ONC – HLN Consulting, LLC

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.

A Public Health Perspective ONC’s Strategy to Reduce Burden on Physicians

by Noam Arzton December 19, 2018

On November 28, 2018 the Office of the National Coordinator for Health Information Technology (ONC) released a draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs for public comment. The strategy aims to reduce the time and effort and improve the functionality of electronic health records (EHRs) for clinicians, hospitals, and other healthcare organizations.

This strategy was developed primarily through the efforts of ONC-convened workgroups in response to requirements laid out by Congress in the 21st Century Cures Act (Section 13103). The report itself does not identify who exactly served on these workgroups and what organizations were represented.

ONC EHR Reporting Program RFI: A Public Health Perspective

by Noam Arzton September 12, 2018

On August 24, 2018, the Office of the National Coordinator for Health Information Technology (ONC) released a Request for Information (RFI) related to the EHR Reporting Program. This RFI is required by the 21st Century Cures Act and its primary purpose is to gather ideas and suggestions related to how ONC might provide better information about Certified EHR Technology (CEHRT).

Apparently, the initial intention was to create a “star rating” like the type used in Consumer Reports to use to rate EHRs, but that seems to have been abandoned in favor of some kind of measurement system. But it is far from clear exactly how this would be done. There may be something to learn from the Immunization Information System (IIS) community: with guidance from the CDC, the American Immunization Registry Association (AIRA) initiated a process to help assess compliance of IIS with national functional standards through a formal measurement and improvement initiative. “Validation,” rather than “certification” or “compliance,” is the carefully-chosen term to signify a system meeting the designated measures through formal testing. The process is interactive, and the results are only made public with the agreement of the IIS program. Perhaps some of the concepts and processes in this initiative can be useful for the EHR Reporting Program.

Frankly, there is not much of interest in here for public health, which is not in the business of worrying about CEHRT. Of course, the quality and functionality of EHR products does impact their effectiveness in supporting interoperability with public health registries. To that end, the RFI does as some questions towards the end (p. 42918) about additional information that might be useful for prospective purchasers of CEHRT, including “Submitting, editing, and retrieving data from registries, such as clinician-led clinical data registries.”

ONC asks for how they might prioritize including information related to this in EHR Reporting as well as data sources for reporting about this. It may be useful for public health to weigh in on these questions; comments are due no later than 5 p.m. on October 17, 2018 at the Federal eRulemaking Portal.

CMS MIPS PI NPRM: A Public Health Perspective

by Noam Arzton September 6, 2018

See my HIMSS blog and our formal comments on this NPRM!

Well, here we go again.

The Centers for Medicare and Medicaid Services (CMS) has now released a new Notice of Proposed Rulemaking (NPRM), titled Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Re visions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program. The purpose of this NPRM is to address proposed changes for Year 3 of MIPS, the provider (as opposed to hospital) side of the Quality Payment Program. The part that is most relevant to public health is the Medicaid Promoting Interoperability (PI) Program for Eligible Professionals (EP)” (the EHR Incentive Programs have been renamed). A major goal of this NPRM is to synchronize as much as possible the EP program with the hospital-based program that was addressed in a previous NPRM just a few months ago.

CMS IPPS Final Rule: A Public Health Perspective

by Noam Arzton August 17, 2018

On August 2, 2018 the Centers for Medicare and Medicaid Services (CMS) released the 2019 Inpatient Prospective Payment System Final Rule to Quality Payment Program. We earlier released thoughts on the Proposed Rule as well as our formal comments.

The Final Rule affirmed most of CMS’ proposed changes, with some notable exceptions:

Required public health measures were reduced from three (Stage 3 requirement) to just two, but Syndromic Surveillance will not be a requirement for hospitals covered under the rule.
While CMS continued to be unclear about its plans for the removal of public health measures altogether for CY2022 and beyond, they did express some openness to consider continuing public health measures and to study the issue over the next few years.

It is clear from the comments discussed in the final rule that comments submitted supporting public health requirements were received, noted, and had a positive impact on the final rule. Kudos to public health advocates for their strong voice!