Initial deadlines are now fast approaching for the 21st Century Cures Act and the CMS Interoperability and Patient Access Final Rule—two legislative orders that, by establishing standard requirements around health data accessibility, transparency, and sharing, will turbocharge the decades-long push toward interoperability in healthcare.
Meeting these requirements has posed new challenges for healthcare payers, particularly in terms of the heavy lift required to clean, organize, and expose data for translation to FHIR standards. The regulations and deadlines themselves also presented something of a moving target in 2020, particularly due to the COVID-19 pandemic.
With that context in mind, it’s likely unsurprising that, in interviews with leaders from select organizations in late 2020, West Monroe found that simply meeting deadlines was the top priority, with about half taking a deadline-driven, sequenced approach. The primary concerns expressed at the time were around organizational readiness, with the majority expressing a limited sense of how new data sharing requirements would impact their end users, and none conveying overwhelming confidence in the state of overall operational readiness and training.
Today, with the deadlines firm and approaching, and the requirements augmented with tools and resources from CMS, health plans continue to be hard at work on planning, developing, and deploying new capabilities to achieve compliance with federal regulations and managing the organizational impact of those changes.
But the big question is: What’s next?
As we’ve detailed previously, simply “checking the box” to meet enforceable requirements in 2021 and early 2022 will be a significant missed opportunity to drive added value, both organizationally and across the larger healthcare landscape. We’ll take a deeper dive into this suggestion, outlining five ways payers might unlock value from interoperability requirements—and demonstrate why interoperability is important in healthcare.
1. Payer-to-Payer Data Exchange
CMS-regulated payers have until January 1, 2022 to establish FHIR-based APIs for exchanging certain patient health information to help create a cumulative health record. Doing this meaningfully requires a mindset shift. Relinquishing the view that member data is a health plan’s intellectual property—and enabling a transparent and accessible portability—will shift the competitive advantage toward those plans that are most adept at surfacing, analyzing, and sharing data.
The value opportunity
Greater transparency and efficiency, better data quality, more complete patient records.
The pandemic has demonstrated just how significant a functioning payer-to-payer exchange can be in burden reduction for providers and patients. As a recent article in the Harvard Business Review put it, “even though up to 96% of hospitals and 86% of physician offices have adopted [electronic health records], we still don’t have EHRs that can rise to the information challenges that clinicians face every day, let alone those posed by COVID-19.” What’s more, data has become siloed and healthcare professionals in one setting have no way to access all the patient data captured by another.
Claims data offers the most comprehensive view of a patient’s health status, history, and socioeconomic conditions. While there is work yet to be done around how prior authorizations will be handled as part of interoperability mandates, it follows that standardizing the payer-to-payer exchange of member health information presents a momentous opportunity for payers to enhance value-based partnerships, improve the breadth and accessibility of patient data, positively impact patient and provider experience measures, and support more the efficient delivery of quality care.
2. Innovative technologies and strategies
Many organizations have so far been focused on standardizing and centralizing data for FHIR API connectivity. As this foundation is being constructed, future-looking payers should explore innovative technologies and strategies for scale—such as adaptable integration patterns and robust data architecture and governance, managing digital servicing and engagement assets, and advanced analytics.
The value opportunity
Eliminating silos and preparing for data-mapping; improving data analytics and insights
Health plans should naturally be looking to leverage FHIR standards to make core processing adjustments that support effective data aggregation and the ongoing mapping of non-standard data. By design, of course, these practices will result in a higher volume of higher-quality data, which presents opportunities for improving data analytics and uncovering insights that were previously beyond reach.
Here, for instance, artificial neural networks and machine learning models can help illustrate population health trends and draw out critical insights. The information derived from the effective implementation of these new technologies can improve care management, delivery, and member experience.
It’s similar to what we’ve built at West Monroe, specifically for health plan organizations, leveraging our proprietary approach to Platform-as-a-Service (PaaS) along with Intellio® DataOps.
Embracing a human-centered innovation mindset
New technologies could lead to increased data security, faster processing, and downstream cost reductions. But they must abide by CMS rules, including requirements that payers share USCDI data they maintain with patients through the Patient Access API and with other payers in the payer-to-payer data exchange.
Blockchain technology, which creates a new avenue of secure, “trustless” data exchange, might offer the key to the truly interoperable system desired by regulators—one which provides patients with a secure, single source of truth for their healthcare data, without putting the responsibility for it on the consumer.
This is not just a development play. It’s a chance to rethink the payer operating model and integrate tech and business capabilities around regulation-driven data exchanges as well as product development and portfolio operationalization. Becoming a blockchain solution provider is a concrete way health plans can transform around technology as a means to achieving greater operating efficiency and cost reduction, as well as laying the groundwork for new revenue streams.