Imagine if you couldn’t see your online retail order activity for four days. Instant access to information is now the norm – except when it comes to patient electronic access to their health information. Under current federal standards for sharing patient records, the measure is defined as “timely” – or within four days.
Under just proposed rules for 2020, the Centers for Medicare and Medicaid Services (CMS) is seeking input over a proposed change to cut the current four-day window to one day, or “immediately.” CMS is also seeking comments on other possible uses of data access, such as patient-generated health data. Potential changes to interoperability standards include if providers should collect data from beyond appointments. This includes data generated by wearable devices and other sensors (i.e., interoperable scales and blood pressure devices). And CMS is also posing the question if patients should be allowed to access and add data to their own records.
The proposed interoperability changes comments were announced at the end of July by CMS. Other rule changes that would alter the Merit-Based Incentive Payment System (MIPS) scheduled to take effect in 2020 were also announced. MIPS is the CMS program to help transform the U.S. healthcare system from episodic (fee-for-service) care to coordinated care based on outcomes (value-based care). The “prompting interoperability” factor counts for 25 percent of the weighting/calculation under the MIPS incentive formula. Hospitals, physicians, and other providers failing to meet the requirement are penalized through lower payments.
Data sharing – interoperability – is not just for doctors or caseworkers. The ability of patients to be active participants in their care is an essential strategy in controlling costs and realizing better outcomes – especially in addressing Social Determinants of Health (SDoH). According to an interview with Gary Kaplan, MD, Chairman, and CEO of Virginia Mason Health System, published in the New England Journal of Medicine, prevention, such as attention to SDoH, and patient engagement through access to their health information in achieving MIPS goal is a good idea.
“Shared decision-making is really about engaging the patient in understanding their choices and that they do, indeed, have choices,” said Kaplan. “That the doctor is not in charge and that the patient’s in charge . . . if we engage patients that way, we can make better decisions together.”
He cited three crucial steps in support of data interoperability:
1: Make patient information accessible: Kaplan’s health system has put its patient electronic health record front and center in all patient interactions. The first thing the physician and patient see are actionable prevention, and screening needs specifically recommend for the patient based on their medical history. Many health systems have teams of care coordinators who work with high-risk patients after they meet with the primary care physician. Care coordinators help connect patients to available community-based support services. Using a care coordination and referral solution, care coordinators are able to see if the patient is adhering to their care plan and close the loop on the referrals.
2: The power of the portal: Patients can log in and review all the physician notes, which helps the doctor engage with the patient on health goals, such as weight loss or screenings. In addition, the portal facilitates collaboration and real-time communication between health, behavioral health, and community-based providers.
3: Educate and empower patients: Knowledge fosters shared-decision making, which is at the most basic level, is vital for a care plan to succeed. There’s buy-in because the plan becomes the patient’s plan, not an order from the doctor.
Any interoperability solutions to allow patients access to their electronic health information, SDoH focused or otherwise, are accompanied by privacy and security concerns. A recent survey by Trusted Network Accreditation Program found that 95 percent of healthcare industry stakeholders agree that improving the ability of the healthcare system to electronically share patient data would be a more effective and efficient system. However, 81 percent of the respondents have privacy and security issues after the data leaves their network. Further, 62 percent felt that efforts to protect patient data have been “inconsistent” with exchange partners.
Despite such concerns, the effort to embed SDoH into decision making with patients and their data is compelling. Eccovia Solutions recently discussed five steps to deploy SDoH in support of MIPS goals, as advocated by the eHealth Initiative. The eHealth Initiative is an independent, non-profit on a mission to identify best practice through the use of technology and innovation.
1: Care coordination: Identify individuals with SDOH needs, coordinate delivery of holistic care, and facilitate connections to additional services or interventions.
2: Recognizing risk via SDOH analytics: Identify risk through the use of analytics tools to develop population health management interventions for persons and communities.
3: Mapping community resources: Assess individual SDOH needs against available community resources to identify gaps that address health and wellness.
4: Service and impact assessment: Assess the results of SDOH interventions and services.
5: SDOH as a tool: Support for customizing health services and interventions, use SDOH as a guide for quality discussions with individuals or their guardians and caregivers to jointly decide which services and interventions are the best fit.
The deadline for comments on the proposed interoperability rule, as well as other changes, is September 27, 2019 at. The proposed interoperability changes build on standards released earlier in 2019 related to certified electronic health record technology (CEHERT) standard data format, which builds on meaningful use guidelines adopted in 2015. According to CMS:
“To continue our commitment to promoting and prioritizing interoperability of health care data, CMS renamed the EHR Incentive Programs (meaningful use) to the Promoting Interoperability Programs in April 2018. This change will move the programs beyond the existing requirements of meaningful use to a new phase of EHR measurement with an increased focus on interoperability and improving patient access to health information.”