National Governors Association Report Highlights Interoperability Policy Levers
The National Governors Association (NGA) Center for Best Practices has developed recommendations for ways state governments can galvanize electronic health information sharing.
The goal of the new NGA white paper is to share strategies governors and other state leaders can pursue to expand access to data and technology that will improve health and wellbeing across the country. The paper includes a set of state considerations, examples from states that have leveraged policy opportunities, sample use cases, and financing strategies.
The NGA notes that for new entrants and smaller providers, providing funding for shared technical services may help providers who would otherwise struggle with the cost of compliance. For instance, State Medicaid agencies can specify contracting requirements for managed care organizations (MCOs) requiring and incentivizing health information exchange (HIE) adoption through collaboration and transparent approaches.
States also can align their policies with federal rules to facilitate participation and compliance. The NGA notes that by aligning state program requirements with federal standards, states can facilitate improved compliance and usability through application programming interfaces (APIs) and timely data sharing. Below are examples of federal requirements with which states may consider aligning:
• Patient access to health data: Payers must share data with patients via APIs, coordinate data between payers using the United States Core Data for Interoperability (USCDI), per the Centers for Medicare & Medicaid Services (CMS) Interoperability Rule by January 2022.
• Admission, discharge and transfer (ADT) event notifications: CMS is requiring hospitals to send electronic notifications of a patient’s admission, discharge, and/or transfer to another health care facility, community provider or practitioner to improve care coordination and follow-up care by April 30, 2021, as a condition of participation in the CMS Interoperability and Patient Access Rule.
• Reporting data requirements for public health: The Centers for Disease Control and Prevention (CDC) is requiring reporting of specific data elements, such as race and ethnicity for vaccine administration, test results, and case investigations.
As CMS encourages state Medicaid agencies to provide a plan to show how 1115 waiver demonstrations will use data and HIT to support delivery system reform and value-based payment models, the NGA points to some possible directions:
• Connect health and community-based organizations through health and social services networks using platforms to better address social determinants of health. Sharing standardized social screening and assessment data across health and community organizations improves interventions, referral coordination and management and population health analytics. For example, North Carolina’s NCCARE360 is a statewide coordinated care platform that electronically connects individuals to community resources and helps health and community- based organizations coordinate an individual’s whole-person care.
• Modernize public health infrastructure with bidirectional exchange of standardized data. States can improve their response to the pandemic by leveraging existing networks across the state through available health information exchange networks to improve data availability, reliability and integration. By identifying and requiring data reporting through specific networks, states can streamline reporting, consolidate disparate data feeds and reduce administrative burden. For example, North Dakota’s rural providers transitioned from paper-based COVID-19 data reporting to electronic reporting using the statewide HIE, NDHIN, for required public health reporting for lab reporting, syndromic surveillance, and immunization data through bidirectional queries to providers’ electronic health records (EHRs).
• Designate a health data public utility to provide common data services for statewide data needs. Health data utility models are increasingly popular state strategies to facilitate exchange of clinical information, improve disease surveillance, and reduce data reporting burdens. By designating a not-for-profit organization to operate a regulated network, states can make and enforce HIE policy decisions, the entity can serve the whole state, and the unified approach can reduce technical capability gaps and fragmented data. For example, Maryland designated the Chesapeake Regional Information System for our Patients (CRISP) to maintain the technical infrastructure for statewide, secure electronic information exchange as a result of legislative action.
