Complete our eight-question readiness assessment and see your score.
Health system executives must approach interoperability not simply to comply with the rules but as a strategic advantage. This means taking immediate action to build a holistic interoperability roadmap. Why? The interoperability rules impact strategic decisions health systems are making today, such as those noted below.
Digital strategy should incorporate interoperability and patient data management strategies, including patient access to records through personal health records (PHR) and a digital front door. In fact, the digital front door will be hampered without strategic interoperability. Patient and consumer engagement are increasingly mediated via digital tools and platforms, which are in turn dependent upon the accuracy and quality of data and effective mechanisms for data exchange. As such, a health system’s interoperability plan must consider how requests for data received via digital platforms will be managed from a data-flow perspective.
Consumer Demand and Competitive Advantage
Consumers are clamoring for their data and greater access, and demand for records during the pandemic has only grown, showing the immediate need for interoperability. The following findings from a July Black Book Report showed changing consumer perceptions of interoperability and the impact on the providers to whom they turn for their care. As patients expect and increasingly ask providers to share data, they will be dissatisfied when organizations are not ready. Ultimately, patients may redirect their care to organizations that promote interoperability and data access.
Consumer Demand for Interoperability
Health systems have already been altering workflows to address the dual system of care required for COVID-19 and non-COVID-19 patients, and the interoperability rules have wide-sweeping operational implications, requiring an enterprise effort. Two examples show the impact:
Regardless of the minimal compliance path or strategic path to interoperability, operational and workflow changes are both required.
EHR technology and interoperability strategy may play a factor in evaluating potential partnerships or ensuring existing partnerships are fruitful. In a Center for Connected Medicine survey from August 2019, 57 percent of health systems felt they were successful sharing data with patients, but less felt successful sharing data with other health systems (37 percent) and other partners (35 percent). Holistically caring for the patient requires seamless interoperability between care partners. Partners who have the same approach to interoperability, and even the same systems, may be a best fit for growth strategies.
Penalties have been set for developers at up to $1 million per violation for information blocking. These penalties could be just as high for provider organizations once they are set. Providers that promote apps or an extension of their EHRs may be considered a developer, and providers with a health plan also must address the payor components. Moreover, delays in enforcement are short. Preliminary compliance dates begin November 2, and delays already announced for admission, discharge and transfer (ADT) notifications and Certified EHR Technology (CEHRT) pushed out compliance only three to six months. The deadlines may not be extended again. Likewise, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) is slated to drive enforcement and publish its rules for enforcement of information blocking in October, with no plans to delay.
The ban on federal funding for a nationwide patient identifier was repealed August 4, allowing for a national identifier to facilitate patient data exchange. More than 99 percent of providers have adopted EHRs, paving the way for electronic data exchange. HHS and ONC are providing monetary boosts to health information exchanges (HIE) for improved structure and innovation. ONC is discussing setting up a Trusted Exchange Framework (TEFCA), which will provide a network for national exchange of data. All these factors will drive continued growth of interoperable exchange.
The key is in aligning this effort with health systems’ current strategic agendas.
The key is in not adding one more thing to health system executives’ already-full plates; it is in aligning this effort with health systems’ current strategic agendas. We recommend taking immediate actions to prepare for compliance with the rules — aligning interoperability efforts with the current strategic agenda.
Start now by building an interoperability plan that will accelerate the health system’s strategic agenda, while meeting fall compliance deadlines.
Align with operational changes. In tandem with legal and operations, assess current policy, data flow, and interoperability and processes, identifying gaps. Focus on high-impact use cases — like clinical notes sharing — for data requests, and create an interoperability plan for all five provider requirements.
Sync with digital and patient engagement strategies. Determine how to facilitate sharing and patient points of contact with other digital and consumer engagement efforts like the digital front door.
Initiate provider outreach. Individual providers will have to make the NPPES database updates themselves, and their notes now will be shared with patients. Begin education and evaluate bulk options, obtaining DirectTrust address early on to streamline the process and considering the role of an enterprise master provider database with up-to-date information.
Build a plan for patient and vendor outreach. Communication plans should be developed to ensure vendors are ready and patients understand how third parties may use their data.
Pausing to assess the health system’s readiness for interoperability compliance can be a helpful step at this stage. Health system executives need to know where they stand in relation to the rapidly approaching November 2 compliance deadline to understand where it is most important to focus attention. We’ve prepared a simple assessment to help executives gauge their level of preparation. Complete this assessment to see how you score for readiness.
Our third article in this series discusses our steps health systems need to address for interoperability compliance and beyond.
Contact us for a review of the rules and implications for your organization.
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