The CMS has kept HIT vendors and providers busy for the last decade. The latest genie is out of the bottle, and it now aims to achieve greater transparency. Out earlier this year, the Cures Act mandates providers to open up and share patient information through two rules. Failure to do so has more repercussions than providers would like to count. Here is what you need to know about it and how you can navigate through it.

What Does The Regulation Mandate?

The Act presents itself in the form of two rules – The ONC's final rule and CMS’s Interoperability & Patient access rule. While the former mainly affects the HIT vendors, its information blocking component exposes healthcare providers to some very significant changes. Combining the two, below is what providers need to do. 

ONC’s Final rule

Expose patient data they hold using a real-time exchange API by Jan 2021

CMS’s Interoperability and Patient Access Rule

Public reporting - Update digital contact information at National Plan and Provider Enumeration System by late 2020

CoP requirements - Electronic patient event notifications by May 1st, 2021

What Does The Regulation Mandate?

The Act presents itself in the form of two rules – ONC's final rule and CMS’s Interoperability & Patient access rule. While the former affects mainly the HIT vendors, its information blocking component exposes healthcare providers to some very significant changes. Combining the two, below is what providers need to do. 

ONC’s Final rule

Expose patient data they hold using a real-time exchange API by Jan 2021

CMS’s Interoperability and Patient Access Rule

Public reporting - Update digital contact information at National Plan and Provider Enumeration System by late 2020

CoP requirements - Electronic patient event Notifications by May 1st 2021

What Happens if you don’t Comply? 

Disincentives as determined by OIG

Listing on CMS's Wall of Shame

Brand dilution eroding patient trust

Overheads of servicing requests/notifications

Legal expenses in cases of allegations

What Needs to be Done?

Compliance demands secured, interoperable and open exchange via APIs. Fragmented systems and fear of HIPAA violation will challenge the propensity of your success at this endeavor. Adding to that, minimizing the effort of servicing requests in the future, factoring the exceptions, and tracing the evidence trail are going to make this a bull ride. To ensure that you accomplish all of this in a future-proof way, below are essential elements of the solution you need.

  • Implement one gateway for secure handling of request
  • Centralized and extensible mechanism for authentication/authorization
  • Aggregate data across silos and map it with USCDI
  • Implement interoperability using FHIR V4
  • Trace the lifecycle of information requests as evidence
  • Implement automation for the entire request-response loop
  • X-enterprise, centralized subscription/Broadcast mechanism for e Notifications
  • Achieve Auto-sync with NPPE

Biggest Challenges you Might Face

With care delivery as the focus, most provider organizations have numerous off-the-shelf products that they ‘use.’ Achieving the objectives listed above may be beyond the scope of their specializations. Executing this initiative by themselves, below is what they are likely to encounter.

Investigating “under the carpet” wiring of all their relevant systems

Aggregating the data spanning multiple systems to fulfill an information request

Learning curve with FHIR, USCDI, C2S etc. in detail from an implementation perspective

Time lost in discovery of Security audit, and workflow automation aspects

How Can we Help you in This Journey?

Each of the solutions you may have today might promise interoperability with the ecosystem, within its walls. However, as an organization, you need an overarching framework covering all of those solutions to be compliant. That is what we can help you achieve.

Assessment of
the technology landscape

Technical approach
and design presentation

Agile and phased
implementation – Parallel Tracks

UAT, Go-Live
and metering

Let’s help you comply with the mandate

A no obligation consultative discussion is always a good step towards the solution.

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