CMS rules are a fantastic step towards meaningful clinical interoperability

New conditions of participation requirements are an important step to achieving both the technical and clinical benefits of interoperability.

Modern medicine is extraordinary. It has a cure for Ebola, successfully treats previously incurable cancers, and has eradicated myriad diseases that previously terrorized entire nations. Infant mortality has declined more than 90%. Age-adjusted mortality has dropped to below 10 per thousand. Life expectancy has increased by thirty years. Healthcare has improved, from a clinical perspective, in nearly every conceivable way.

One area that has not meaningfully improved is clinical interoperability—how we coordinate care across disparate members of a care team of extraordinary practitioners spanning multiple organizations. Medical advances have led to increased specialization, but with that increase have come all sorts of communication barriers that make it difficult for care teams to stay aligned. Some organizations, like Kaiser Permanente and Intermountain Healthcare, have solved for this by brining all care providers under the same tent. But for the majority of healthcare in the country, that hasn’t been feasible.

There is a disconnect between individual members of a patient’s care team. And how couldn’t there be when downstream providers are generally unaware when their patients visit the hospital or other care settings? We expect primary care physicians (PCPs) to quarterback a patient’s health. But how can they call the right plays if they don’t even know who their teammates are or where their patient is?

If we continue to expect PCPs to be the principal stewards of care for our communities, they need to know where their patients are and why. But in a sea of other health IT needs, this has largely gone unaddressed. Until now.

Last month, the Centers for Medicare and Medicaid Services released the highly anticipated Interoperability and Patient Access final rule as part of the 21st Century Cures Act. The rules update existing conditions of participation (CoP) and require all hospitals—including psychiatric and critical access hospitals—to send ADT notifications to primary care and other downstream providers.

Hospitals need to set up a system—by themselves or through an intermediary—after the rule is published on the federal register.

Moving in the Right Direction

I’m delighted that these rules were passed and the implications they’ll have on the future of healthcare in this country. They’re a meaningful step forward in achieving both technical and clinical interoperability and will continue to aid the positive transformation of care delivery and patient outcomes.

By facilitating the sharing of clinical data between different providers and care settings, the rules ensure that even though there are stakeholders who represent different organizations, all can operate from the same playbook as though they were on the same team. Because in reality they are, in fact, on the same team. They might have different titles and different organization names on their ID badges, but in that moment, they all care for one, single patient.

With so many moving pieces, the rules drive alignment across care teams enabling each provider to pick up exactly where the last left off—eliminating medically unnecessary or duplicative workups, unnecessary expenses and wasted time.

Letting Technology Do Its Job

The CoP requirements ask hospitals to make a set of standard demographic information and identifiers available to each patient’s established providers—be it primary care, post-acute or their own practice group. That’s it. For now, hospitals aren’t being asked to provide metrics of any kind; they just need to implement a system and start sending notifications.

So, while the requirements aren’t incredibly strenuous, they still saddle hospitals with several burdens. First, in many cases hospitals likely don’t know every member of their patients’ care teams. They may have established provider relationships within their community, but what happens if there are other providers outside of their state? How can you send information to people you don’t know exist? Then, if hospitals can locate these providers—how do they pass ADT notifications securely and in a way that doesn’t compromise patient health information? Both of these problems feed into the last: hospitals have a very short runway to figure this out and implement a system on their own.

Luckily, hospitals aren’t in this alone—they can implement such a system using an intermediary (like Collective). Health IT intermediaries are positioned to do this much more quickly and accurately because they already have the infrastructure to locate every person on a patient’s care team and securely push clinically relevant patient info between care settings—and they’ve been helping care teams across the country do exactly that, long before the CoP requirements were released.

By going through an intermediary who can help hospitals fully comply with the new CoP requirements, they’ll be able to focus on their patients that matter the most.

Collectively Caring for the Whole Patient

The rules are the gateway for sharing a lot more information much more proactively. When downstream providers are kept in the loop on where their patients are and why—the whole care team can respond as one entity. Some states, like Oregon, are ahead of the curve in terms of leveraging clinical collaboration and interoperability to better serve patients and the community. Several years ago, Oregon had the foresight to implement a statewide ADT-based network—connecting all of its hospitals and many of the state’s ambulatory facilities and other downstream providers, including skilled nursing facilities—and they have benefited tremendously from doing so.

Oregon’s statewide health IT infrastructure has made exceptional improvements to ED utilization. According to a recent report published by the Oregon Health Leadership Council (OHLC), Oregon has seen a statewide reduction in avoidable ED visits from patients with patterns of high utilization by 11.2 percent across 2018. During this same time period, ED visits fell by 31 percent in the 90 days following development of an initial care guideline.

All in all, the CoP requirements are a huge step in the right direction, and these new rules mark a turning point in our healthcare system in regard to how we collectively think about and manage patients. As a patient myself and as a father of four kids, I think the rules are phenomenal, and I’m truly looking forward to this new era of complete clinical interoperability where health IT intermediaries and care teams can truly operate as one.

Chris Klomp is the CEO of Collective Medical. Collective delivers the leading ADT-based nationwide network for real-time care collaboration.


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