The Ultimate Guide to Adopting 21st Century Interoperability

Table of Contents

What is the ONC Interoperability Rule
(and Why Does it Matter)?

Although it has several monikers...

• 21^st Century Cures Act
• ONC Interoperability Rule
• The Final Rule
• ONC Final Rule
• CMS Final Rule

...the rule mandates that all patients have free and immediate access to the health information available in their electronic health record. Sounds good, right? Not if your organization is information blocking and doesn't even know it. If you are found to be information blocking (even inadvertently), you'll incur monetary penalties and enforcement actions, and delay your ability to do business with the Centers for Medicare & Medicaid Services (CMS).

On a positive note, compliance with the rules means increased data-sharing leading to better care coordination and quality outcomes – along with transparency increasing patient trust and satisfaction.

In a recent study,¹ 30 executives were polled from large health systems – primarily CFOs and revenue cycle VPs. The report found that 62% of respondents think the new CMS and ONC rule data-sharing requirement will boost care coordination and quality outcomes.

They also recognized the need to invest in consumer experience, and indicated plans to develop new online scheduling capabilities (70%), cost estimation apps (53%) and payment financing options (53%), according to the report.

¹ Phelps, A., Skalka, C., Gerhardt, W., & Chang, C. (2021, January 25). Greater transparency and interoperability in health care: Uncover strategic opportunities for health systems. Deloitte Insights. https://www2.deloitte.com/us/en/insights/industry/health-care/health-care-pricing-transparency-operability.html

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Who is Affected by the ONC Interoperability Rule?

Healthcare providers, health information networks, and health IT developers of certified health IT are mandated to ensure they comply by July 1, 2021. Beyond compliance, adopting 21st Century Interoperability uses the forward momentum of the industry to improve your infrastructure and how you do business for a better patient experience and return on investment (ROI), and with less provider burden.

Don’t fall behind! Healthcare providers do not want – and cannot afford – to scramble at each health IT regulatory step. Instead, they need to adopt a long-term plan to meet compliance deadlines and create a competitive edge to success in the future of health.

• Healthcare providers – You’re eternally busy doing the great work of caring for your patients, so you may not be aware of the information blocking rule and how it applies to your practice or organization. We appreciate that your main focus is on patients and not the business side of the practice. You feel constantly burdened by technology. You may need to bake in extra time for administrative tasks as a result of the new rules. It may require extra time to craft medical notes in a patient-friendly manner since they and other members of the patient’s healthcare team will have access to them. You may encounter a higher volume of patient questions if they are reviewing their medical records; while time consuming, the benefit is higher patient engagement. Some providers may feel concerned about getting paid for time spent on the EHR (documenting, answering patient questions, coordinating with the patient’s healthcare team, etc.). The new rules will not only reduce costs for the patient, but aim to reduce costs and waste for practices as well. We want to help you gain access to quality data and processes to better patient care and experiences, and collaborate further with payers and other provider organizations.
• Healthcare IT leaders (CIOs/CTOs/CMOs) – As a stakeholder in health IT, you work hard and bear a heavy load of overseeing your organization and its success. You may have expertise with provider and patient user experience with technology and systems. Your work encompasses clinical IT needs, infrastructure operations, infrastructure management, buying systems that comply to the rule, EHR vendor considerations, and more. You are likely aware of the information blocking rules but might think your current electronic health system (EHR) has it covered. During the transition to rule adoption, you may need to devote more time to supporting your staff, encouraging buy-in from them, training them, and allowing them additional time to devote to administrative tasks. You may also be focused on providing the appropriate platforms and wondering about any additional reporting requirements. We want to help provide clarity on what is being asked of you, and insights on your rights to fair technology access and prices.
• Health Information Networks (HINs) or Health Information Exchanges (HIEs) – This refers to people involved in the use of technology or services for access, exchange, or who use electronic health information between two individuals or entities that are enabled to exchange information with each other for a treatment, payment, or health care operations purpose.
  • EHR adjacent: registries, etc.
  • Those who have a need to understand systems affected by the rule and how they affect their systems
• Health IT developers of certified health IT – This refers to anyone who develops or offers health information technology. An objective of the new rule is to minimize application programming interface (API) development and maintenance costs in turn minimizing developer costs. The new certified API requirements focus on standardized datasets. Additionally, there are specifications in place allowing for the protection of the intellectual property of health IT developers.

