By John D’Amore, MS, President and CTO of Diameter Health
Prepare for a data deluge. Stage 3 of Meaningful Use will provide unprecedented access and interoperability of clinical information in electronic health records. In this article, we highlight several key considerations of the new proposed regulation for health information technology, published here on March 20, 2015.
Data access and interoperability have been consistent goals of Meaningful Use since its inception, but currently most users and developers of health information technology are not satisfied. A recent survey found that many accountable care organizations (ACOs) are struggling with access to and integration of data from disparate sources. These barriers become more acute as ACOs add new health information technology platforms and build out their network of medical providers in varied clinical settings. Moreover, a federally commissioned study concluded that Meaningful Use Stages 1 and 2 have not achieved robust interoperability for clinical use, research, or patient access.
The new regulation takes an aggressive and refreshing stance to liberate clinical data. It does this in three ways: 1) strengthening testing of health information technology, 2) opening up access through improved tools and new application programming interfaces (APIs), and 3) empowering payers to push for standardized data.
While prior stages of Meaningful Use adopted specific interoperability standards, a 2014 research project I contributed to found gaps in the capabilities of certified products. This research, which was directly cited in the rule, found that content and completeness of digital care summaries varied significantly among EHR technologies. Since variations among the hundreds of certified products weren’t publicly known between vendors, developers and users, they became barriers to automated information exchange. The new rule addresses these challenges in two ways. It requires certified products be tested for interoperability against a reference, or “gold standard,” and that the output of certified products be publicly disclosed as part of certification. These procedures will substantially strengthen the quality and transparency of information exchange among certified technologies.
Next, the federal rule critically examines feedback on data portability and access of electronic health records. One complaint highlighted in the rule is that if a nurse or physician needs to contact a vendor to activate functionality for medical record exchange, this technology violates the intent of Meaningful Use. Federal regulators have clearly articulated that information access and exchange should be easy and obvious to end-users. Additionally, the rule takes a critical step in allowing for programmatic access to health information through APIs. This will enable authorized developers of new health information technologies to access data without human intervention. Just like Mint, a tool that aggregates and analyzes personal financial information today, software will soon be capable of querying and consolidating clinical information for the improvement of patient care, therapy adherence and provider communication. While the rule explicitly states that FHIR (Fast Health Interoperability Resource) is optional in required APIs, it mandates that the data be available through the C-CDA (Consolidated Clinical Document Architecture), which is the document summary already in use for Stage 2 of Meaningful Use.
Finally, the rule cites a chilling and compelling statistic. Over $45 billion annually, more than the Meaningful Use program in its entirety, is paid by Medicare for medical care that was medically unnecessary or insufficiently documented. Much of this excess could be examined digitally if medical records could be exchanged in a rapid, reliable and common format. This led regulators to include requirements for what is known as the “electronic submission of medical documentation” (esMD Initiative) to help identify and reduce excess costs by federal payers. Presumably private payers will also use this new capability of electronic health records. The esMD initiative uses the C-CDA as the basis for extracting medical data from electronic health records, which will make requests using this standard incredibly common.
In total, the term “C-CDA” appears over 100 times in the federal rule, and the alignment between stronger testing, improved tools and APIs, and empowered payers will make this standard the workhorse of interoperability. If you haven’t learned about the standard, now is the time to start. Hold on tight; the coming years will open the floodgates of health data, and when we arrive at calmer waters, we will look back and acknowledge Stage 3 was when the deluge began.
About the Author: John D’Amore, MS, is President and CTO of Diameter Health and Editor on the C-CDA standard. He has over a decade of experience in health IT and medical informatics. John was previously Vice President at Allscripts, a leading vendor for electronic health records. Before then, he has served as a health industry consultant and Director of Decision Support at Memorial Hermann, winner of the 2009 National Quality Forum award. John is a published researcher and national speaker on the use of interoperability and analytics to improve clinical care. He holds an undergraduate degree from Harvard University and graduate degree in clinical informatics from the University of Texas, School of Biomedical Informatics.
About Diameter Health
Diameter Health offers service and software solutions using interoperability standards for healthcare organizations seeking to improve their clinical and operational performance. Specifically, Diameter Health has developed tools to asses C-CDA document quality and normalize its clinical data for improved care. For more information, please visit the website www.diameterhealth.com or contact the company at firstname.lastname@example.org.