ONC Needs to Address HTI-1’s Burdens on Healthcare Providers, Health IT Developers

By David Bucciferro, Chair, EHR Association

While the EHR Association has long supported the goals of ONC’s proposed rule to advance interoperability, improve transparency, and support further access, exchange, and use of EHI, we have several serious concerns about the impact HTI-1 (ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule) will have on the industry if finalized as proposed. 

Among the most significant are the insufficient implementation timeframes associated with various concepts included in HTI-1 and a failure to accurately consider the significant burden compliance would place on both provider organizations and health IT developers. Vendors need more time than proposed in HTI-1 to accommodate the substantial lift required to deliver safe, compliant, and high-quality versions of their certified products – 18-24 months is the commonly accepted necessary timeframe – while providers need sufficient time to implement, test and become proficient on that upgraded software. 

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Good Information Sharing Practices Released

By Leigh Burchell (Altera Digital Health), Vice Chair, EHRA Information Blocking Compliance Task Force

The EHR Association is committed to preventing information blocking and supporting efforts to share electronic health information to better patient care. As such, our Information Blocking Compliance Task Force collaborated over the past two years with stakeholders across the industry to address regulatory questions and further information exchange.

Our collaboration has produced “Good Information Sharing Practices,” a collection of best practices for health IT developers. The Practices are a practical list of proactive actions health IT developers can undertake to demonstrate their strong support for access, use, and exchange of health information and compliance with information blocking regulations. These include detailed recommendations on:

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Standards will Make or Break Efforts Toward ePA

By Janet Campbell (Epic), EHRA Public Policy Leadership Workgroup Vice Chair

This is part two in a four-part series examining the need for ePA, the barriers presented by the current environment, necessary capabilities, and functionality, and the EHR Association’s policy recommendations. Part one can be read here.

Streamlining the electronic prior authorization (ePA) process will require significant coordination and standardization across multiple domains within individual healthcare organizations, across dozens of health plans covering their patients, and across the health IT tools in use by every participant in the process.

Progress is being made by various stakeholders in terms of standards development. Notably, the Coverage Requirements Determination (CRD), Documentation Templates and Rules (DTR), and the Prior Authorization Support (PAS) implementation guides – all a part of the Da Vinci Project’s efforts to understand functional requirements, build consensus on a technical approach, pilot, and iterate – have resulted in significant progress toward the enablement of highly automated prior authorization workflows.

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“No Surprises Act” Regulations Raise Concerns

By Leigh Burchell (Allscripts), Chair, & Janet Campbell (Epic), Vice Chair,
EHRA Public Policy Leadership Workgroup

The growth in high deductible health plans requiring patients to shoulder more of their healthcare costs and the lack of transparency in healthcare pricing has exacerbated the issue of patients left with surprise medical bills that many cannot afford to pay. The urgent need to address these serious issues is why the EHRA supported the No Surprises Act when it was developed and welcomed the regulations published last year as a foundation upon which it can be implemented. 

However, we have several concerns about rulemaking to date as it relates to workability and the unnecessary burden it creates for industry stakeholders. To that end, we reached out proactively to regulatory agencies to provide feedback in four key areas that we believe – based on our member companies’ experiences and our ongoing advocacy for reasonable timelines and requirements – will be informative when it comes to additional regulatory actions expected later this year. 

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The USCDI Curation Process: Why Stratify?

By John Travis and members of the EHRA Information Blocking Task Force 

In our last blog on the United States Core Data for Interoperability (USCDI), the focus was on USCDI as the policy ground for advancing federal interests for promoting high impact needs for health data, and USCDI’s import as a certification specification impacting developers of Certified Health Information Technology (CHIT). In this blog, we focus on how the evolution and curation of USCDI impacts the efforts of health IT developers and implementers to “stay current.” 

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The Balance Challenge for Policy in Progressing the U.S. Core Data for Interoperability (USCDI)

By John Travis and members of the EHRA Information Blocking Task Force

 

With publication of the 21st Century Cures Act: Interoperability, Information Blocking , and ONC’s Certified Health IT program final rule (Cures Act Final Rule), the Office of the National Coordinator for Health IT (ONC) worked to implement important provisions of the 21st Century Cures Act (Cures Act) for nationwide interoperability. The initial proposal from ONC addressing the Trusted Exchange Framework and Cooperative Agreement (TEFCA), which was also required by the Cures Act, created a central role for the U.S. Core Data for Interoperability (USCDI) in federal health IT policy, and it is important to consider what that role will be in the national policy framework. Will the USCDI push the industry beyond where it would go on its own by being progressive in its version expansion? Will it affirm and codify an extension of the current state, adhering to a principle of expansion based on supporting pre-requisites of already established interoperability standards? Or something in between?

In recent deliberations of the USCDI Task Force of the Health Information Technology Advisory Committee (HITAC), the Federal Advisory Committee established under the Cures Act, this tension point has come to light. The members of the task force seem to have two perspectives on the matter. 

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