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, Certification, and ePA: Proceed with Caution

By Hans Buitendijk (Oracle Cerner), EHRA Chair

This is part one in a four-part series examining the need for electronic prior authorization (ePA), the barriers presented by the current environment, necessary capabilities and functionality, and the EHR Association’s policy recommendations.

The prior authorization process required by health plans and payers frustrates patients and providers alike because of inconsistent requirements and associated delays, and it isn’t going away. 

It is clear that there is an opportunity to apply health information technology (IT) toward the goal of improving efficiency in this area, but doing so will be a challenge that requires significant cross-stakeholder coordination and standardization of related data. The need for a collaborative focus is further exacerbated by the widely varying approaches to the adoption and deployment of health IT systems among providers. Further, the process itself touches many different points and players in administrative, clinical, and financial workflows. 

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Genomic Data Sharing Policies Must Protect Patient Privacy, Minimize Risk

By Michael Saito (Epic), Chair & Nam Nguyen, (Allscripts) Vice Chair, EHRA Privacy & Security Workgroup

The National Institutes of Health’s (NIH) ongoing objective of sharing research data sets to facilitate additional study is something EHRA member companies wholly support – as long as it protects patient privacy, ensures patients can provide informed and meaningful consent for use of their data, and minimizes the risk that patients’ genomic and other health data can be re-identified or misused. 

To that end, we took advantage of the NIH’s recent Request for Information (RFI) on the proposed updates to and long-term considerations for its Genomic Data Sharing (GDS) Policy to provide feedback in the key areas of de-identification, potentially identifiable information, and data linkages.

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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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TEFCA Signals Progress, With Work To Be Done

By EHRA Public Policy Leadership Workgroup

After a journey more than four years in the making, the Office of the National Coordinator for Health IT (ONC) and The Sequoia Project achieved a major milestone in the advancement of nationwide health information exchange: the publication of the Trusted Exchange Framework and Common Agreement (TEFCA) v1.0. ONC and The Sequoia Project have demonstrated their commitment to incorporating input from stakeholders across the industry, which created a process that produced significant improvements with each draft publication. We applaud the significant efforts undertaken by ONC and The Sequoia Project to collaborate with industry interoperability experts and create a framework that incorporates key principles of trusted exchange, like reciprocity, as well as a technical approach that leverages commonly adopted standards. 

For well over a decade, members of the Electronic Health Record Association (EHRA) have invested substantially in advancing the data sharing capabilities of the health IT systems used by healthcare organizations across the country with the belief that doing so will improve the quality and efficiency of health care. It is our sincere hope that TEFCA will continue to build on those investments for the benefit of patients.  

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