We have spent years involved with the management of the Center for Medicare and Medicaid Services (CMS) Electronic Health Records (EHR) Incentive Programs which were created by the HITECH Act (2009). These programs were recently renamed Promoting Interoperability (PI) programs. In a nutshell, these programs were tied to the Medicare and Medicaid insurance programs and provided financial incentives over a number of years to ambulatory providers and hospitals to adopt and use EHRs. Vendors submitted their technology products for testing and certification that they performed specific functions and could exchange data using specified message formats.
In November 2019 the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) released a new report, Top Management and Performance Challenges Facing HHS. Divided into six major sections, this report reviews the OIG’s observations with respect to financial integrity of HHS programs, value and quality, protecting the health and safety of beneficiaries as well as the public at large, harnessing data to achieve these goals, and working across government.
The Trust for America’s Health (TFAH) released its 2019 edition of what it hopes will be an annual report, Ready or Not: Protecting the Public’s Health from Diseases, Disasters and Bioterrorism last February. The ground-breaking report warns about key global challenges ahead, like the risk of a flu pandemic; the impact of weather pattern changes due to climate change; the dangers of antimicrobial resistance, and others, and tries to offer advice on how to prepare for them.
In Section 1 of the report, titled Health Threats: A Review of 2018, the authors review a litany of disease outbreaks, and severe weather and natural disaster events. They note the incidents, actions, and corresponding research findings, meetings, and events related to each. On the policy front, they note the September 2018 release by the White House of its National Biodefense Strategy (see earlier article on this topic). The Centers for Disease Control and Prevention (CDC) released another report, Public Health Emergency Preparedness and Response Capabilities, in October 2018 (updated in January 2019). This section of the TFAH report also reviews the various activities of the Blue Ribbon Study Panel on Biodefense.
|See our final comments on the TEFCA v2 Draft|
On April 17, 2019 the Office of the National Coordinator for Health Information Technology (ONC) released the second draft of its Trusted Exchange Framework and Common Agreement (TEFCA) for comment. The initial version was released more than a year ago in January 2018 (see my original blog). As before, this is in response to a requirement imposed by Congress in the 21st Century Cures Act. After a somewhat lengthy (but well written) introduction, the document contains three parts (compared to just two parts the first time around):
|See our final comments on the ONC NPRM and the CMS NPRM Patient Matching RFI|
On February 11, 2019 the Office of the National Coordinator for Health Information Technology (ONC) released its latest Notice of Proposed Rulemaking (NPRM) to Improve the Interoperability of Health Information. Referred to by some people as the “Information Blocking NPRM,” since this was the primary topic anticipated, the document actually covers a host of other topics related to interoperability driven primarily by requirements of the 21st Century Cures Act. Besides the initial text of the NPRM, ONC also released a set of summary slides and fact sheets to help explain the document.
Given the relatively minimal mention of core public health reporting certification criteria in this NPRM, there is still a fairly large potential impact on public health. Topics, descriptions, issues, impacts, and potential opportunities discussed in this article and associated documents are based on our careful read of the NPRM and related material. But please note that this information is voluminous and at times confusing. Ongoing discussion and review will attempt to clarify (and if necessary correct) initial ideas presented here.
In order to help focus the reader, I have prepared a detailed table of Public Health Issues, Impacts, and Opportunities (currently at Version 15) which will be updated periodically, as well as a separate detailed response to the ONC Patient Matching RFI and CMS Patient Matching RFI.