What a crazy week
Last week was another HL7 FHIR Connectathon event. If you have not taken part in a Connectathon event, it is an opportunity to test out the HL7 Fast Healthcare Interoperability Resource Specification. I was there leading the Payer Data Exchange track for two days.
We spent our time with 40–50 people from across the healthcare spectrum looking at Payer-to-Payer exchange. It was a productive two days. We looked at a number of aspects of the HL7 Da Vinci Payer Data Exchange Implementation Guide. We reviewed the current version and some planned changes. A big part of the testing was to look at how Payers that are impacted by the CMS Interoperability and Patient Access Rule can support the requirement for Payer to Payer exchange. The Regulations required payers to implement support for Payer to Payer exchange by January 1, 2022. That is just a few short months away.
A lot of progress was made in two days to address questions and concerns. There emerged two methods to solve the exchange challenge.
- Member-mediated exchange using the Patient Access API that payers had to implement by July 1, 2021.
- Using a Business-to-Business exchange between payers.
We spent time looking at how the business-to-business exchange would happen and the technical capabilities required to make this possible.
On the whole it was a very productive two days.
Then Thursday happened…
CMS announced that they will not be enforcing the January 1, 2022 deadline for Payer-to-Payer exchange. However, they left the threat of future regulation hanging out there. We saw the shape that future regulation could take when the proposed Burden Reduction rule was published in December 2020 before being withdrawn in January 2021.
That proposed rule effectively removed the optionality in the use of FHIR for Payer-to-Payer exchange. I think we see where the future is going. We expect the majority of data to flow via business-to-business exchanges between payers and between payers and providers.
Effectively the delay in enforcement gives the industry time to double down on how payer-to-payer exchange will be accomplished. This is a two-fold thrust. Firstly, we have to resolve the technical mechanisms needed to accomplish exchange. These mechanisms need to be able to operate at scale. The technologies are available and can be implemented.
The bigger challenge is on the policy side. A trust framework is needed. A framework that enables payers to agree to share information. A framework that enables one payer to collect a consent from a member and pass it to a previous payer and have the payer accept the documentation. This is the bigger challenge. However, I believe it is a challenge that can be overcome. Hopefully quickly.
As all of this has been happening I am proud to say that my company, Onyx Techology - onyxhealth.io has been busy working to help payers make sense of all these changes. This week we launched an information site, payertopayer.com. We plan to post information to help payers as the regulations and the FHIR specifications evolve. We would love your input. Send us questions and we can post our best insights to help you plan effective strategies to implement healthcare interoperability.
It is going to be a fascination journey. Come join us.
