among payers, providers and HIT vendors working to define standards-based implementations to improve some of the more costly workflows in the industry. In addition to adoption by traditional HIT vendors, even IT “gorillas” are adopting FHIR. We recently saw this with the launch of Microsoft Cloud for Healthcare which extensively leverages FHIR APIs and data standards.
What to expect for payers and providers?
Payers and providers and their health IT vendors have a great deal of work to do on a tight timeline to meet the requirements put in place and to simply keep up with the pace of change in the industry. Given the massive investment in and footprint of legacy systems, there is a vast amount of work to do to connect systems and data to the emerging FHIR API ecosystem.