I’m not sure how many of my readers are following the subject and CMS stance/policy on interoperability among providers but the concepts and resultant debate are rather interesting. I am trying to encourage as many clients and readers to tune-in on this subject as the implications are sweeping – positively and negatively.
Interoperability in this context means the ability of computer systems or software to exchange and/or make use of information for functional purposes. In health care, the genesis of the interoperability concept began with HIPAA in the nineties. HIPAA spawned the HITECH Act in 2009 which ultimately created Meaningful Use. For anyone unfamiliar with Meaning Use and its incentive provisions, think no further than Value-Based Purchasing (VBP) and quality reporting. The IMPACT Act is an analogous outgrowth of blended concepts between Meaningful Use, Value-Based Purchasing and Interoperability. Conceptually, the goal is to create data measures that have “meaning” in terms of clinical conditions, outcomes, patient care and economics. Ideally, data that matters and can be shared will improve outcomes, improve standardization of care and treatment processes and reduce cost through reduced waste and duplication. Sounds simple and logical enough.
In April of this year, with the roll-out of various provider segment Inpatient PPS proposed rules for FY 2019, CMS included proposals to strengthen and expedite, interoperability. The concept is contained within the SNF and Hospital proposed rules. The twist however, is that CMS is changing its tone from “voluntary” to “mandatory” regarding expediting or advancing, interoperability. Up until this point, Meaningful Use projects that advanced interoperability goals were incentive driven; no punishment. Among the options CMS is willing to pursue to advance interoperability are new Conditions of Participation and Conditions for Coverage that may include reimbursement implications (negative) and fines for non-compliance and non-advancement. In the SNF 2019 Proposed Rule, providers are mandated to use the 2015 Edition of Certified Health Record/Information Technology in order to qualify for incentive payments under VBP and avoid reimbursement reduction(s). For those interested, the 2015 Certified EHR Technology requirement summary is available here: final2015certedfactsheet.022114
The possible implications for providers are numerous – positive and negative. The greatest positive implication is a (hopeful) rapid escalation of software systems that can share functional data directly without having to build and maintain separate interfaces (third-party). Likewise, the proposed regulations will facilitate faster development of Health Information Exchanges (HIEs). Many states have operating HIEs but provider participation and investment has been limited. A quick interoperability interchange is via an HIE versus separate, unique data and software platform integration. As SNFs and HHAs have MDS and OASIS assessment requirements on admission, fluid patient history, diagnoses/coding exchange and treatment history will facilitate faster and more accurate, MDS/OASIS completion – a real winner. Dozens of other “tasky” issues can be addressed as well such as portions of drug reconciliation requirements by diagnosis on admission, review of lab and other diagnostic results, order interchanges and interfaces, etc.
The most negative implication for providers is COST. In reality, the post-acute side of health care isn’t really data savvy and hasn’t really kept pace with software and technology developments. Many providers are small. Many providers are rural. Many providers maintain primarily paper records and use technology only minimally. Full EHR for them is impractical and with present reimbursement levels, unlikely any time soon. The second most negative implication for providers is the fragmentation that exists among the system developers and software companies in the health care industry. The “deemed” proprietary nature of systems and their software codes has limited collaboration and cooperation necessary to advance interoperability. HIEs were supposed to remedy this problem but alas, not yet and not at the magnitude-level CMS is foretelling within its Proposed Rules.
Interoperability is needed and amazing, conceptually. The return is significant in terms of improvements in outcomes and reductions in waste and cost. Unfortunately, the provider community remains too fragmented and inversely incentivized today to jump ahead faster (money not tied to integration and initiatives among providers). Software systems don’t work between providers in fashions that support the interoperability goals. More troubling: the economics are daunting for providers that are not seeing any additional dollars in their reimbursements, capable of supporting the capital and infrastructure needs part and parcel to additional (and faster), interoperability.