With its most current Interoperability and Patient Access Rule, the Centers for Medicare & Medicaid Services (CMS) is attempting to use all its levers to promote more and better information sharing. Some argue the agency is going too far—but I join those who applaud pushing the envelope. This is a tremendous opportunity to use the health information exchange (HIE) infrastructure that’s been built over the last decade to improve the experience for providers while also empowering patients.
As CMS makes some changes to the rule to address public input, it should not retreat. The proposed rule changes will likely need more time to fully implement and are quite expansive, but the potential opportunities around hospital notifications, network requirements, and patient access to healthcare claims could dramatically improve our overall healthcare system.
To best coordinate patient care, providers need timely information about their patients’ care. In New York State, providers subscribed to our statewide health information network—dubbed the SHIN-NY—get alerts when their patients are admitted, discharged, or transferred (ADT) from a hospital, so they can take appropriate actions to help organize and navigate follow up medical and social needs. According to a recent Cornell Weil and Indiana University study, providers that participate through their regional network have found alerts to be invaluable in helping manage patient care and reduce readmissions.
CMS’ proposal to require hospitals to share inpatient ADTs will dramatically help patients across the country. While the rule does need some tweaking to ensure that existing robust health information network alert systems, like the one in New York, can be used by providers to meet this new proposed requirement, expanding this type of information sharing is key to improving patient care.
CMS also got it right proposing the requirement for health plans offering public products to participate in trusted exchange networks. In New York, we have 25 plans able to use timely and comprehensive clinical information to help manage the care of their enrollees. In many regions health information exchanges are also helping to support quality measurement and more.
Most existing trusted exchange networks have been built to facilitate information exchange between providers and health plans. In order to truly leverage what has already been built, CMS needs to phase in the patient access requirement to ensure that mature health information networks, like New York’s, can best support care management.
Another important piece of the CMS proposal includes supporting payer-to-payer information exchange. Working with application programming interfaces (APIs) is definitely on the horizon – but for prompt implementation, CMS must remain flexible in the approach payers may take to actualize this reality. And of course, moving beyond payer to payer, to patient access through APIs, CMS must work across offices within the Department of Health and Human Services (HHS) to help ensure reasonable safeguards and consumer awareness – specifically with regards to privacy and security implications.
These rules are a big step forward in promoting interoperability and they can indeed make a difference in the health of our communities – especially if CMS holds strong and continues advance our national health information exchange program.
NYeC’s full comments are available here. Valerie Grey is the Executive Director for the New York eHealth Collaborative, a non-profit organization working to improve healthcare by integrating health information exchange (HIE) across the state.
