Why You Need to Care Now About the ONC Interoperability Rule

The Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC) 21^st Century Cures Act program rule on Interoperability, Information Blocking, and the ONC Health IT Certification are happening.

Healthcare providers, health information networks, and health IT developers of certified health IT are mandated to ensure they comply with the ONC Interoperability Rule. Interoperability means that typically siloed health IT systems are now expected to work together.

These new rules mean increased data-sharing leading to better care coordination and quality outcomes – along with transparency increasing patient trust and satisfaction.

But, if an organization is information blocking (even inadvertently), they may incur monetary penalties and enforcement actions, and even a delay in their ability to do business with CMS.

This post will focus on what the 21^st Century Cures Act is, and what each of the rules surrounding the issue are. A featured topic will be the differences between the new rules and Meaningful Use.

What is the ONC Interoperability Rule?

The ONC Interoperability Rule mandates that all patients have free and immediate access to the health information available in their electronic health record. Adopting 21^st Century Interoperability uses the forward momentum of the industry to improve infrastructure and how organizations do business resulting in an improved patient experience and return on investment (ROI) with less provider burden.

Many organizations are seeking insight and a plan on how to implement the new rule and to ensure that they are in compliance. It is important to work with objective standards and interoperability experts who are continuously connected to the healthcare community for a roadmap to compliance and implementation guidance.

At BookZurman, we understand the new policy, the complexities of the standards, and the technology that enables those standards. We have been part of creating and testing these rules in the federal sector and understand the nuances of the rule that may benefit organizations and help them achieve their business goals more holistically. BookZurman can build the technology and infrastructure that transforms an organization’s healthcare delivery while saving them time and money by working with an experienced and connected interoperability partner.

Why is the ONC Interoperability Rule Important?

The new rule benefits all stakeholders:

• Patients will have access to their health information and cost transparency to be better equipped to make choices about their health
• Providers and healthcare IT leaders can be educated consumers of 21^st Century Interoperability – making them key players who can influence the future of health IT while improving their infrastructure, avoid civil monetary penalties and enforcement actions, reduce operating costs, increase productivity, secure CMS revenue, and avoid losing a competitive edge in the marketplace.

Ignoring the rule could lead to penalties and enforcements, leave organizations behind the interoperability curve, and make them less competitive in the marketplace.

Tips and Reminders About the ONC Interoperability Rule

Though the ONC Interoperability Rule couples with CMS, it differs from Meaningful Use.

• Meaningful Use is using certified EHR technology in a meaningful way and enabling electronic health information exchange between healthcare providers, insurers, and patients. Meaningful Use aims to improve quality of care, advance patient care, data security, and the healthcare IT industry.
• The ONC Interoperability Rule has already started and deadlines are right around the corner so there is an urgency to comply now. The new rule is intended to reduce provider burden and democratize access to information. The basis of the 21^st Century Cures Act is the patient, putting them in charge of their medical information and allowing them to drive their healthcare choices. The interoperability requirements implemented in this patient-centered Act are a step toward a value-based health care system in a modern health IT economy. Additional pieces within the 21^st Century Cures Act include medical cost and outcomes transparency, competitive medical care options, accelerated product development, and more convenient ways for patients to access their medical information faster and more efficiently e.g., through modern smartphone apps. The innovation and choice of an app economy benefits patients, providers, hospitals, payers, and staff.
  • The new rules from the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health IT encompass the CMS Hospital Price Transparency Rule and ONC's Cures Act rules around information blocking and patient access. The new rules offer new growth opportunities for health systems. The CMS Hospital Price Transparency Rule states that by January 1, 2021, hospitals in the U.S. were required to provide clear, accessible pricing information about the items and services they provide. The requirements assert that hospitals must provide a comprehensive machine-readable file with all items and services and a display of shoppable services in a consumer-friendly format. The CMS and ONC Interoperability and Patient Access Final Rule seeks to enable patient access to their health information, improve interoperability, and promote innovation. Furthermore, the rule’s approach to data exchange aims to execute these mechanisms in a manner that reduces the burden on providers and payers.

Expanding on Meaningful Use, the information blocking rule:

• Allows access to information for research, precision medicine, transfer of care, care coordination, and patient access to information.
• Aims to eliminate practices that restrict access to health information and health information exchanges, and practices that implement health IT in a way that makes access to health information and health information exchange too challenging or leads to fraud, waste, or abuse.
• Subjects health IT developers of certified health IT, health information networks, and health information exchanges found guilty of committing information blocking to penalties—civil monetary penalties up to $1 million per violation, and healthcare providers are subject to disincentives (to be established by the Office). So, if a claim of information blocking is filed against an entity, they may be investigated by the U.S. Department of Health and Human Services (HHS) Office of Inspector General.
• Has several exceptions including preventing harm, privacy, security, infeasibility, health IT performance, licensing, costs, and content and manner.

What Can You Do to Comply?

Organizations can avoid civil monetary penalties and other enforcement actions by complying with 21^st Century Cures Act information blocking provisions and preparing systems for future-enabled interoperability immediately. Specifically:

• Adopt industry standards and automation to reduce operating costs and improve margins.
• Prepare systems for compliance now instead of scrambling when compliance is urgent, and resources are not be available to retool infrastructure. This will save time and increase productivity.
• Take advantage of incentive payments and other CMS-based reimbursement opportunities and MIPS incentives. Certification of non-information blocking enables you to secure CMS revenue/rates and value-based payment qualifications. Find out more here:  
• Comply now to avoid risks of falling behind the interoperability curve, including losing a competitive edge in the marketplace.
• Take advantage of forward momentum in the industry and available interoperability to improve IT infrastructure and streamline systems and processes.

BookZurman Can Help

An award-winning, healthcare standards and interoperability consulting group, BookZurman can be your objective partner to bridge the gap between healthcare and technology for a better patient experience. Our industry-leading, domain-specific subject matter experts bring an unparalleled breadth and depth of experience to government, industry and community partners to help systems and projects stay ahead of the technology curve, and maximize the longevity and return of IT investments.

Find out how we can help your organization get closer to compliance and adopt 21st Century Interoperability.

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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.