In the year 2019, the Proposed Interoperability rules were released from ONC and CMS, and the final version of these rules was published in March 2020. While there were some changes implemented based on comments received, largely the new rules kept a lot of the original requirements along with the timelines for implementation.
- Although not required by CMS, use of the referenced Implementation Guides on the CMS web site is encouraged. The challenge here is that some of those implementation guides are still not finalized. For example, the CARIN Blue Button and CPCDS Implementation Guide still need to reconcile comments to Standard for Trial Use ballots (STU1).
- CMS finally has provided guidance on Clinical Data, and the news is good for payers. Only clinical data elements listed in the United States Core Data for Interoperability (USCDI) that are structured data need to be shared for the Patient Access API.
- The more payers can curate the clinical data, the easier it will be for third party applications to use and display it to members in a meaningful way. Having aggregated normalized and de-duplicated data is the key to enabling the ability to payers pass clean data to an API vendor.
- Health plans need to make sure that they, or their vendor partners, capture and share the provenance data with the third-party apps. They should also be educated on the payers website and as part of its member portal that provides clear information on what members should do if their information isn’t correct.
- For payers, it’s as important to focus on the operational impacts of the CMS rules as it is on the technology used to comply with them. By focusing on these non-technical considerations as they move to implementation, the process will become much more seamless.