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CMS IPPS Final Rule: A Public Health Perspective

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CMS IPPS Final Rule: A Public Health Perspective

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 rele ...

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!

Thoughts on the CMS IPPS NPRM: A Public Health Perspective

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Thoughts on the CMS IPPS NPRM: A Public Health Perspective

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 Rule ...

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

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HITAC USCDI Task Force Delivers its Recommendations

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 D ...

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.

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

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

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 ...

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.

TEFCA: A Public Health Perspective (final)

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TEFCA: A Public Health Perspective (final)

In January 2018 the Office of the National Coordinator for Health Information Technology (ONC) issued a draft Trusted Exchange Framework and Common Agreement (TEFCA), and related s ...

In January 2018 the Office of the National Coordinator for Health Information Technology (ONC) issued a draft Trusted Exchange Framework and Common Agreement (TEFCA), and related supporting documents, in response to a requirement imposed by Congress in the 21st Century Cures Act. The Act says that the TEF may include a common method for authenticating users, a common set of rules, enabling policies, and a process for managing non-compliance. Nowhere does the Act instruct ONC to determine an actual technical architecture in this process, though such a step is not precluded either.

The primary document is in two parts: Part 1 is a set of principles that set the foundation for Part 2 which is a set if minimum terms and conditions for trusted exchange. While the principles seem overall quite reasonable, the terms and conditions have many, many technical specifications and standards embedded within them and lay the groundwork for a very specific nationwide implementation. Though the phrase “network of networks” appears nowhere in these documents, Part 2 seems to describe a technical implementation not too unlike the original NwHIN/eHealth Exchange model that was implemented with limited success a number of years ago. It does not appear that this model fits all that well with any of the major market-based strategies that have emerged in the past several years, notably the Commonwell Health Alliance, Carequality, or the Strategic Health Information Exchange Collaborative (SHIEC).