HIMSS to ONC and CMS: Open APIs key enablers for innovation, competition
HIMSS has published its comments – sent separately to the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health IT – on their respective proposed rules on interoperability, patient access to health data and information blocking.
Feedback for ONC: Dial back definition of EHI for now, require FHIR v4
HIMSS, the parent organization of Healthcare IT News, says it supports the aims of both agencies' regulations, but has concerns about some specific aspects of each.
For instance, in 74 pages of comments sent to ONC, the group said it agrees with the information blocking exceptions carved out for certain stakeholders in the rule, and said that by establishing appropriate "boundaries and expectations" they'll enable more widespread information exchange.
But HIMSS told National Coordinator for Health IT Donald Rucker, MD, that it wants some supplementary information from ONC, such as a list of best practices for sharing more information, consistent with the exceptions included in the proposal.
"Such a list could serve to reinforce the positive behaviors expected of the regulated actors, establishing 'safe lanes' for specific use cases and reducing compliance costs and risks," officials noted, and could "help communicate more detailed information around the intended roles and expectations for each of the regulated actors, developers, providers, or networks/exchanges."
HIMSS also wants ONC to dial back its definition of "Electronic Health Information" in the rule – staying more closely aligned, in the near term, with the specifications set forth by the U.S. Core Data for Interoperability data classes.
But going forward, the organization hopes to see USCDI bolstered with additional data classes, such as social determinants of health, patient-generated and wearables data, genomics and cost and price information.
The agency should adopt HL7's recently-unveiled FHIR Release 4 in the final rule for reference, said HIMSS officials, and should require developers to "build, test, and certify systems solely to FHIR R4 and its associated implementation specifications" before they're certified by ONC.
HIMSS applauded ONC's focus on APIs, and its efforts to ensure that patient data be accessed and put to use "without special effort." It also opposed the idea any pricing practices that "create barriers to entry and competition for apps that healthcare providers seek to use."
HIMSS to CMS: API requirements good, but slow down on trusted exchange regs
In a separate eight-page letter sent to CMS Administrator Seema Verma about that set of rules, HIMSS expressed support for proposals to require open API use for Medicare Advantage organizations, state Medicaid and CHIP fee-for-service programs, managed care plans and others on the federally-facilitated exchanges.
"Making patient information more readily available will enable patients to better understand their healthcare cost, and offer provider organizations and researchers the opportunity to deliver very real value in efforts to foster better outcomes for patients and decrease unnecessary cost expenditures across our healthcare system," officials said.
But HIMSS also cautioned that CMS should slow the timeline for the requirement that private payers participate in trust exchange networks for more widespread interoperability. While it supports the idea behind that proposal, the group recommended that CMS wait on such mandates "until the structure and requirements around the TEFCA are more clearly defined and enacted."
It also voiced support for CMS publicly calling out any organization that doesn't play by the rules with regard to information blocking and use of electronic health information undermines efforts to improve interoperability, since, "this transparency should help contribute to greater information sharing."
'Opportunities for innovation'
In his letter to Dr. Rucker, HIMSS CEO Hal Wolf said the organization commends ONC for its work putting "our health system and stakeholders on a path to transform healthcare."
On the whole, ONC's proposed rules "set a course for a healthcare paradigm that takes full advantage of the promise of standards-based API technology, and capitalizes on the inherent opportunities for innovation and makes allowances for encouraging new market entrants," said Wolf. "HIMSS appreciates the opportunity to help HHS create a new healthcare ecosystem that reinforces the secure access to, exchange of, and use of EHI."