CMS and ONC Interoperability Rules: What Do the Latest Updates and Enforcement Delays Mean for the Industry?

CMS and ONC delays to enforcement give the industry a few additional months to prepare for major overhauls to ensure the appropriate sharing of patient health information. Yet the need for these efforts is now more important than ever.

In the past few months, healthcare organizations have experienced an influx of COVID-19 patients, prompting providers to make clinical decisions based on the most critical, timely data available. This data is especially useful in identifying individuals with comorbidities and other risk factors that directly impact health outcomes, including illness severity and morbidity. However, given the unpredictability of this virus, every individual’s health status, history and medications must be taken into account in order to inform treatment decisions. Fortunately, the initial groundwork for these efforts is already being laid by new mandates from the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC) on interoperability.

Understanding the Purpose and Aim of These Rules

The CMS and ONC rules, which fulfill the interoperability and information-blocking provisions of the 21st Century Cures Act, were finalized and distributed on March 9. Together, they help providers, payers and technology vendors work collaboratively to implement systems that give Americans safe and secure access to their own electronic health data. This allows them to make informed decisions about care, better understand their health history and even share this information with their care providers.

By promoting interoperability across the healthcare ecosystem, the healthcare industry can help make sure that critical data about patients—including those diagnosed, treated, discharged and given subsequent care plans—is shared among all members of a care team. This includes patients diagnosed with COVID-19, as well as others with ongoing care needs. This approach allows us to track and monitor patients regardless of the setting in which they are receiving care, from telemedicine visits in the home to the ICU. During uncertain times, sharing this essential data is critical to the healthcare system’s sustainability, and ultimately, our nation’s recovery. However, we must first have a set of standards that allows us to efficiently communicate with each other. That’s why these new rules arrived at an ideal time for everyone impacted by COVID-19, as well as care providers themselves.

While the enforcement of these rules has been delayed to allow healthcare organizations more time to prepare amidst other priorities during the pandemic, they still loom on the horizon. As such, savvy leaders should consider their plans and preparations for compliance while also positioning their organizations for successful management of COVID-19 and non-COVID patients over the coming months.

The Latest on Enforcement Delays

On April 21, the United States Department of Health and Human Services (HHS) announced that ONC and CMS will exercise enforcement discretion for certain requirements, although the actual compliance dates in the published rules remain the same. Both entities announced that enforcement for many of the requirements have been pushed back by six months.

Below are a few of the updated enforcement dates:

• Patient Access API: Effective 1/1/2021; enforcement discretion until 7/1/2021
• Provider Directory API: Effective 1/1/2021; enforcement discretion until 7/1/2021
• Patient Access API for QHP Issuers: Effective 1/1/2021; enforcement discretion until 7/1/2021
• Hospital Conditions of Participation: Effective 12 months after publication (5/1/2021)
• ONC requirements: Effective dates vary; enforcement discretion 6 months. Refer to this chart for more information.

How Can Organizations Prepare?

Healthcare organizations faced with multiple competing priorities can use this valuable window of time to plan a strategy that will allow for rapid deployment of new resources that ensure compliance. Fortunately, Aerial™ by Medecision was purpose-built in order to promote interoperability and is being enhanced to include data management capabilities that support these rules. We are already able to deliver on many of the following core requirements in order to help our customers meet the aggressive timeframes that accompany both the CMS and ONC final rules and we are working on several improvements that will further address these needs.

• Flexible data ingestion: Clients will have the freedom to send data in any format, as Aerial will consume and produce data in multiple industry- standards including FHIR, HL7 v2, CCDA, X12 and CCLF.
• Flexibility for developers as well: We already provide support for a live API console with real-time API documentation that allows developers to create adapters, configurations and credentialing infrastructure in a unified and secure manner.
• Near real-time data exchange: While we already support batch data exchange, the next-generation infrastructure of Medecision’s Insights analytics technology will allow for both batch and real-time data exchange with internal applications and approved third-party entities such as provider groups, payers and other health technology companies including Medecision. Connecting data from Aerial in real time through FHIR APIs will allow clients and their patients to view the most current healthcare information for decision-making.
• Making healthcare information compliant and useful: An Enterprise Logical Data Model (ELDM) will govern how data is stored within Insights, next-generation big data and machine learning for predictive analytics. The ELDM is inclusive of data elements associated with healthcare industry standards (including FHIR, HL7, etc.), all the standard data classes defined by the United States Core Data for Interoperability (USCDI) standards and major medical terminology descriptions that patients will need to understand the code sets referenced throughout their medical record.
• Support for real-time notifications: Our real-time notifications and alert capabilities will position Aerial to serve as the mechanism for provider groups looking to comply with new requirements for data sharing about hospital admissions, discharges or transfers.
• End-to-end Data Quality and Validation: Our existing capabilities ensure that data that is shared within an integrated health delivery network is valid and provides data submitters with the information they need to correct data issues. We continue to enhance these capabilities.
• An extensible, scalable Master Patient Index: Our patient index already allows Aerial to accurately identify unique patients and integrate data together from disparate sources to create a holistic, longitudinal health record. However, our new enterprise master patient index has even better matching accuracy and is more automated. This can help address duplicate records to people with multiple IDs, for example.

At Medecision, we believe that the CMS and ONC rules will advance the transformation of healthcare toward more person-centered, coordinated care delivery and help us deal with the onslaught of patient data from across the healthcare ecosystem. We also expect that Aerial will play a critical role in these efforts as health plans look to address the upcoming requirements.

We’ve already made significant strides toward advancing consumer access to useful, useable health information via Aerial by Medecision, which provides a 360-degree, holistic view of each individual’s health status, health history, risk factors and other critical clinical information. Because we’ve already laid the groundwork for interoperability, this makes us the partner of choice for health plans who want to quickly and effectively meet these requirements.