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Thoughts on the CMS IPPS NPRM: A Public Health Perspective

by Noam Arzton June 1, 2018

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program (one from AMIA, one from CDC). Here are just a few additional tidbits I picked out of the NPRM.

Of course, this document is written like stereo instructions so I welcome any corrections or comments to my interpretation of what’s in the rule. I put page numbers (from final FBO version referenced above which has just been released) where relevant in parenthesis.

HITAC USCDI Task Force Delivers its Recommendations

by Noam Arzton April 19, 2018

On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core Data for Interoperability (USCDI) and Proposed Expansion Process which had been published for public comment back in January 2018. HITAC promptly accepted the Task Force’s recommendations.

The Task Force focused almost exclusively on the process for identifying the USCDI rather than the proposed USCDI data itself. I especially appreciated their introduction of some key concepts related to how USCDI should be organized and understood. It has always bothered me that the current Common Clinical Data Set (CCDS) upon which the current draft USCDI is based contains a variety of types of data at different levels of analysis: for instance, a single discreet data element (like date of birth or sex) sits alongside more complex data constructs (like address, which contains many discreet data elements within it) which sit alongside even more complex data types (like immunizations or procedures). The Task Force introduces a notion of hierarchy to make this more sensible: data classes (high level topic like “demographics”), data objects (a single item within a class, like “address” within the class “demographics”), and data object attributes (a specific data element within a data object, like “zip code” within “address”).

From a process standpoint, the Task Force recommended an expanded set of steps which has an emphasis on more stakeholder participation and less ONC pronouncement. This includes a recommendation for patient input as well. These are welcomed additions and I certainly hope they will be operationalized by ONC.

HLN-authored White Paper published by NYeC: The Case for Payer Participation in Health Information Exchange

by Noam Arzton April 10, 2018

The New York eHealth Collaborative (NYeC) recently published a new white paper authored by Dr. Noam Arzt, President of HLN, titled The Case for Payer Participation in Health Information Exchange.

Health information exchanges (HIEs) are collaborative efforts that focus on health data exchange on a community, regional, or statewide basis. HIEs are quite diverse; their services have yet to be fully leveraged by the payer community. HIE is an important tool in improving the quality of patient care and outcomes, increasing accuracy and speed of diagnosis, eliminating unnecessary or duplicative tests and procedures, and reducing healthcare expenditures. Payers who participate in HIEs can experience greater oversight and can be better equipped to manage and coordinate patient care.

HLN Participates in Stewards of Change Regional Symposium

by Noam Arzton March 29, 2018

On March 27-28, 2018, Dr. Noam Arzt, President of HLN, participated by invitation in the Stewards of Change National Interoperability Collaborative Symposium on Advancing Information Sharing in California and Beyond on behalf of the Healthcare Information and Management Systems Society (HIMSS). In attendance was a small, but diverse set of stakeholders across the health, human services, education, and criminal justice with an interest in improving data interoperability between systems with these diverse domains, with a special emphasis on efforts in California. Sponsored by the National Interoperability Collaborative (NIC) this symposium represents a continuing expansion of the Stewards of Change focus from human services into the health domain. This expanded conversation will allow public health to participate more fully as the shift to our collective concern about wellness requires a more holistic view of people, their requirements, and their circumstances. We look forward to continuing engagement with this community and an opportunity to bring what we have learned in public health about interoperability into this new forum.

ONC Selects Noam Arzt to serve on the Trusted Exchange Framework Task Force

by Noam Arzton February 19, 2018

The Office of the National Coordinator for Health Information Technology (ONC) has selected Dr. Noam H. Arzt, President of HLN Consulting (HLN), as a member of the Trusted Exchange Framework Task Force. This group of healthcare and health information technology specialists will advise ONC on various aspects of the Draft Trusted Exchange Framework. This framework outlines a common set of principles for trusted exchange of health information records and minimum terms and conditions for trusted exchange as directed by Congress in the 21st Century Cures Act.

The task force is expected to consider a number of important implementation issues for the framework, including the nature of the coordinating body that ONC envisions for this activity (the Recognized Coordinating Entity, or RCE); the definition, attributes, and functioning of the organizations that will operate within this framework to exchange data (the Qualified Health Information Networks, or QHINs); issues related to privacy and security that must be understood and settled before interoperability can take place; and determination of exactly what activities and uses will be supported by the network.

Dr. Arzt has been a vocal proponent of health data interoperability and health information exchange for many years, with particular emphasis on public health’s needs and activities. Dr. Arzt has written extensively on the challenges and potential solutions to interoperability, including The Interoperability of Things which describes why interoperability in the US seems so hard to achieve. In a recent blog post (HIE: The New Landscape), Dr. Arzt described the state of health information exchange today and the changes that have taken place since Federal funding under the HITECH Act ended. He has also written key articles on important issues in health information technology such as information blocking, the state of patient matching strategy in the US, and cloud computing.

Dr. Arzt recently submitted public comments related to TEFCA on behalf of HLN, and participated in the responses developed and submitted by key organizations including the American Immunization Registry Association (AIRA), American Medical Informatics Associations (AMIA), Healthcare Information and Management Systems Society (HIMSS), and the Joint Public Health Informatics Task Force (JPHIT).

See Task Force Recommendations.