Could RFI Signal New Health IT Directions for CMS and ASTP/ONC?
The Assistant Secretary for Technology Policy/Office of the National Coordinator for Health IT has been unusually quiet since the transition to the new administration, with few if any public announcements made, and no new national coordinator named. Steve Posnack, a longtime ONC exec, is serving as interim assistant secretary/national coordinator. Rumors tend to fill an information void and there have been rumors circulating online that ONC could be downsized and/or folded into the Centers for Medicare & Medicaid Services. Likewise, informational calls around progress on TEFCA by the Recognized Coordinating Entity have been cancelled so far this year.
CMS and ASTP/ONC, however, recently put out a Request for Information (RFI) with a series of questions that may signal what they plan to emphasize in the next few years. Perhaps the fact that the RFI comes from both CMS and ASTP/ONC lends credence to the idea that they could be combined or at least that they will work even more closely than in the past.
This RFI focuses on the market of digital health products for Medicare beneficiaries as well as the state of data interoperability and broader health technology infrastructure.
Interestingly, there are quite a few questions about what is needed to get patients/caregivers to sign up and use digital identity credentials. Expect to see work in that area to develop more momentum in the digital health app space.
The RFI will probably cheer executives and startups in the value-based care realm. As the intro to the RFI makes clear, “the transition to value-based care (VBC) represents a cornerstone of CMS’ strategy to incentivize improvements in health outcomes rather than increases in service volume. The role of technology is critical to this transformation.”
CMS and ASTP/ONC says that there are opportunities to better align technology requirements with the needs of providers participating in alternative payment models (APMs) and other value-based care programs. One of the areas they are asking about involves how certified electronic health record (EHR) technology (CEHRT) requirements can enable value-based care and meet statutory requirements while meeting other program objectives.
The RFI asks: “What incentives could encourage APMs such as accountable care organizations (ACOs) or participants in Medicare Shared Savings Program (MSSP) to leverage digital health management and care navigation products more often and more effectively with their patients?”
Fans of FHIR API adoption requirements and Bulk FHIR will also be encouraged by the number of questions focused there.
The RFI asks how CMS could better encourage use of open, standards-based, publicly available APIs over proprietary APIs and how a nationwide provider directory of FHIR endpoints could improve access to health information for patients, providers, and payers.
Among the Bulk FHIR questions: What would be the benefits and downsides of using Bulk FHIR data exports from EHRs to CMS to simplify clinical quality data submissions? Can CMS reduce the burden on providers by performing quality metrics calculations leveraging Bulk FHIR data exports?
The RFI also asks how interested payers and providers are in EHR technology advances that enable bulk extraction of clinical quality data from EHRs to payers to allow them to do the calculations nstead of the provider-side technology.
Also with a focus to payers, the RFI asks: How can CMS encourage payers to accelerate the implementation and utilization of APIs for patients, providers, and other payers, similar to the Blue Button 2.0 and Data at the Point of Care APIs released by CMS?… and what would be the value to payers of a nationwide provider directory that included FHIR end points and used digital identity credentials?
The RFI suggests the possibility of creating stronger links between interoperability and quality reporting efforts so that investments can be dually purposed. It asks if there are requirements CMS should consider for data registries to support digital quality measurement in a more efficient manner, and if there are requirements CMS should consider for data registries that would support access to real-time quality data for healthcare providers to inform clinical care in addition to simplifying reporting processes.
Proponents of TEFCA and health information exchange organizations, however, might be less excited by the tone of the questions. The RFI asks “How is the Trusted Exchange Framework and Common Agreement (TEFCA) currently helping to advance patient access to health information in the real world?” and asks for specific examples. It also asks, “Are there adequate alternatives outside of TEFCA for achieving widespread patient access to their health information?”
Maybe I am reading too much into these questions. But the answer to the first question is that it probably hasn’t been around long enough yet for very many organizations to be able to provide specific examples of benefit. And what will the CMS reaction be if most respondents answer the second question in the affirmative?
The RFI also asks: What is the ongoing role of HIEs amidst other entities facilitating data exchange and broader frameworks for data exchange (for example, vendor health information networks, TEFCA, private exchange networks, etc.)?
The section on interoperability ends with this question: “Given operational costs, what role should CMS or ASTP/ONC or both have in ensuring viability of healthcare data sharing networks, including enough supply and demand, that results in usage and outcomes?”
To me, the tone of all these questions suggests an acceleration of work done in the previous administration on FHIR and APIs, an increased focus on getting patients into value-based care arrangements, an interesting connection between data needed at the point of care, quality reporting and interoperability capabilities, as well as a stronger effort to foster the development of a digital health marketplace. It will be interesting to see the responses of stakeholders, including the EHR vendors. I would say the direction on TEFCA still seems unclear.
