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 ONC's final rule mainly affects the HIT vendors. But its information blocking component exposes healthcare providers to some very significant changes. To parry the swing of this double edged sword, here's what providers must 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 NPPES
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
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 for implementation
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