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Where HIMSS Stands on the Proposed Interoperability Rules


HIMSS will release an official comment letter on the proposed interoperability rules on May 3.


The release of the proposed interoperability rules by the U.S. Department of Health and Human Services (HHS) on the first day of HIMSS 2019 seemed like perfect timing. As experts in the healthcare industry gathered to talk about health technology and innovations, the interoperability rules became one of the focal points of the conference.

A month later, and experts are still sifting through the hundreds of pages in an attempt to interpret the rules that the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for Health IT (ONC) rolled out.

In a WebEx roundtable call held by the HIMSS government relations team on Thursday morning, Jeff Coughlin, senior director of federal and state affairs, and Tom Leary, vice president of government relations, said that their team is still working to figure out how it wants to position HIMSS in its comment letter regarding the proposed rules.

Coughlin said that there are weekly conversations across HIMSS members and federal agencies to interpret what’s in the rules. HIMSS is also working on informing the membership through monthly committee and community meetings to emphasize the details of the rules and get feedback and impressions. Currently, HIMSS has no fully formed ideas.

Overarching Thoughts

Coughlin said that the proposed rules include all sectors of the healthcare ecosystem — vendors, providers and payers.

He also said that between the two rules, there are two big themes: pushing data sharing forward and the putting the patient at the center of their healthcare.

Application Programming Interfaces (APIs) play a key role in both rules. APIs are seen as a leveler of the playing field in terms of providing patients more control, Coughlin said.

And HHS has been focused on transparency and pricing transparency over the past several months.

So, CMS is trying to increase pricing transparency by requiring hospitals to publicize their chargemaster data in a machine-readable format on their websites to empower patients.

The ONC rule would require that patients have electronic access to their electronic health information at no cost. The rule also asks for comments on pricing information that could be included as part of their electronic health information and would help the public see the prices they are paying for their healthcare. Additionally, ONC attempts to be transparent by ensuring that the terms laid out are consistent, non-discriminatory and create opportunities for new market entrants.

The Impact of the Rules on Health Systems

According to Coughlin, the CMS rule around conditions of participation changing and ADP feeds is a major step forward and something HIMSS is looking at and talking to members and associations about.

Health systems are important when thinking about the broad exchange of data and what’s trying to be facilitating through the ONC rule, which calls on the industry to adopt standard APIs to help patients securely and easily access structured and unstructured electronic health information via a mobile device.

Coughlin said that nearly all of the provisions in ONC’s rule will impact and help providers in some way.

HIMSS Membership Takeaways

Coughlin said that there are a few things being said by membership about the proposed rules, including the complexity of the rules and what’s included, the definitions of certain terms in the rules and the burden being placed on providers.

While the ONC and CMS worked hard designing proposed rules to enhance the exchange of information, due to the complexity of the rules, it makes them harder to interpret and potentially implement.

With that, several of the ideas being laid out by the agencies are difficult to define.

For example, HIMSS is looking closely at the rules’ use of “electronic health information” and the difference between “health information exchanges” and “health information networks.”

Coughlin suggests that it would be helpful for the community to have examples and use cases for the rules, especially exceptions to information blocking.

It is also necessary to recognize the additional burden being placed on providers across the community. Burden is important when thinking about compliance and implementation.

Leary added to that that there needs to be balance between the push toward value-based care and ensuring that Medicare and Medicaid providers can move down a similar path without being burdened.

HIMSS will release its comment letter on the proposed rules on May 3.

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