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It’s Getting Real! ONC Rules are Here.

The future is here and if you do not take action now, your business will suffer (and the care you provide will too). The sprint to compliance is also a sprint to stay or become competitive in the marketplace, and doing nothing sets you back — making it harder to catch up. The fact is, we are collectively accelerating to compliance, so if you are moving at the same pace, you are moving backwards … and will be left behind.

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Your EHR Vendor Might Not Be Ready for ONC Interoperability Rule Compliance

You do not want to scramble at each health IT regulatory step but, instead, adopt a long-term plan that will help you meet deadlines and create a competitive edge to success in the future of health. Are you confident that your EHR vendor has set your organization up for success? How do you know? With so many nuances to the 21^st Century Cures Act information blocking provisions, it takes a robust understanding of the rules themselves and your systems to ensure you are in compliance.

It’s not as simple as it may seem on the surface, so don’t be lulled into a false sense of security that you’re compliant and have no liability, you may be inadvertently information blocking. Now is the time to work with objective experts and specialists in standards and interoperability to ensure compliance with 21^st Century Cures Act information blocking provisions and a create a roadmap to implementing 21^st Century Interoperability. It’s vital to uncover and identify your organization’s health IT needs and desires, as well as empower your organization with this competitive edge.

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Why Should Your Organization Prepare to Comply Now?

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21^st Century Cures Act Information Blocking Provisions Can Be Overwhelming

Providers and health IT leaders often operate in silos from other areas of healthcare IT. They are too busy with their extraordinary daily duties to recognize the nuances of how HIT provisions and standards can improve patient care and their bottom line. However, providers and health IT leaders who operate without awareness or education on the provisions will make expensive and obsolete decisions that affect their business long term when it comes to IT infrastructure, systems, tools, and more.

As the industry travels on CMS’ path for change, CMS has the power to turn interoperability infrastructure into something everyone knows about. A past example of this is electronic claim processing, which nobody really heard of until HIPPA, and then the industry adopted this practice as they were mandated to send insurance claims electronically. CMS’ plan continues to move forward, hitting milestones along the way, so providers and healthcare IT leaders can choose to:

Things are only going to get more interesting and complex as the years go by, especially if providers and healthcare IT leaders do not start complying now.

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Your Organization Could be Information Blocking Right Now. Yes, You.

A reactive approach to healthcare IT is about to cost you. Comply now to avoid penalties and enforcement actions for information blocking, and risk being behind the interoperability curve. Compliance with CMS and ONC’s new rules may feel like a burden, but when handled right, they can reduce some of yours. What’s more, information blocking goes along with Accountable Care Organizations (ACO) that have to report, and supports research and value-based payment models. There is potential for incentives tied to measurable improvements in patient care quality.

Some reasons why you’re in the dark:

