Shanti Wilson, Consultant, Freed Associates As if 2020 couldn’t be
any more challenging for healthcare providers, new federal rules on
interoperability and patient access, granting patients direct access to their healthcare
data, begin taking effect this November and continue into 2022. These rules,
while ultimately beneficial to patients, bring an additional level of
operational complexity to many revenue-stressed healthcare organizations.
If anything, the 2020 pandemic has illustrated the vast potential of interoperability. For example, consider the huge increase in 2020 in virtual care visits, projected to be more than 1 billion by year’s end, and with an estimated 90% related to Covid-19. Many of these new virtual health patients will move through different care networks, using different health plans, and seeking remote access to their health records. These are precisely the type of patients’ interoperability is meant to help.
What should healthcare providers be doing now to ensure they’re not only compliant with new interoperability rules, but also applying them as optimally as possible to benefit their patients and organizations? In this article, we review the upcoming rules and suggest five key steps providers can take to ensure their interoperability implementations proceed as smoothly as possible.
What’s Ahead with
After several years of discussion on interoperability standards, the Office of the National Coordinator (ONC) for Healthcare IT and the Centers for Medicare & Medicaid Services (CMS) issued their final rules on interoperability in the spring of 2020. The new rules, covering both health systems and health plans, are intended to ensure that patients can electronically access their healthcare information regardless of health system or type of electronic health records (EHR) and covering all CMS-regulated plan types, including Medicare Advantage, CHIP, and the Federally Facilitated Exchanges.
Starting Nov. 2, 2020, healthcare systems must begin complying with interoperability rules preventing information blocking, which means not interfering with patients’ access to or use of their electronic health information. Providers must also attest they are acting “in good faith” regarding preventing information blocking, with any non-compliance flagged on the National Plan and Provider Enumeration System. By May 1, 2021, hospitals, psychiatric hospitals, and critical access hospitals with an EHR must send notification of their patients’ admission, discharge, and transfer (ADT) events to providers.
Interoperability will replace the current fragmented and error-prone ways of exchanging vital healthcare information. Near-term benefits of interoperability include improved care coordination and patient experience, greater patient safety, and stronger patient privacy and security. Longer-term benefits include higher provider productivity, reduced healthcare costs, and more accurate public health data.
For providers, the good
news about interoperability is that they’ve had years to think about and
implement many of its fundamental tenets, based on their work meeting
meaningful use requirements. That’s borne out in a 2019 HIMSS survey of
healthcare organizations which found nearly 75% of respondents past the
“foundational” level of interoperability – “foundational” defined as allowing
data exchange from one IT
system to another, but without data interpretation.
Five Steps for
While healthcare systems
will achieve significant interoperability gains through technology investments,
they should not consider technology as the ultimate sole key to
interoperability success. If anything, financial and political considerations
may be far more important to your organization’s interoperability success. Here
are five critical non-technology factors to consider:
1. Determine your “master”
All pertinent stakeholders in your organization should be on the same page about your interoperability strategy, resources, and timing. Know up-front that those implementing interoperability may not have previously worked with patient-centric analytics, partners, or departments in your organization. Plan your resources and timing accordingly. Your strategy should focus on the value-add of interoperability internally, such as access to additional data points on your patients, and externally, such as how you describe the upcoming benefits of interoperability to your patients.
2. Convey your vision, expectations
and expected return
An interoperability implementation is
a massive change management initiative, which requires continuous, top-down
leadership and championship, and proper expectation-setting. Communicate where
your organization currently stands regarding its interoperability capabilities,
and where you wish to have it go. Convey how the organization plans to get to
its future desired state. And perhaps most importantly, share the likely return
on investment in this effort. Be as specific as possible. For example, if you
believe interoperability gains will ultimately enable a 5% decrease in your
hospital readmissions, state that.
3. Examine workflows and identify
specific use cases
Every type of ADT event in your
organization, and its corresponding workflows and system interactions, should
be under review. Consider all types of clinical use cases, the types of data to
be exchanged, and those involved in providing patient care. This will help
determine your optimal approach to data-sharing and how your organization can
strategically use the additional data you receive from other health
4. Rigorously prep your data
Standardized data collection and reporting
which produces quality data is the heart and soul of successful
interoperability. Be sure your organization’s data is clean and meaningful, and
will ultimately be understandable and useful to your patients.
5. Think big-picture differentiation
There’s nothing in the ONC and CMS
interoperability rules that says you need to stop at mere rules compliance.
Consider your pursuit of interoperability as a singular opportunity to be a
patient-centric leader in your market. Let everyone relevant know of the
success you’ve achieved.
offers a chance for healthcare systems to achieve multiple operational gains,
when handled well, it is ultimately a patient-centric endeavor. Always keep the
needs and interests of your patients at the core when facilitating access to
their personal health data. It’s the ultimate smart long-term interoperability
Shanti Wilson is
a consultant with Freed Associates,
a California-based healthcare management consulting firm.