Stakeholders Offer Early Impressions of California Data Exchange Framework

During a recent online discussion, payer and provider organization representatives shared their impressions of the progress being made in the first year of implementation of California’s Data Exchange Framework. 

Erica Galvez, CEO of Manifest MedEx, the largest nonprofit health data network in California, hosted the discussion about the implementation phase of the framework, which under state law AB 133, requires most healthcare entities in California to exchange health and social services information beginning this year. Manifest MedEx is one of nine qualified health information organizations (QHIO) designated by the California Health & Human Services Agency (CalHHS). 

Galvez was joined by David Ford, vice president of health information technology at the California Medical Association; Adam Davis, M.D., a physician informaticist leader at Sutter Health; and  Krishna Ramachandran, senior vice president, health transformation and provider adoption at Blue Shield of California, a nonprofit health plan with $25 billion in annual revenue serving 4.8 million members.

Galvez asked the panelists for their initial assessment of whether the Data Exchange Framework was meeting their expectations so far.

Ramachandran responded that he was reminded of the Gartner Hype Cycle. "Certainly we were in this peak of inflated expectations at one point, maybe last year, because we had the signatures coming through,” he said.  I feel like we're somewhere in the trough of disillusionment to the slope of enlightenment. Yet I'm always a glass-half-full person, so I feel like we will be up the slope of enlightenment and to the plateau of productivity. But so far, I feel like we're definitely in the trough, where we've got people signed, but just a fraction are actually signed and have put a data exchange method in the directory.”

He noted that on the payer side, they are not yet getting any data from an operational perspective. “I know there’s data exchange happening from a treatment perspective, which is fantastic. But we are definitely very eager to get up the slope and continue to light up a number of meaningful use cases that I think can really help members, patients, and providers reduce administrative burden, as well as streamline how we deliver care in our state.”

Ford said that if he were to grade the implementation of the Data Exchange Framework, he would give it an incomplete. “There's definitely still some policy work that needs to happen to put the rest of the structure around the Data Exchange Framework,” he explained. “But that being said, we do have 3,000-something entities that have signed. We’re seeing some really great energy and some interest from non-traditional parts of data exchange. The community-based organizations have been some of the earliest ones to raise their hands and say they want to be part of this, and that's been really interesting. It's something I would not have predicted coming into the whole process, But I really would like to see us close those last gaps, and get the rest of the structure in place, so that we can really move forward together.”

Davis noted that from his perspective, the framework has not been impactful yet. “The way that I like to think about it is, what's the delta between what we're doing in California, what the feds require through various information-sharing regulations, and now the TEFCA on-ramp,” he explained. “There are some significant differences and some of those significant differences are potentially exciting, but I don't think they have played out yet. 

He described three requirements for the type of sharing you have to do under the framework. One of them is query exchange, which is very similar to what the federal requirements are. “In fact,” Davis said, “many of our systems are doing that through national exchange networks that already exist. One of the things that the California Data Exchange Framework failed to do, although it enunciated which purposes of use we needed to be able to respond to, it didn’t create standards for how to do that, so that's still an area of discomfort for a lot of organizations.”

The second requirement, he said, is to respond to orders or referrals electronically. “For the referrals part, there are some standards around that some people are able to use to do that. We are able to do that with Direct secure messaging, but we are unable to do that for orders. I don't think any health system is able to do that for orders yet. So that was sort of an interesting requirement to put in, because there are really no technical standards around how that could be done at this time.”

The third requirement, which Davis said is the most exciting in the short term, is the ADT [admissions, discharge, transfer] subscription model. “We've had those sort of requests bouncing toward us for a long time. There are lots of great use cases for that and and we are hopeful that through the QHIOs connecting with each other and everybody giving their ADT information to the QHIOs, we will both, as producers of ADT messages, be able to say, hey, we're not going to be managing this anymore. You guys can go out and contact one of your QHIOs and they'll be able to provide you with that. Also, as receivers, we will now be able to subscribe and get a fuller picture of where patients who we are primarily responsible for their care are getting care. I am excited for that, and I'd like to see how that develops in the next six months. We have not yet benefited from that, but we're hoping that we will.”

Galvez asked the panelists for examples of early wins. Ford said just getting the framework through the legislature and established is a huge win after 15 years of efforts related to HIE in the state.

“Beyond that, there are more than 1,000 small practices that have signed the data-sharing agreement and that are getting up and running on the Data Exchange Framework statewide,” he added. “I think that's interesting, just because, those folks don't have to do it for another year and a half, so many of them have come in early. It shows the demand was there and that they really wanted to be involved in data exchange. By and large, small practices are not the folks who are holding the data. They're the folks who need the data to treat their patient, and they're coming forward and they're raising their hand and they're saying, Yes, I want to be a part of this.”

Ramachandran said he certainly like the engagement from  the breadth of social services and community-based organizations as well as government agencies. “It's nice to see people wanting to have a seat at the table and wanting to be a part of this journey. Transforming health is a painful, hard journey, and we have to start this journey somewhere. So I'm glad we're sort of like in chapter two of the journey, and its better than not starting the journey at all.”

Because he was involved in the Meaningful Use implementation and ran California's Regional Extension Center for five years, Ford was asked if there were lessons learned there that could apply to the Data Exchange Framework implementation to increase the percentage of organizations that are actually putting entries into the directory.

 “Well, let's not do what we did in Meaningful Use, OK? Let's start there,” Ford replied with a laugh. “We all know what a grind Meaningful Use was for so many physicians, It was way too complicated, right? I think the more simple we can keep this for practices, the more uptake we're going to get. The Meaningful Use experience was that many of the physicians who started on that journey dropped out because they saw how complex and how complicated it was. Let’s avoid as much complexity as we can.”