In March, The Centers for Medicare & Medicaid Services (CMS) released the proposed Stage 3 Meaningful Use rules, which focus on interoperability. While the healthcare industry has been cautiously supportive of this proposal, almost every public comment on the rules has carried suggestions for more clarity and more universal definitions of various types of data.
While the Meaningful Use program has been very effective at broadening practical use of electronic health records (EHRs), its major flaw from the beginning has been a lack of interoperability standards. The feds were trying not to be heavy handed, requiring specific functionality for certification as an EHR eligible for subsidies, but leaving much of the detail on how EHRs would work to the vendors.
The result has been a robust, complex EHR industry that has created data silos that are increasingly untenable. And the EHRs we have were created in a financial environment that rewarded episodic care. While EHR vendors are at least talking about interoperability standards, they are much more interested in improving their applications in ways that make them work better for the people who use them.
And the vendors don't really have a strong incentive to make their products interoperable. If anything, interoperability would commoditize their systems to some extent. By maintaining proprietary silos, they make switching difficult, which serves to maintain customer loyalty. So expecting the industry to take the lead on interoperability isn't realistic.
But putting those standards in the hands of the government also isn't perfect. With so much disagreement in the industry, CMS is reluctant to be too heavy handed or to move quickly. They are rightfully concerned about pushing fast on standards that may turn out to be less than perfect. Hence, the incremental improvements offered in the MU rules.
With so much money invested in EHRs and other clinical applications, none of which are interoperable to any real extent, interoperability may be a pipe dream. If you are a health system that has spent hundreds of millions of dollars and years of effort to implement an EHR and get your clinical staff to use it, implementing a new system that is interoperable might not be practical any time in the near future.
A detour that could get healthcare where it wants to go
But this roadblock might not, ultimately, be the disaster that it seems to be at the moment. Here's why. The healthcare industry is also moving vigorously toward outcomes-based payment models and increasing use of population health analytics and predictive analytics. These initiatives represent real progress toward a better healthcare system – one that values health instead of just treating illness. And these initiatives need reliable data from lots of sources to be effective, not just the data from EHRs. While interoperable EHRs would certainly simplify part of the task, you still have to integrate data from claims systems, social media, census data and many other sources that would not be interoperable with the EHR data.
So what do we do? We focus on why we need interoperability and then find another path to meet those goals. In short, we integrate the data. Rather than trying to get disparate systems to talk to each other, we create bridge between them that allows us to do several useful things. First and foremost, we can create a unified patient record. Second, we can share the data via a vendor-neutral platform that lets authorized individuals (the patient, family members and care providers) access the data. And we standardize the data so that it can be used in analytics.
This approach allows us to move forward immediately, rather than waiting on the EHR industry or the government to set standards. It may even turn out to be the perfect solution, because it replaces rigid standards with a flexible solution that can change as data needs change. And it is a solution that is fully baked now, not a goal we hope will come about.
In the meantime, we can all get behind the MU rules and move things forward, because interoperability would be a useful improvement. But we can also move beyond MU rules to focus on the ultimate goals of the program: Using data to better understand how healthcare can improve health, for individuals and for all of the world's people.