5 Reasons You're Not Ready for the ONC Rule

If you haven’t heard, there is a new provision to the 21^st Century Cures Act in regard to interoperability, information blocking, and the Office of the National Coordinator for Health IT (ONC) Health IT Certification Program. Healthcare providers, health information networks, and health IT developers of certified health IT are required to implement the new rules by the deadline. Initial deadlines have been delayed given the Covid-19 pandemic impact on the industry, but the 21^st Century Cures Act is still happening.

So, What is the ONC Interoperability Rule?

The new 21^st Century Cures Act ONC Final Rule provision is comprised of penalties against information blocking, and updates to the Health IT Certification Program to enhance interoperability of Electronic Protected Health Information (ePHI).¹ Organizations are required to adopt the United States Core Data for Interoperability (USCDI) standard and standardized application programming interfaces (APIs). Health data must be securely and seamlessly exchanged and accessed in a way that is convenient.

These new regulations put us all in this together making information ready for consumption and sharing . In the past, there were no specifications in interoperability rules for organizations to adopt a particular healthcare data standard. Now that there are, it brings a common good. Executives and decision makers need to be educated that this new rule is a requirement and provides them with an opportunity to use the forward momentum of the industry to enhance and upgrade their interoperability, along with thinking ahead with your vendors and all of the other benefits to your organization. Think about it like this. If you have a working TV but want to upgrade to streaming, you may have trouble making a case for why you need it. However, if there are rules that require streaming, it makes it easier to incorporate into your overall plan for enhancing your system.

Things to Consider:

• Are you connecting the need to avoid information blocking with the need to be interoperable? This new approach to interoperability is not backwards compatible, and it’s vital to ensure that your desire to share data connects to your overall interoperability needs.
• Don’t fall into the trap of thinking that because restful APIs are part of the plan, and your team is good at web systems, that you should be ok. The complexity of the data you have to exchange may increase, and capabilities you’ve had in the past may not be enough to cover the new requirements.
• Data that your organization has to exchange must be able to not only keep up with current requirements – but likely future growth. The ONC rules address only minimum data required for interoperability.
• Deploying these APIs may allow you to meet the current requirements, but may not be useful to your organization. Make it work for you. Worry about data meeting the minimum set of requirements of the country and stakeholders in your ecosystem.
• It is not enough for your system to be capable, it also needs to have staff available to change organizational behavior so there is a collective understanding that collecting this information is important and why. Governance and training for internal teams to evolve will be needed.

Here are the Five Reasons You May Not Be Ready for the ONC Rule:

1. Do you understand the new 21^st Century Cures Act ONC Final Rule and what is being asked of you as a healthcare provider, health information network, or health IT developer?
2. Do you know where your organization fits within the provisions and what you need to do to make sure you are compliant?
3. Do you know your organization's level of interoperability maturity and compliance readiness?
4. Do you know if your current practices are inadvertently information blocking?
5. Have you reviewed your business agreements regarding your information blocking liability and asked your technology vendors how they plan to comply with the new regulations?

Need Help?

We’re here! A consulting firm that bridges the gap between healthcare and technology, BookZurman can help you understand the new 21^st Century Cures Act ONC Final Rule and what is being asked of you. We can help your organization discover where your organization fits within the provisions and what you need to do to avoid penalties. We can help assess your organization's level of interoperability maturity and your compliance readiness for the future. And we can prepare you for conversations with your third-party technology vendors to discuss how they plan to comply with the new regulations.

Learn more about how this rule can affect you and your organization.

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BookZurman’s team of multidisciplinary, highly specialized experts continue to drive progress and innovation in the healthcare IT community. For more information on this and other work in the areas of standards and interoperability, informatics architecture or clinical decision support, follow us on Twitter and LinkedIn.