HHS Ruling Disrupts Healthcare: Let the Data Sharing Begin!
Interoperability and the right to share patient and member data between healthcare organizations—and between healthcare organizations and third-party application developers—is long overdue and desperately needed. Much as the Health Information Technology for Economic and Clinical Health (HITECH) Act—enacted as part of the American Recovery and Reinvestment Act of 2009—and meaningful use broke through decades of industry inertia to force the adoption of electronic health records (EHRs), the new Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinatorfor Health Information Technology (ONC) interoperability rules will move the entire industry to an interoperable future.
Meaningful use was not perfect, and challenges remain in term of usability and other aspects of EHRs, but the current state is immeasurably superior to where we would be if the industry had largely stuck with paper charts. Nor are the interoperability and data locking rules perfect; however, they will force a huge step forward that will contribute to better care for individuals, better health for populations, and lower per capita healthcare costs.
Breaching the Barriers to Sharing Healthcare Data
I’ve spent most of my career in healthcare involved in interoperability in some way: from the community health information networks (CHINs) in the ’90s, where barriers were abundant, spanning technology, politics, and funding; to the proliferation of the health information exchanges (HIEs) of the past two decades, which achieved at best modest success and were impeded by a lack of sustainable financial models, politics, and EHR vendor intransigence; to the renewed emphasis on interoperability of the last month driven by the new CMS and ONC regulations.
Where does this leave us? From my perspective, CMS and ONC have effectively breached the barriers to sharing healthcare data with their new interoperability and data blocking rules. They have established what data must be shared, how that data must be shared, and perhaps most importantly, put the patient in control of their own data, enabling them to decide who it gets shared with.
The data blocking rule alone holds the potential to be a game-changer for the healthcare
industry. As the global leader in enterprise cloud data management with a significant commitment to the healthcare market, Informatica has keen insight and has experienced first-hand the detrimental effects of vendor data blocking and the limitations it has imposed on the ability of health systems to access and use patient data.
Health and Human Services (HHS) has now prohibited by rule anti-competitive behaviors that effectively locked data within vendor systems. This is a huge step forward in liberating data from these vendor applications; it makes the data much more broadly accessible for use by the vendor’s own customers and for consumption by third-party applications that will be the engines of innovation.
A Roadmap to a Radically Interoperable Healthcare Future
So, let me conclude with a call to action to the entire healthcare industry: do not view the CMS and ONC interoperability rules as a compliance mandate; rather, they are a roadmap to a radically interoperable healthcare future.
There are no technology limitations to sharing member and patient data in the manner mandated by CMS and ONC—the technology solutions are widely available and the data management architectures are straightforward. I am not suggesting it will be easy, but I do believe it is the right thing to do and desperately needed in these challenging times.
The need to share data and create a comprehensive 360-degree view of all the data about a member and a patient is the foundation of predictive modeling. It enables us to foresee who is most vulnerable to COVID-19, who may become ill, who may need ICU care, how the virus spreads, and countless other insights.
Provider networks are being wildly disrupted with out-of-state providers, individuals coming out of retirement, and many other forms of nontraditional contributors caring for patients in this time of urgent need. Exposing provider network data to third-party application vendors—so they can develop new solutions to help members and patients navigate and find providers—has never been more needed. Let’s use the CMS and ONC rules as an opportunity to accelerate data sharing for the common good, rather than something to be delayed.
In my next blog, I will discuss some architectural approaches to data sharing that are technically practical and include robust consent management to ensure members and patients have control over the sharing of their data and the transparency to see what data is being shared with whom. In this way, payers, providers, and the members and patients themselves can be comfortable that their data is protected and shared only when appropriate, via approved channels.
Want to hear more? Listen to Denny Brennan, Executive Director at Massachusetts Health Data Consortium and I discuss the HHS interoperability rules, what it means, whether it’s the right policy for the industry and what it portends - https://www.mahealthdata.org/page-1861607