• Lack of awareness. Most providers themselves are not aware that the rule deadline is approaching or what it is/means to them, and even healthcare IT leaders as they think their vendors are taking care of things. That’s how we can help. We want to arm you with information before you find out you aren’t in compliance or that there isn’t a plan in place.
• The ONC Interoperability Rule pairs with CMS, but is different from Meaningful Use. Meaningful Use, now known as “Promoting Interoperability,” is defined by the use of certified EHR technology in a meaningful way and enabling electronic health information exchange between healthcare providers, insurers, and patients. The goal of meaningful use is to improve quality of care and it is essential in the mission to advance patient care, data security, and the healthcare IT industry. There is urgency to comply with the ONC Interoperability Rule now given the upcoming start dates. The new rule is intended to reduce provider burden and democratize access to information. The foundation of the 21^st Century Cures Act is the patient, putting them in charge of their medical information and empowering them to be in control of their healthcare. In a modern health IT economy, the interoperability requirements implemented in this patient-centered Act are a step towards a value-based health care system. Other features designed within the 21^st Century Cures Act include medical cost and outcomes transparency, competitive medical care options, accelerated product development, and more convenient ways for patients to access their medical information faster and more efficiently e.g., through modern smartphone apps. An app economy not only benefits patients, but providers, hospitals, payers, and staff can benefit from this innovation and choice.
• There are new rules from the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health IT.
  • The CMS Hospital Price Transparency Rule and ONC's Cures Act rules around information blocking and patient access (which start to take effect in July) offer new growth opportunities for health systems. The CMS Hospital Price Transparency Rule states that by January 1, 2021, US-based hospitals are required to provide clear, accessible pricing information about the items and services they provide. The requirements state that hospitals must provide a comprehensive machine-readable file with all items and services and a display of shoppable services in a consumer-friendly format.
  • The CMS Interoperability and Patient Access final rule aims to enable patient access to their health information, improve interoperability, and promote innovation. What’s more, the rule’s approach to data exchange intends to do so in a way that reduces the burden on providers and payers.
  • Section 4004 of the Cures Act specifies certain practices that could constitute information blocking:
    • Practices that restrict authorized access, exchange, or use under applicable state or federal law of such information for treatment and other permitted purposes under such applicable law, including transitions between certified health information technologies (health IT);
    • Implementing health IT in nonstandard ways that are likely to substantially increase the complexity or burden of accessing, exchanging, or using electronic health information (EHI);
    • Implementing health IT in ways that are likely to—
      • Restrict the access, exchange, or use of EHI with respect to exporting complete information sets or in transitioning between health IT systems; or
      • Lead to fraud, waste, or abuse, or impede innovations and advancements in health information access, exchange, and use, including care delivery enabled by health IT.
      • If a claim of information blocking is filed against an entity, they may be investigated by the U.S. Department of Health and Human Services (HHS) Office of Inspector General.
  • The information blocking rule expands on meaningful use. It does this by allowing access to information for research, precision medicine, transfer of care, care coordination, and patient access to information. If the entity is found guilty of committing information blocking, they are subject to penalties. Health IT developers of certified health IT, health information networks, and health information exchanges in violation of the information blocking provision are subject to civil monetary penalties up to $1 million per violation and healthcare providers are subject to disincentives to be established by the Office. The information blocking provisions begin on April 5, 2021. Exceptions to the information blocking provision include reasons of preventing harm, privacy, security, infeasibility, health IT performance, licensing, costs, and content and manner.

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Your Source of Clarity for the ONC Interoperability Rule

It is important to work with experts who are continuously connected to the healthcare standards and the interoperability community for a roadmap to compliance and implementation guidance. At BookZurman, we have been part of creating and testing these rules in the federal sector and understand the nuances of the rule that may benefit you and help you achieve your business goals more holistically.

Unsure you’re information blocking? We can help.

We can help you feel relieved that there is someone out there who can provide clarity and a custom roadmap to compliance in time for the provisions to go into effect.

You can take comfort in trusting an objective partner who has been involved in the development in the federal sector, and is continuously connected to the HIT standards and interoperability community to help you comply and take advantage of efficiency and improvements in health information exchange. We have faith that with our help, you will be ahead with evolving rules and current communicated milestones, and not fall behind with additive requirements.

Take action by booking a discovery meeting with Team BZ experts to determine your compliance readiness for the 21^st Century Cures Act information blocking provisions.

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A Rare Opportunity For Expert ONC Rule Guidance

Team BZ has been a consistent, active leader in driving the state of healthcare standards with more than a decade of uninterrupted engagement with a specialized focus in the health IT community. Our leading position affords us an unparalleled expert-level understanding of the needs, desires, and requirements of the healthcare IT community. Collectively, our team has more than 100 years of healthcare/IT experience.

While the broader healthcare IT industry has been thinking about and planning for 21st Century Cures Act provisions to go into effect, we have been actively shaping the technical specifications that describe this infrastructure. We have been actively working on the specifications that describe what the interoperability infrastructure will look like in support of federal agencies. We are in a unique position to transfer this unique and valuable knowledge to provider organizations and healthcare IT leaders in the private sector. Our team has been creating specifications, testing to make sure the plans are implementable, piloting, and looking at issues coming down the pipe. We are involved in the nitty gritty details of what the interoperability infrastructure will do from a technical specification standpoint and have policy level contacts and the network to help providers and healthcare IT leaders with very nuanced and specific questions.

