Mandated Interoperability: Strategic Differentiator or Compliance Project?
Interoperability within health care has been a top concern across the industry for more than a decade. The HITECH ACT drove an expectation that interoperability would be a natural byproduct of broad EHR adoption, but this turned out not to be the case. Digitizing health data did not automatically make it liquid. The missing key ingredient is a business motivation to share data outside of the silo in which it was generated.
In the post-HITECH era, several different strategies for internal interoperability have become commonplace, but two stand out at opposite ends of the spectrum. At one end, we have organizations that prefer to adopt a single EHR system for as many departments, business functions, and clinical workflows as possible. When all the data is generated within a single system, there is less need for interoperability. At the opposite extreme, we see organizations that prefer a best-of-breed approach. They implement the best system for each purpose and integrate them in order to share data between and among their best-of-breed systems. This often means implementing an organization-wide interoperability strategy using a best-of-breed integration tool.
The organization’s internal interoperability strategy often has a bearing on the organization’s external or cross-organizational interoperability strategy. Providers that adopt an EHR-centric internal integration strategy often find that the easiest way to communicate externally is through the EHR’s proprietary exchange network. Providers that have taken a best-of-breed approach are more likely to use vendor-neutral exchange networks, such as Carequality and CommonWell. Either way, it seems that data is not presently flowing as freely as providers, patients, and regulators expected.
To address the interoperability gap, Congress passed the 21st Century Cures Act at the end of 2016. The law contains a number of health care-related provisions, including a definition of and prohibition against information blocking. More than two years later, CMS and ONC published proposed rules to clarify what this would mean in practical terms, and we are still waiting to see what the final policies will look like. This signals the end of HITECH’s incentives for health care technology and the start of the penalty phase for players that are not using the technology as intended.
We expect the result will be improved cross-organizational interoperability, which will help enable new, outcomes-based health care reimbursement plans. Another benefit will be to patients, who will have improved access to their electronic health information. In either case, providers will be compelled to facilitate these data flows outside their organization. For some providers, this will represent an onerous compliance project. Others will take the opportunity to go beyond the mandate and turn external interoperability into a strategic advantage.
Organizations that excel at cross-organizational and patient-oriented interoperability will not only avoid penalties due to information blocking violations; they’ll also position themselves as effective players in the new, value-based reimbursement plans that public and private payers see as the way health care will be paid for in the future. Getting as good at external interoperability as most providers already are at internal interoperability will be a foundational capability to participating in these new reimbursement systems.
There remains some uncertainty around the margins of the proposed rules; certain details, like the exact version of FHIR APIs that will be expected, may change before they are finalized. However, the current drafts of the proposed rules will not change at a fundamental level, and organizations that want to be ready to treat the new regulations as a strategic opportunity should take the following practical steps to prepare:
- Gain a better understanding of healthcare legislation like: HIPAA, 21st Century Cures, and ONC’s NPRM. This will be important given different organizations will have different priorities and obligations.
- Identify alternative locations within the organization where patient information is stored. Doing so will enable a clear understanding of the capabilities required to transfer and share that data effectively.
- Have a strategy. Thankfully most networks use the same core standards (like: HL7 v2, FHIR, CCD, C-CDA, and IHE profiles) so the approach to interoperability will be relatively similar across the board.