Interoperability and Patient Access
The CMS final rule: what it is, who gets impacted, and how to plan for the future
This paper contains a detailed summary of the Interoperability and Patient Access Final Rule and the 21st Century Cures Act, along with technical and implementation standards. The paper explains how the ruling impacts healthcare enterprises and technology firms and provides a planning guide for implementation of the requirements.
Historically, nuances of a patient’s healthcare journey have been locked in multiple silos within electronic health records and payer systems, both being the custodians of patient data. A patient visiting various providers has his or her health record stored into individual EMRs of the providers as well as in the claims and encounter data of payer systems. With the final ruling, the patient can now get medical records on their smartphones using any application of choice. All their health information from labs, prescription data, past medical history, and data from continuous monitoring devices like Fitbit can now be available on the screens of their phones. Undoubtedly, this will create a high level of empowered and engaged patients. The success of healthcare facilities in the post-COVID world, therefore, depends on the interoperability of healthcare information and making it available to all stakeholders across the healthcare continuum, with the patient being at the center of all data exchange transactions. In the end, it is all beneficial for the patients who are more engaged and a partner in their healthcare decisions.
The MyHealthEData initiative was announced at the HIMSS 2018 conference, following which the Office of the National Coordinator (ONC) and CMS released the Interoperability and Patient Access Final Regulation on May 1, 2020. The regulation implements the key provisions of the 21st Century Cures Act and empowers patients with control of their own healthcare records. The deadline to implement the final rule is early- to mid-2021. There is a list of infrastructure and technology updates that payers, providers, and Health IT vendors need to implement to comply with the ruling.
For payers, the first milestone is in January 2021, which gives them less than six months to put their action plan together. The CMS has announced a temporary policy of relaxed enforcement due to the COVID-19 crisis which may extend to July 2021. Nevertheless, the payers must have the technical infrastructure in place to share patient claims, encounters, and clinical data stored in their databases in a format that can be easily consumed by third-party developers and applications. The data must be made available in FHIR compliant APIs (Application Programming Interfaces), and USCDI prescribed vocabulary standards along with a robust patient authentication and identification standard.
For providers, including the healthcare systems, the ruling is relatively more straightforward with most of the technical implementation burden being on the EMR systems, payer systems, and other technology vendors. Provider organizations only need to attest to not blocking information and providing digital contact information to NPPES online records.
The technology vendors must conform to the vocabulary standards and attest to the technical and implementation standards. In this paper, using Damo’s ICEATM framework, we have highlighted the applicable impact of the ruling on each of the four types of technology providers.
This paper explains how the CMS Interoperability Rule impacts healthcare enterprises and technology firms, and provides a roadmap to plan for the future.
- Executive Summary
- Introduction
- The Rule
- Technical Standards
- Implementation Standards
- Implementation Strategies for Technology Firms: ICEATM Framework
- Implementation Strategies for Healthcare Enterprises
- Conclusion
- References
