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Washington Debrief: Stakeholders Call for Patient Data Matching, Data Fluidity Action

August 18, 2014
by Jeff Smith, Senior Director of Federal Affairs
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Jeff Smith, Senior Director of Federal Affairs

Top News

Stakeholders to Senate Leaders: Action Needed on Patient Data Matching, Data Fluidity

Key Takeaway: CHIME was one of many healthcare associations to respond to the Senate Finance Committee’s stakeholder letter dated July 12, 2014, concerning digital health data availability and use.

Why It Matters: The letter signed by Chairman Ron Wyden (D-OR) and Senator Chuck Grassley (R-IA) received a wide range of input from industry groups pertaining to increasing health data fluidity and usability. Many of the health IT-focused associations mentioned the need for a national patient matching strategy before the issue of health information exchange can rectified in addition to the need for comprehensive Medicare payment reform.

On July 12, 2014 the Senate Committee on Finance released a stakeholder letter soliciting feedback on four questions concerning digital health data. The four questions were:

  1. What data sources should be made more broadly available?
  2. How, in what form, and for what purposes should this data be conveyed?
  3. What reforms would help reduce the unnecessary fragmentation of healthcare data? What reforms would improve the accessibility and usability of healthcare data for consumers, payers and providers?
  4. What barriers stand in the way of stakeholders using existing data sources more effectively, and what reforms should be made to overcome these barriers?

CHIME’s comments, submitted on August 12, called on Congress to support the concept of a longitudinal healthcare record as a way to prioritize policy challenges. CHIME’s comments focused on the need to:

  • Further develop data standards and robust testing requirements for certified EHR technology and other components of health IT referenced in federal policies, including HIEs;
  • Adopt a national patient matching strategy; and
  • Harmonize privacy laws to reduce burdens on providers that want to exchange data.

Other health IT stakeholders also weighed in. For example, the Healthcare Information and Management Systems Society (HIMSS) called for a careful balance to be struck between protecting the patient’s privacy, security and safety; the patient’s ability to control their own data; and the ability of the healthcare system to aggregate de-identified data for the greater good. The HIMSS Electronic Health Records Association (EHRA) insisted that a nationwide patient data matching strategy remains one of the most critical unresolved issues preventing health information exchange, citing that patients often have medical records in multiple locations, including hospitals, physician practices, laboratories, pharmacies and other settings across states. The American Medical Association (AMA) called for the targeted release of health data, including details around specific conditions, procedures and issues to enable physicians and patients to better understand quality and performance. The American Hospital Association (AHA) requested additional data be made available concerning inpatient hospital discharges, Medicare Advantage enrollees, Medicare Part B carriers and Medicare Part D prescription drugs.

It is expected that Senate leaders will use stakeholder feedback to determine and prioritize future legislation, although nothing specific is expected before the end of the current session of Congress.

Administration

Implementation Workgroup to Recommend Constrained C-CDA

Key Takeaway: According to the Implementation Workgroup (http://www.healthit.gov/facas/calendar/2014/08/11/standards-implementation-workgroup), the current consolidated-CDA required for Stage 2 certification has too much variation and data does not integrate into EHRs, despite the requirement for physicians to exchange health history for at least 5 percent of patients.

Why It Matters: Members of the Implementation Workgroup are concerned about the usability of data contained within the current release of C-CDAs and worried that providers and hospitals may start to drop out of the Meaningful Use Program if the technical functionality is not improved.

The standards for the Consolidated-Clinical Document Architecture (C-CDA) were created by HL7 and adopted by and the Office for the National Coordinator for Health IT (ONC) for Stage 2. The C-CDA includes things like vitals, orders, prescriptions, lab notes and discharge summaries. Unfortunately, certification for this element was designed around the creation and transport of a C-CDA rather than the reception and integration of the patient data. While this infrastructure was supposed to allow for flexibility to create documents for care coordination, the workgroup believes that physicians cannot digest all the information and health history provided within the document, and patients often cannot interpret the complex information presented.