What’s more, BookZurman is an award-winning healthcare standards and interoperability consulting group helping bridge the gap between healthcare and technology for a better patient experience. Our industry-leading team of domain-specific subject matter experts brings an unparalleled breadth and depth of experience to government, industry and community partners to help their systems and projects stay ahead of the technology curve and maximize longevity and return for their IT investments.

As an educated organization adopting 21^st Century Interoperability infrastructure, Team BZ can help you:

• Address the holistic needs of your entire organization to provide comprehensive and permanent solutions, not just temporary labor and fixes
• Ensure compliance with 21^st Century Cures Act information blocking provisions.
• Influence the interoperability infrastructure triggered by the 21^st Century Cures Act and associated regulation including advancing the development of new FHIR API specifications intended for adoption according to ONC and CMS payment rules in coming years
• Engage with HL7, and other standards-related organizations and industry stakeholders to influence the direction of emerging interoperability specifications
• Advance medical records analysis for quality improvement

As an integrated provider of information technology and digital architecture consulting services, our core competencies include work in standards and interoperability, informatics architecture, clinical decision support, and terminology.

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Providing Leadership for CMS Final Rule Implementation

We have worked, since 1996, with government, industry and community partners, helping bring their systems and projects to the leading edge of healthcare IT. BookZurman has played a vital leadership role for similar health IT rules, such as the CMS Final Rule, including:

• U.S. Department of Health and Human Services (HHS), Office of National Coordinator for Healthcare Information Technology (ONC), FHA Active in development of ONC’s TEFCA
• Helped interpret MACRA
• Provided guidance on Meaningful Use (and all preceding policies)
• Led the charge to create the BPM+ Health initiative including origination and documentation of modeling workflow guidance

Created and evolved standards-based processes and systems:

• Service-oriented architecture
• EHRs/EMRs
• Terminology
• Medical devices

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Need Implementation Guidance for the ONC Interoperability Rule?

BookZurman has been contributing for over a decade to interoperability standards in health IT, working directly with the Veterans Health Administration to advise on development and implementation as a Service-Disabled Veteran-Owned Small Business (SDVOSB). Continuously connected to the health IT community, we provide industry leadership and active participation through leading-edge organizations and have played a vital leadership role for health IT rules and policy. 

We can:

• Engage at the highest levels of your organization to show value as a true strategic thinker, trusted adviser, and partner by providing unmatched, expert-level understanding of the needs, desires, and requirements of the healthcare community from the clinical and IT sides;
• Address the holistic needs of your entire enterprise to provide comprehensive permanent solutions, not just temporary labor and fixes;
• Share more than a decade of uninterrupted engagement with a specialized focus in the health IT community where we have been a consistent, active leader in driving the state of healthcare standards where our experts individually average 20-plus years of healthcare/IT experience; and
• Clearly demonstrate the benefits of standards-based work and enterprise architecture. This is how we are able to stay ahead of the curve and show real value for our advice and implementations. Our leading position affords us an unparalleled expert-level understanding of the needs, desires, and requirements of the healthcare IT community.

BookZurman can build the technology and infrastructure that will transform your healthcare delivery while saving you headaches and millions of dollars over time by working with an experienced and connected interoperability partner.

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Don’t Delay Preparing Your Organization for 21^st Century Interoperability

The Centers for Medicare and Medicaid Services (CMS) developed and are following a roadmap to compliance³, even if some areas are delayed. Are you prepared for what’s next? Below, we’ve outlined the major milestones in play. Updates occur yearly so it is imperative to become compliant as soon as possible in order to keep things from getting more and more complex, and to prevent you from falling further behind the curve.

³ Centers for Medicare & Medicaid Services (CMS). (n.d.). CMS Interoperability Roadmap: A Proposed Rule to Help Patients Access their Health Information. https://www.healthit.gov/sites/default/files/facas/2019-04-10_CMS_Presentation_508.pdf 

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Let's Talk Today

As an award-winning healthcare standards and interoperability consulting group, we can be your objective partner to bridge your gap between healthcare and technology for a better patient experience. 

Our industry-leading team of domain-specific subject matter experts brings an unparalleled breadth and depth of experience to government, industry and community partners to help their systems and projects stay ahead of the technology curve, and maximize longevity and return for their IT investments.

Discover how we can help your organization get closer to compliance and adopting 21^st Century Interoperability.

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