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ONC Releases 2018 HITECH Report

by Noam Arzton January 16, 2019

In early January the Office of the National Coordinator for Health Information Technology (ONC) issued its annual report to Congress for 2018 on the adoption of electronic health records (EHR) and interoperability. This report is required under the HITECH Act and is further informed by requirements of the later 21st Century Cures Act.

There was actually very little to comment about in this report, and it felt more like ONC was “going through the motions.” There were a few (actually, very few) updated statistics about technology use, a short discussion about the importance of open Application Programming Interfaces (APIs), and a useful but not terribly new list of initiatives and reports issued by ONC over the past year or two. I spotted one or two things in there that I had not recalled seeing before but nothing terribly important.

One thing that I think is notable was a short discussion about barriers to interoperability that we have heard before. The report identifies three types: technical barriers, financial barriers, and trust barriers. Within trust barriers the report mentions legal incentives to keep data from moving (I guess that would have better been phrased as legal disincentives to sharing), but this misses the point: It is the patchwork of inconsistent and incompatible State and local laws and regulations – not intentional information blocking – that presents a bigger challenge and barrier. These can be laws prohibiting movement of certain health data across state lines, incompatible consent requirements, or restrictions on “downstream” use of data that is shared. Until these legal barriers are addressed separate from trust issues interoperability will be hampered.

HHS Releases Landmark Report: Reforming America’s Healthcare System

by Noam Arzton January 6, 2019

On December 3, 2018, the Department of Health and Human Services (HHS) released an extensive, 120-page report on the administration’s proposals to reform the healthcare system. The report, titled Reforming America’s Healthcare System Through Choice and Competition, is divided into four major sections. The report that government policy of the last few years has suppressed competition, increased prices for healthcare, and limited choices for consumers. Though rich in detail as it tries to prove each of these points, the more than fifty recommendations are often broad and aspirational rather than practical.

Since I am not a health economist, I will leave the market issues to others to discuss (many of the ideas in this report have been vetted and discussed by others previously). But there are two sections of the report which make direct mention of Health IT.

HLN Submits Comments to CMS on IPPS NPRM

by Noam Arzton June 14, 2018

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program based on our earlier comments:

HLN Consulting, LLC is pleased to submit the following comments on the recently-released CMS IPPS NPRM, CMS–1694–P. HLN is a leading public health informatics consulting company. With that in mind, we read documents like the NPRM through a public health lens, and confine our comments to that important context.

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.