The following is a guest article by Vatsala Kapur Pathy, Vice President of Policy for Collective Medical.
As the COVID-19 pandemic rages on, the delayed enforcement of the federal Interoperability and Patient Access rule may have prompted a collective sigh of relief among healthcare leaders, but the pandemic demonstrates exactly why interoperability is needed—especially during a public health crisis.
Enforcement of the final rule, which sets standards for interoperability and patient access under the ONC’s 21st Century Cures Act, was pushed back six months due to COVID-19. But as providers reset their interoperability game plan and implementation for July 21, 2021, a recent report from the Duke Margolis Center for Public Policy shows why interoperability matters during the pandemic:
- 50% of COVID-19 test results sent to public health agencies by laboratories lack the patient’s address or Zip Code. This limits the ability of state and local public health agencies not only to contact patients, but also to identify where infection clusters exist or localize disease hotspots.
- Gaps in patient demographic information make it difficult—if not impossible—to pair patients’ test results with their medical record. Because of this, primary care providers often aren’t alerted to a patient’s test result, preventing efforts to coordinate patient care from the start of the testing encounter.
- Missing contact information also keeps health agencies from contacting patients to complete investigations around positive COVID-19 cases—putting the health of communities at risk.
The Duke Margolis report—written by a former Centers for Medicare & Medicaid Services (CMS) administrator and a former national coordinator for health IT based on insights from key stakeholders—outlines three immediate actions that healthcare providers, laboratories, and public health programs can take to enhance data interoperability and exchange to help contain the COVID-19 outbreak. But it also underscores why electronic data sharing that improves the flow of critical health information is critical now and after the immediate health crisis is over.
Why Continued Momentum Matters
The Cures Act calls for providers to exchange certain types of electronic patient information, such as transfer and discharge notifications, as a condition of Medicare participation. The rule also spells out the need to develop application programming interfaces (APIs) for exchange of data such as patient claims data, details of the medical encounter or insurer provider directory information.
It’s true that a delay in implementation was necessary, with some hospitals experiencing a large surge of patients as COVID-19 surged in their communities. However, easing the administrative strain on healthcare organizations by delaying enforcement of the Cures Act doesn’t mean progress toward interoperability should completely stop until next July.
Beyond COVID-19, increased interoperability ensures that primary care providers receive alerts when a patient with a chronic health condition presents in the emergency department (ED).
For example, a physician receiving a notification that a patient with diabetes has presented at the ED can determine:
- Was emergency care needed because the patient couldn’t afford insulin?
- Does the patient understand how to use insulin properly?
- Does the dosage need to be adjusted?
- Is the patient following an appropriate meal plan, and if not, could a nutrition counselor provide the right assistance?
Similarly, access to the right data at the right time helps ED physicians better understand a patient’s total health care needs at the point of care. Real-time alerts built into an electronic health record (EHR) can help ED physicians make critical game-time decisions, such as whether to administer pain relief based on a patient’s ED history or whether to contact social services if a patient faces issues with transportation to primary care appointments or access to healthy food.
Making Strides Toward Interoperability
In addition to seeking opportunities to strengthen existing IT systems and data capture processes to support a COVID-19 response, there are a number of steps healthcare organizations can take right now to support Cures Act compliance in 2021.
Request additional guidance. The 470-page final rule for interoperability is complex and confusing. Now is the time to contact CMS, the Office of the National Coordinator for Health Information, or the U.S. Department of Health and Human Services to request additional guidance, including:
- Under which circumstances providers will not meet Medicare conditions of participation requirements
- Target goals for each year of this initiative?
- How these rules will potentially adapt to a post-COVID-19 world
Begin the technology evaluation process. Involve a multidisciplinary team of key stakeholders—including physician leaders and supervisors who understand clinical workflows—in selecting the right technology solutions. Consider whether to swap out legacy systems or pair software solutions with existing health IT infrastructure to achieve compliance.
Talk with your care partners about Cures Act compliance. Look for ways to coordinate compliance with that of other providers in the area. Find out what primary care practices, post-acute providers, physician specialists, and others in the healthcare network are planning in response to the interoperability rule. What systems and solutions are being implemented? Are there changes in communication and collaboration that are needed to ensure a highly coordinated approach? Ultimately, hospitals need to be on the same page as their care partners when the time for implementation go-live arrives.
The Cures Act is a step to help modernize healthcare delivery. Even as healthcare organizations focus on their COVID-19 response, leaders should still assess their approach to Cures Act compliance while seeking ways to strengthen data exchange for improved public health.
About Vatsala Kapur Pathy
Vatsala Kapur Pathy is the VP of Policy for Collective Medical. Prior to joining Collective, Kapur Pathy worked at her self-founded consulting agency, Rootstock Solutions, providing policy and operational guidance to the Office of the National Coordinator. She also served as a Senior Advisor to the State Innovations Group at the Centers for Medicare and Medicaid Innovation.
