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.
More is yet to come. In recent days, the CMS announced a “Price Transparency” Final Rule, aimed at enabling consumers to be better informed and have ready access to price information for their healthcare. While this rule did not specify FHIR as the data standard, the picture is clear that we are steadily opening the black box of healthcare information and making it available to consumers and other stakeholders in the ecosystem.
Not all will succeed in navigating this change. Not all will be able to maintain the investment and pace of innovation required. But this represents a necessary and largely self-imposed evolution of healthcare that is long overdue.
A new healthcare ecosystem
Combined, these regulations and voluntary efforts represent tectonic movements in healthcare. They have delivered us into a healthcare ecosystem driven by FHIR APIs, an ecosystem that is rapidly undergoing the digitalization and consumerization that we have seen in nearly all other aspects of our lives, from banking to travel to leisure.
Healthcare data will more easily flow across traditional siloes, from payer to consumer to provider to biosciences. New entrants to the healthcare marketplace such as AWS, Apple and Microsoft will and have emerged. Consumers will have access to and control over the exchange of their records, if they care to, and otherwise, will have a much better chance of just having their data in the hands of their caregivers when it is needed. Payers and providers will more easily cooperate and collaborate on behalf of patients. Some of the most dreadful workflows in healthcare such as prior authorization will be automated. Healthcare will be cheaper, easier and a better experience for consumers, providers, payers and all other participants.
With FHIR and market innovation, coupled with policy initiatives to accelerate them, we are seeing the long overdue emergence of an interconnected healthcare ecosystem. This evolution is taking place rapidly, and the industry will now face the challenge of bridging legacy systems, where the data resides today, into this community of FHIR-enabled data liquidity.