HHS Releases RFI on Interoperability and HIE

HHS Releases RFI on Interoperability and HIE

HHS, CMS and ONC have released a Request for Information (RFI) seeking input on policies and programs to encourage health information exchange (HIE) through interoperable systems.  Although the Medicare and Medicaid EHR Incentive Programs and other federal efforts are rapidly increasing the adoption of standards based HIE and EHR technology,

This alone will not be enough to achieve the widespread interoperability and electronic exchange of information necessary for delivery reform where information will routinely follow the patient regardless of wheter they receive care….

The overarching goal is to develop and implement a set of policies that would encourage providers to routinely exchange health information through interoperable systems in support of care coordination across health care settings.  

HHS therefore seeks comment on several options for encouraging HIE among providers and settings of care through a hodge-podge of existing statutory vehicles (primarily CMS and ONC programs and projects). In addition to requesting comment on these existing vehicles, CMS and ONC seek to identify what is currently working to encourage HIE, and which changes would have the biggest impact on HIE adoption, including regulatory requirements.

Furthermore, although long neglected under the EHR Incentive Programs, CMS and ONC specifically seek comment on what policies and programs would have the most impact on post-acute and LTC care providers as well as behavioral health.  They ask for insight into how these programs and policies should be implemented and developed to maximize care coordination and quality improvement for these populations. In addition, CMS and ONC specifically seek comment on policies and programs which would most impact patient access and use of their electronic health information for management of their care.   

Post-Acute and Long-Term Care Providers.  HHS acknowledges the low rates of EHRs and HIE among LTC and post-acute care providers and identifies existing authority which could be leveraged to expand HIE.  These include incorporating HIE as key components of:

1. Medicaid health homes;
2. Demonstration and pilot projects under Medicaid and the Childrens Health Insurance Program (CHIP);
3. Home and community based services (HCBS), which would include LTC;
4. State expansions of HIE infrastructure as part of the Medicaid EHR Incentive Program, and
5. CMS Conditions of Participation or Coverage

Settings of Care.  HHS additionally acknowledges the need to accelerate HIE across providers, including ambulatory care, behavioral health, laboratory, and post-acute and LTC. For example, HHS seeks comment on:

1. New e-specified measures for exchanging summary records following transitions of care aligned with CMS quality reporting programs, including the EHR Incentive Programs;
2. Medicare Shared Savings Program, requiring or encouraging Accountable Care Organization (ACO) to engage in HIE as part of coordination of care;
3. Payment and service delivery model testing under the Affordable Care Act, such as demonstration of use of interoperable technology for HIE to facilitate model participation decisions and requirements;
4. Model testing to align Medicare and Medicaid financing and care integration under the Capitated Financial Alignment model.

Consumer and Patient Engagement.  HHS and CMS seek to encourage engagement of patients in their care by improving their access to health information and electronic communication between their health care providers.  Options to encourage consumer and patient engagement include:

1. Incorporating new measures into Medicare Advantage Program consumer assessment serveys (CAHPS);
2. Blue Button availability to all CMS beneficiaries;
3. Payment and service delivery model testing under the Affordable Care Act, such as demonstration of incentives for consumers to more actively participate in their health; and
4. Direct access to lab results from laboratories (CLIA and HIPAA Amendments).

The RFI will be published today in the Federal Register.  Comments may be submitted up to 5pm on April 22, 2013.