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March 06, 2013

ONC releases RFI on catalyzing interoperability of EHRs at HIMSS13

Blind men and elephantFarzad Mostashari, National Coordinator for Health IT, announced the release of an ONC RFI at HIMSS today, entitled "Advancing Interoperability and Health Information Exchange," in order to identify ways in which ONC may accelerate interoperability of EMRs without any additional statutory or regulatory authority.

Per the summary of the ONC RFI:

HHS seeks input on a series of potential policy and programmatic changes to accelerate electronic health information exchange across providers, as well as new ideas that would be both effective and feasible to implement. To further accelerate and advance interoperability and health information exchange beyond what is currently being done through ONC programs and the EHR Incentive Program, HHS is considering a number of policy levers using existing authorities and programs.

There has been much discussion of interoperability at HIMSS, and there are probably at least as many perspectives on how to use the term as there are blind men's descriptions of an elephant. This ONC initiative dovetails nicely with private sector activities promoting interoperability (e.g.,CommonWell Health Alliance and Verizon SUMS) though clearly all parties are coming at the issue from different persectives, with differnt motivations, and on different timelines. 

From the presser:

The goals build on the significant progress HHS and its partners have already made on expanding health information technology use. EHR adoption has tripled since 2010, increasing to 44 percent in 2012 and computerized physician order entry has more than doubled (increased 168 percent) since 2008."The 2014 standards for electronic health records create the technical capacity for providers to be able to share information with each other and with the patient," said Dr. Mostashari. "Through the RFI, we are interested in hearing about policies that could provide an even greater business case for such information sharing."

In addition to seeking public input, the RFI also discusses several potential new policies and ideas to accelerate interoperability and exchange of a patient’s health information across care settings so that they can deliver better and more affordable care to their patients.

The full announcement, courtesy of HIBCtv: 

Farzad Mostashari - ONC press conference at #HIMSS13


ONC wants to encourage data sharing over data hoarding, and is asking broadly for input and ideas on how to improve the exchange of electronic health information through changes in payment policy, tweaks to existing programs, focus on provider sectors with low uptake of EHRs, leverage conditions of participation for post-acute care providers, attention to patient access and use of their data in managing their care, and improvements in standards for electronic exchange of information and standards based electronic exchange of lab results.  

The RFI calls more specifically for responses in the following ten categories:

1. What changes in payment policy would have the most impact on the electronic exchange of health information, particularly among those organizations that are market competitors? 

2. Which of the following programs are having the greatest impact on encouraging electronic health information exchange: Hospital readmission payment adjustments, value-based purchasing, bundled payments, ACOs, Medicare Advantage, Medicare and Medicaid EHR Incentive Programs (Meaningful Use), or medical/health homes? Are there any aspects of the design or implementation of these programs that are limiting their potential impact on encouraging care coordination and quality improvement across settings of care and among organizations that are market competitors?

3. To what extent do current CMS payment policies encourage or impede electronic information exchange across health care provider organizations, particularly those that may be market competitors? Furthermore, what CMS and ONC programs and policies would specifically address the cultural and economic disincentives for HIE that result in “data lock-in” or restricting consumer and provider choice in services and providers? Are there specific ways in which providers and vendors could be encouraged to send, receive, and integrate health information from other treating providers outside of their practice or system?

4. What CMS and ONC policies and programs would most impact post acute, long term care providers (institutional and HCBS) and behavioral health providers’ (for example, mental health and substance use disorders) exchange of health information, including electronic HIE, with other treating providers? How should these programs and policies be developed and/or implemented to maximize the impact on care coordination and quality improvement?

5. How could CMS and states use existing authorities to better support electronic and interoperable HIE among Medicare and Medicaid providers, including post acute, long-term care, and behavioral health providers?

6. How can CMS leverage regulatory requirements for acceptable quality in the operation of health care entities, such as conditions of participation for hospitals or requirements for SNFs, NFs, and home health to support and accelerate electronic, interoperable health information exchange? How could requirements for acceptable quality that involve health information exchange be phased in over time? How might compliance with any such regulatory requirements be best assessed and enforced, especially since specialized HIT knowledge may be required to make such assessments?

7. How could the EHR Incentives Program advance provider directories that would support exchange of health information between Eligible Professionals participating in the program. For example, could the attestation process capture provider identifiers that could be accessed to enable exchange among participating EPs?

8. How can the new authorities under the Affordable Care Act for CMS test, evaluate, and scale innovative payment and service delivery models best accelerate standards-based electronic HIE across treating providers?

9. What CMS and ONC policies and programs would most impact patient access and use of their electronic health information in the management of their care and health?
How should CMS and ONC develop, refine and/or implement policies and program to maximize beneficiary access to their health information and engagement in their care?

10. What specific HHS policy changes would significantly increase standards based electronic exchange of laboratory results?

I would encourage interested stakeholders to participate in this Government 2.0 example of crowdsourcing sub-regulatory guidance over the next six weeks (the comment period closed April 21).

David Harlow
The Harlow Group LLC
Health Care Law and Consulting 


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The ideas are great....the main project management was flawed and too ambitious, with a very compressed time frame. This has not allowed vendors, providers & consultants to properly evaluate and implement better software. Meaningful use should have waited until EMRs were better established. ONC and HHS need to develop more patience, and do away with the penalties for non adoption for at least five more years.

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