- Over the past few years, health data interoperability has become a top priority for the Office of National Coordinator. Buffeted by complaints from Congress and industry stakeholders about the deeply entrenched data siloes and proprietary architectures that prevent providers from meeting health information exchange and care coordination objectives, the ONC has released a series of documents outlining its plans to bring greater interoperability into the EHR Incentive Programs and beyond.
Yesterday, ONC officials announced a finalized version of its overarching interoperability strategy, called “Connecting Health and Care for the Nation: Shared Nationwide Interoperability Roadmap.”
In conjunction with the 2015 Edition Health IT Certification Criteria final rule, the Roadmap hopes to leverage more stringent certification requirements to ensure a higher degree of interoperability for providers investing in new EHR products to meet future meaningful use criteria, said National Coordinator for Health IT Karen DeSalvo in a blog post on HealthITBuzz.
While the industry responded hesitantly to the draft of the framework, which was released in January, DeSalvo and Erica Galvez, Interoperability and Exchange Portfolio Manager at the ONC, hope that the Roadmap will adequately address the urgent need for health information exchange across an industry rapidly shifting to accountable, coordinated care.
“[The Roadmap] lays out the milestones, calls to action and commitments that public and private stakeholders should focus on achieving, particularly in the near-term. In January 2015, the Office of the National Coordinator for Health IT (ONC) requested public comment on the draft version of the Roadmap,” DeSalvo and Galvez explain.
“We received over 250 comments which were used to shape the Roadmap released today. Additionally, the Roadmap was informed by the input from 25 federal partners, 90 individuals from 38 states from across the nation and the ONC Federal Advisory Committees (FACAs), whose membership includes 167 representatives from over 140 private and public organizations.”
After reviewing stakeholder feedback, the ONC has published an industry-wide plan to achieve near-term wins while keeping the quickly evolving nature of healthcare technology in mind as providers bulk up their interoperability capabilities in the future.
Guiding principles for nationwide interoperability
In the previously published “10 Year Vision to Achieve an Interoperable Health IT Infrastructure,” the ONC stressed a set of ten guiding principles for health data exchange. The principles, updated in light of suggestions and responses from the industry, stress the importance of working with existing circumstances while striving for simpler, more streamlined goals.
The principles suggest that the healthcare industry should build upon existing health IT infrastructure while recognizing that “one size does not fit all” when it comes to interoperability and data exchange. Providers have made significant investments in EHRs, data analytics, and population health management tools, some of which may not be optimally designed for data interoperability.
Instead of requiring providers to scrap their existing systems, which would be financially untenable for the majority of healthcare organizations, interoperability efforts should include options for flexibility and tailored development that meets baseline requirements without burdening providers.
Providers and other stakeholders should also leverage the power of individuals to embrace self-management for chronic diseases and other health issues. The rise of wearables, mHealth, and the Internet of Things will provide significant opportunities for patient engagement and encourage patients to access, review, and augment their personal health data.
Similarly, healthcare organizations can enact change by using their purchasing power to demand simpler, more streamlined, more intuitive health IT tools and EHR interfaces that promote health data interoperability while maintaining patient safety and provider productivity. Providers should invest in modular tools, which may be more resilient to change than rigid, monolithic systems, and keep in mind the need to scale these flexible solutions to meet the needs of the industry as a whole.
In addition to focusing on the privacy and security of patient data as it moves more frequently across the healthcare continuum, providers must ensure that they are producing value when engaging in interoperability strategies. Patient-centered care must remain a top priority, and the patient experience should be considered as providers invest in health IT tools at their own individual pace.
Four critical actions for short-term wins
To better integrate these principles in the healthcare delivery system, the ONC has targeted four critical actions for short-term success.
Establish a coordinated governance framework and process for system-wide health data interoperability
“The proliferation of health information sharing arrangements has created many different processes and rules for interoperability among subcomponents of the health IT ecosystem,” the Roadmap says. “To enable nationwide interoperability for a common clinical data set, there must be agreement on the policies, operations and technical standards that will enable trust and allow information to be shared appropriately across the ecosystem.”
