HERE’S WHO DID WHAT TO ME: COMING REGULATIONS SUPPORTING INTEROPERABILITY FOR HEALTH DATA

With the creation of MyHealthEData, and through current rulemaking, the Centers for Medicare and Medicaid Services (CMS) is pushing significant new data-sharing requirements into the market.  The new rule opens all types of doors in its effort to improve data transparency and data velocity throughout the system.

The core tenets are:

Ensuring patients have access to all health data where CMS has programmatic authority:

Any payors involved in the following programs are required to have open APIs (Application Program Interfaces): MA organizations, Medicaid programs (both FFS and managed care), CHIP (including FFS and managed care), and QHP issuers in FFEs.

These open APIs will allow patients to empower a vendor to access their claims, encounter data, utilization history, and any clinical health information (such as lab results when available) the payor may have. Payors are also to make their plan directory available through these APIs and have to share care coordination data with each other.

Electronic patient event notifications:  

As a condition of participating with Medicare and provided their EHR has the ability to produce and send an Admit/Discharge/Transfer (ADT) message, it is being proposed that hospitals should send notifications to those practitioners or providers that have an established relationship with the patient relevant to his or her care. (The requirement is waived if the receiving provider can’t receive such messages.)

Prevent information blocking:  

Providers who are not making patients’ clinical data readily available will, essentially, be publicly shamed into compliance as CMS aims to share provider attestations that the provider complies (or doesn’t) with interoperability requirements laid out in updated MIPS rules.  In my opinion, this is a seemingly weak penalty for non-compliance so hopefully, CMS tightens this to improve accountability.

So how might care be impacted by these changes if implemented largely as proposed?  

Where are patients likely to engage with this information?  How about providers?

Patients, to date, have shown little interest in actively engaging with their health care data on their own (consider almost every provider’s struggle to get Portal engagement) - what will Medicare/Medicaid patients do with their claims history?  It’s possible applying algorithms to claims data to identify at-risk profiles might generate patient-level demand but the marketing will have to be focused and on point.  

The first real-world test of the data typically available is Medicare’s Blue Button API (now in version 2.0).  As of October, there were 1,200 software developers in the sandbox and 100 - 200 patients had downloaded their data.  It’s possible this gap between developer engagement and patient engagement represents a lag from the time it takes to create an application to generating demand for the information.  I think it also highlights that age-old health care problem of an abundance of data and little of it valuable or comprehensible to your average individual. At the end of the day, how do you engage a patient to make their best health care choices when those choices are either deeply complex or rarely and erratically occur?

The other audience, of course, is providers.  Claims data provides a history of activity which can complement the clinical care history each participating provider can access.  They can see diagnoses and procedures which both carry useful information in any given provider’s ongoing care of the patient and supplement their clinical inquiries.

The second benefit of having access to claims data is in optimizing HCC scores.  Since a primary input of HCC scores are all the diagnoses a patient accumulates during the year, having access to a comprehensive list of billed diagnoses allows for any given provider to potentially optimize the patient’s HCC scores.  If this market evolves, payors could fully decentralize HCC scoring (with appropriate incentives) to providers. Considering the HCC score paradigm is national, and zero-sum, it can be expected there will be a rush to claim this space and a handful of winners should emerge.

The health care market continues to be pushed to evolve as the population ages and inflation marches on.  You should consider the technology companies you work with and ask if they have the history, the people, and the capabilities to help you navigate a market where changes can dramatically impact your bottom line and your outlook.  At pMD, through our expertise in mobile charge capture, secure clinical communications, and care navigation we strive to meet our customers where their future needs live.  See what we are about at www.pmd.com.

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