At the end of April 2025 the Centers for Medicare and Medicaid Services released the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes proposed rule. While most of this rather long proposed rule is not focused on public health issues, there are a few sections which do potentially impact public health data interoperability and standards.
CMS proposes adding an optional bonus measure under the Public Health and Clinical Data Exchange objective for reporting data to a public health agency (PHA) using the Trusted Exchange Framework and Common Agreement (TEFCA) beginning with the EHR reporting period in CY 2026. While the fate of TEFCA seems to be a bit uncertain given the reorganization of Health and Human Services (HHS) and the potential elimination of ASTP/ONC from the proposed FY2026 Federal budget, from a public health standpoint anything that helps to promote or facilitate interoperability between clinical care and public health seems to be a positive development. Of course, to be effective, more PHAs would themselves need to participate in a TEFCA-compliant network than do today.
Public health has been very active in the HL7 Helios Bulk FHIR initiative. The proposed rule is not mandating its use, the proposed rule asks some questions regarding experience with Bulk FHIR both for import and export of data. Remember, Bulk FHIR is also used for quality measure reporting which is incumbent on Medicare-participating clinical care sites but not PHAs.
Comments on this proposed rule, including answers to their requests for information, are due by June 10, 2025.