The ONC will tackle that problem by ensuring the establishment of a governance framework that contains overarching “rules of the road” for health IT interoperability, a public/private process for addressing implementation or operational issues, and a mechanism for recognizing organizations and holding stakeholders accountable for compliance with interoperability rules.
Improve technical standards and implementation guidance for the Common Clinical Data Set
The Common Clinical Data Set (CCDS) is the Stage 3 MU-minded update to the Common MU Data Set previously defined by the ONC in the 2014 Edition CEHRT criteria, and holds major potential for big data analytics and population health management. The industry must work on improving the underlying data standards that will support and enable collection of CCDS elements while allowing the data to be shared and used in clinical documents.
Despite the limitations of the C-CDA and other relatively static HIE protocols, “it is unlikely that the care delivery system will stop using clinical documents for specific purposes in the near term (or perhaps the long term) and mobile technologies and applications will need to simultaneously access specific data elements to support individuals in the near term,” the Roadmap notes.
Healthcare stakeholders should advance the use of data standards that enable sharing of a common clinical data set “in a manner that makes sharing and receiving electronic health information easy for users.”
Promote incentives for sharing health information and using common data standards
As meaningful use incentive dollars dry up and providers are faced with non-participation penalties instead, the healthcare industry must adopt new methods of encouraging providers to invest in interoperable technologies and health information exchange.
“Experience has demonstrated that current fee-for-service payment policies often deter the exchange of electronic health information, even when it is technically feasible,” ONC states. “To ensure that individuals and providers can send, receive, find and use a common clinical data set, federal, state and commercial payers will need to evolve policy and funding levers.”
Accountable care and value-based reimbursement arrangements, offered by both public and private payers, have quickly become a major driver for providers to embrace data-driven population health management programs and improved communication across the care continuum. The ONC hopes to continue this trend by designing a supportive business and regulatory environment with an eye towards data exchange.
Clarify privacy and security requirements to ensure compliance with HIPAA
At the core of all these efforts are patient privacy and data security. “While health IT developers can design health IT tools that support electronic health information sharing, it is important to remember that the majority of clinical information resides within and is stewarded by health care organizations,” the Roadmap reminds readers.
Widespread confusion over certain provisions in the HIPAA Privacy and Security rules, especially in relation to business associate (BA) agreements, has led to misinterpretation of limitations on sharing patient data. These rules must be clarified and providers must be educated about what health information exchange activities HIPAA does and does not prohibit.
“With improved understanding, covered entities and BAs will be able to exchange appropriately with greater confidence,” ONC says. “This includes ensuring that individuals can exercise their legal right under HIPAA rules to access their own health information.”
The ONC has developed an estimated timeframe for many of these milestones, stretching out to the year 2020.
Following a recent report that stated 40 percent of hospitals engage in some level of health information exchange, DeSalvo and Galvez urge the industry to “continue, in the near-term, to focus on ensuring that systems can send, receive, find and use the priority data domains to ensure electronic health information is securely available to improve health care quality and outcomes.”
“Achieving these four exchange activities is part of the foundation that is necessary for the nation to continue making progress and push information sharing beyond electronic health records (EHRs) to include technologies that empower the American public by putting them at the center of their own care.”
Crafting the learning health system
The ultimate goal of the Roadmap and the activities contained within is to develop what’s known as the “learning health system,” which encourages continuous improvement in the areas of data exchange, information governance, interoperability, EHR usability, patient safety, provider satisfaction, and population health management.
The Roadmap is intended to be a “living document” that guides stakeholders across the care continuum towards collaborative efforts to achieve the goals of the learning health system, DeSalvo and Galvez write. Future versions of the roadmap will continue to incorporate feedback from the industry as it is periodically updated to reflect the progress and pitfalls of the health IT ecosystem.
“While together we have come a long way and are thankful for your involvement thus far, much work still remains to be done,” DeSalvo and Galvez said. “In the near-term, the collaboration of stakeholders to fulfill the calls to action and commitments is critical to advancing nationwide interoperability.”
“Over time our collective efforts will shift to expand the interoperable health IT ecosystem to include other data sources and users that form a learning health system that puts the person at the center, can continuously improve care, public health and science through real-time data access. I am excited to continue on this journey with you to improve the health of consumers no matter where they live, work and play.”