5 CIOs predict challenges with HHS' upcoming interoperability rules

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HHS' new interoperability rules will go into effect April 5, but health IT departments at hospitals across the nation are unsure how smoothly their compliance processes will go.

Below, four CIOs and one chief medical information officer from health systems around the country predict possible challenges that could present themselves once the rules go into effect.

Editor's note: Responses have been edited lightly for clarity and style.

Julie Hollberg, MD. Chief Medical Information Officer at Emory Healthcare (Atlanta). I think the most challenging piece is going to be if and when we are asked for large amounts of data from other agents. Emory started practicing open notes and releasing all clinical documentation improvement elements last fall. We want our patients to be empowered with their data and are excited about increasing the information on the patient portal.

Zafar Chaudry, MD. Senior Vice President and CIO at Seattle Children's. Even though EMR systems are more usable and readable now, different platforms will require different standards and approaches for true interoperability. 

Getting healthcare information systems to communicate in a predictable and secure way will be a continuing problem. Getting healthcare information systems’ vendors to play in a collaborative way with each other, even with the rules, will remain a risk.

Billing/documentation have traditionally been the drivers for EMRs; this has resulted in complex usability issues, which still remain. 

Patient privacy may still be at risk when healthcare information is transferred outside of an organization.

Joel Klein, MD. Senior Vice President and CIO at University of Maryland Medical System (Baltimore). It’s a huge step forward in communication and engagement to open documentation up widely to patients. Being able to read the exact words in a medical chart has the potential to put patients and providers closer to the same shared vision of the problems they’re trying to solve together. 

The challenge for providers will be to make sure their tone and language choice can simultaneously resonate with patients, improve health literacy and convey the necessary clinical detail. In other words, there will be a lot more people reading our words, and we have to be thoughtful about how they will be received. 

Audrius Polikaitis. CIO and Assistant Vice President of Health Information Technology at UI Health (Chicago). Whereas I am thoroughly supportive of the interoperability rule and its intent, I am concerned that this demand is being placed upon healthcare delivery organizations while we are still in the context of a pandemic. Thankfully, COVID-19 positivity rates, hospitalization rates and mortality rates are all declining, however now we must have extreme focus on getting our communities vaccinated. And as we know vaccination rates are definitely not where we had hoped that they would be. 

The expectation of interoperability rule compliance at this time feels tone deaf. Of course, one can always argue that compliance has already been delayed and that there is never a good time, however I really don’t see any immediate harm to further delay compliance until vaccination rates have been improved.

In my view, a great challenge is understanding the nuances of the 21st Century Cures Act requirements and then properly interpreting these requirements. The interoperability rule is not prescriptive and leaves the detailed interpretation of the rule and its eight exceptions up to each healthcare organization. We are trying to find that balance between the risk of information blocking and potential risk of patient harm through premature release of information. And, of course, we will only find out whether we have struck the proper balance when the Office of the Inspector General gets involved to investigate a claim that we engaged in information blocking.

2021 interoperability is limited to the United States Core Data for Interoperability data set, which typically is all contained within our EHR systems. However, in 2022, the interoperability requirement is extended to all electronic health information, which can originate from EHRs, diagnostic systems, imaging platforms, etc. It is yet completely unclear how we will comply with these requirements. There is much more fun to come.

Ash Goel, MD. Senior Vice President and CIO at Bronson Healthcare (Kalamazoo, Mich.). The intent of the interoperability rules is certainly meaningful and relevant. Empowering patients and caregivers to receive timely access to their own information goes a long way in helping them advocate for themselves. The concerns are mostly centered around how this comes with a responsibility to educate our communities and stakeholders as consumers of this data to enable data privacy and have informed discussions on responsible use of such data. 

In addition, healthcare delivery organizations are coming at it from several and sometimes very different points of view. The rules and regulations suggest a certain ambiguity that will need to be resolved. I believe that over the next few months and years, we will be in a better position to know if it promotes interoperability as intended or commercialization of this data in silos that helps few.

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