To improve the C-CDA’s usability, the workgroup plans to recommend constraining the document to include less variation and thus would enable EHR developers to design interoperable products based on the revised standards. They also will call for the publication of conformance tools “to optimize and validate real-world instances of CCDA.” And they also will recommend the creation of another workgroup to review the challenges addressed by the Implementation Workgroup. The workgroup will present their draft recommendations to the Health IT Standards Committee (http://www.healthit.gov/FACAS/calendar/2014/08/20/hit-standards-committee-virtual) at this week’s meeting on August 20. They expect to finalize the recommendations by the end of the month.

Meaningful Use Amendments and EHR Certification Changes in Final Stage of Review

Key Takeaway: The White House’s Office of Management and Budget (OMB) is examining final rules from CMS, on Meaningful Use flexibility in 2014, and ONC, regarding technical and policy updates related to 2014 Edition Certified EHR Technology (CEHRT).

Why it Matters: Both rules have tremendous implications for health IT executives. The Centers for Medicare and Medicaid Services (CMS) rule will determine what flexibilities will be offered to providers in meeting Meaningful Use requirements in 2014, and it will decide the reporting requirements of the program in 2015. The ONC rule will likely update certain 2014 Edition certification criteria, create new paths of certification for “non-MU” EHR technology and sunset certain provisions.

Two important rules are at the final stage of review before being made final. The CMS rule will likely provide new pathways for providers to meet Meaningful Use in 2014, based on a provider’s inability to implement 2014 Edition CEHRT. And a rule published by ONC will likely make a number of technical and policy updates to the 2014 Edition itself. Both rules will have up to 60 days of review at OMB, but both rules are expected to be finalized sooner. CMS officials have indicated they wish to have their rule published by Sept. 1, 2014, and ONC’s rule will likely publish shortly thereafter.

CHIME News & Notes

CHIME Responds to Two Congressional Requests Concerning Digital Healthcare Data

Key Takeaways: The interest in the digital healthcare landscape among members of Congress is growing. Just this summer, the House Energy & Commerce Committee released a white paper and held a hearing on “Digital Health,” while the Senate Finance Committee requested comments on the fluidity and availability of health data.

Why It Matters: Throughout the 113th Congress, members of the House and Senate have demonstrated an increased level of interest in health information technology and the digital healthcare landscape. Topics including mobile medical applications to telemedicine, information blocking and the meaningful use program have appeared in Congressional white papers, stakeholder feedback letters and hearings.

In the House

On June 17, 2014, the House Energy and Commerce Committee’s 21st Century Cures Initiative released a white paper on “Digital Health.” To accompany the white paper, the Communications and Technology Subcommittee and the Subcommittee on Health held a joint hearing on July 17 entitled, “21st Century Technology for 21st Century Cures.” Interoperability was among the many issues discussed during the hearing. Lawmakers expressed interest in cost barriers to health IT adoption and interoperability, and panelists agreed on the need for the right payment models and standards to drive the development of interoperable systems.

CHIME submitted comments to the 21st Century Cures digital health-focused whitepaper on July 21. The recommendations included in CHIME’s comments addressed the following issue areas:

  • Standards adoption and harmonization;
  • Cross-agency alignment and prioritization of digital health; and
  • Research and development.

The intention of the 21st Century Cures initiative, launched by Chairman Fred Upton (R-MI) and Representative Diana DeGette (D-CO), is to solicit suggestions for a healthcare transformation bill to be drafted by December and voted on in the next session.

In the Senate

On August 12, CHIME submitted comments in response to stakeholder letter signed by Senate Finance Committee Chairman Ron Wyden (R-OR) and Senator Chuck Grassley (R-IA) concerning health data availability and fluidity. CHIME’s comments highlighted the need to:

  • Further develop data standards and robust testing requirements for certified EHR technology and other components of health IT referenced in federal policies, including HIEs;
  • Adopt a national patient matching strategy;
  • Harmonize privacy laws to reduce burdens on providers exchanging data; and
  • Enable patients to engage in their longitudinal health record.

CHIME’s Congressional comments were consistent in emphasizing the need for strengthened data standards and rigorous testing requirements for certified EHR technology as well as the need for a national patient matching strategy.

Edited for style by Gabriel Perna


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