Due to COVID-19, CMS has delayed enforcement of the Patient Access and Provider Directory APIs of its FHIR-based CMS-9115-F final rule by six months, from January 2021 to July 2021. So, while there\u2019s a little more breathing room, don\u2019t wait \u2013 those six extra months will go by fast. You really need to address the deadline \u2013 now.<\/p>\n
Just before the pandemic hit, the Centers for Medicare & Medicaid Services (CMS) released final rule CMS-9115-F that covered Interoperability and Patient Access. A major requirement of the final rule \u2013 Patient Access \u2013 says that Medicare healthcare payers holding patient information must do the following:<\/p>\n
Failure to do the above could be construed as \u201cinformation blocking\u201d \u2013 and could open payers up to hefty civil monetary penalties.<\/p>\n
\nPeople really like having access to their health data. CMS created the \u201cBlue Button\u201d in 2010 for Medicare beneficiaries to download their claim data. Since then, patients have pressed the Blue Button more than one million times. CMS\u2019s new, improved Blue Button 2.0 is an API that contains four years of Medicare data for 53 million people.<\/p>\n<\/blockquote>\n
But all of this isn’t required until July. Wait\u2026that\u2019s not far off.<\/strong><\/h4>\n
You’re right. It\u2019s almost here. CMS adopted the HL7 Fast Healthcare Interoperability Resources (FHIR) data API standards framework into its Interoperability and Patient Access final rule \u2013 and it comes into force July 1, 2021.<\/p>\n
Unfortunately, we\u2019ve seen the payer industry fall into two general categories:<\/p>\n
\n
- Those that are medium\/smaller, with fewer and\/or swamped IT resources unable to take on the requirements of the Interoperability and Patient Access final rule.<\/li>\n
- Larger organizations in which bureaucracies and approval levels haven\u2019t fully come to terms with the immediacy of CMS-9115-F (or believe that market forces will result in another delay).<\/li>\n<\/ul>\n
In either case July 1, 2021 is coming fast. Did we mention hefty potential civil monetary penalties?<\/p>\n
Okay \u2013 we know the deadline is approaching. Do we panic?<\/strong><\/h4>\n
No \u2013 not just yet. As with many business solutions, you will generally have the \u201cbuild or buy\u201d scenario. As far as building, at a minimum you\u2019ll need to know if your swamped IT staff can do the following (sorry, it\u2019s a bit techy):<\/p>\n
\n
- Become technical experts on FHIR V4 API and resource specification, including resource profiles<\/li>\n
- Determine which of the more than 140 FHIR APIs and dozens of resource types you need to implement for mandate compliance<\/li>\n
- Design an appropriate consent model for your patients and tie that in with your web properties and OpenID\/OAuth-based security infrastructure<\/li>\n
- Design and deploy an audit infrastructure that you can use to defend against potential \u201cinformation blocking\u201d complaints<\/li>\n
- Determine how you are going to deal with data quality issues that propagate from your existing data sources<\/li>\n
- Deal with bi-directional data synchronization of data in a multi-source data scenario<\/li>\n
- Create all the mappings for all the FHIR APIs and Resources that you\u2019re going to need to map\/transform to\/from HL7<\/li>\n<\/ul>\n
Given the complexity and the time frame, perhaps buying is the way to go.<\/p>\n
What to ask about if you\u2019re buying<\/strong><\/h4>\n
There are a number of FHIR-related solutions that can meet your compliance needs out there, so be sure you know what you\u2019re getting into. Some questions to ask a potential provider:<\/p>\n
\n
- Is it tech-vendor neutral? That is, is it viable on the platform that works best for you, or is the provider locked in? For example, AWS versus IBM Cloud or Azure.<\/li>\n
- Can you migrate the solution easily between cloud, on-prem and hybrid models?<\/li>\n
- Can one deployment function for multiple backend health record systems?<\/li>\n
- Will is work securely through the Internet on its own, versus requiring you to buy into expensive VAN-like infrastructure?<\/li>\n
- Will it scale as your needs change?<\/li>\n
- Will it work with the technology you already have?<\/li>\n
- Can it be tailored towards broader FHIR usage, or is it just an \u201cout-of-the-box\u201d solution for CMS-9115-F compliance?<\/li>\n
- Does it have data quality capabilities to deal with data quality issues before those issues are propagated outside of your data perimeter?<\/li>\n
- Will it audit your end-to-end FHIR data flows as a defense against potential \u201cinformation blocking\u201d complaints?<\/li>\n
- If you want, will the provider run it for you as a managed service?<\/li>\n<\/ul>\n
So, there\u2019s a lot to think about \u2013 and get implemented \u2013 by July 2021. Don\u2019t wait \u2013 the CMS deadline is on its way.<\/p>\n
Prolifics can help<\/strong><\/h4>\n
Prolifics offers you our Quick FHIR solution that will jumpstart your FHIR initiative and CMS compliance. Our solution is built on leading technology that accelerates FHIR adoption. Quick FHIR deployments are end-to-end solutions built to each unique client\u2019s requirements, from CMS-9115-F compliance to FHIR as the backbone of your organizations data strategy. We\u2019ll guide you in a rapid, comprehensive implementation across your enterprise. You can start your Quick FHIR journey with a no-cost workshop. Learn more from our brochure, Quick FHIR for CMS Mandate Compliance<\/a>, and email\u00a0solutions@prolifics.com<\/a> to get going.<\/p>\n
[For complete information, check out Prolifics guide to FHIR<\/a>.]<\/p>\n
Talk with us<\/strong><\/h4>\n
You have a vision for your organization \u2013 don\u2019t let your technology slow you down. Our Quick FHIR solution and experience will get you there. Sit down with us \u2013 let\u2019s talk about your challenges, review and reevaluate your plans and get you started where it makes the most sense. Vision to Value. Faster.<\/em> It\u2019s not just our tagline, it\u2019s what drives us. It\u2019s how we deliver solutions and services. It\u2019s our commitment to you \u2013 and it\u2019s needed today more than ever. Visit www.prolifics.com<\/a> or email solutions@prolifics.com<\/a>.<\/p><\/p>\n","protected":false},"excerpt":{"rendered":"
Due to COVID-19, CMS has delayed enforcement of the Patient Access and Provider Directory APIs of its FHIR-based CMS-9115-F final rule by six months, from January 2021 to July 2021. […]<\/p>\n","protected":false},"author":34,"featured_media":29498,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"content-type":"","footnotes":"","_links_to":"","_links_to_target":""},"categories":[49],"tags":[],"class_list":["post-3387","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-blog","has-post-title","has-post-date","has-post-category","has-post-tag","has-post-comment","has-post-author",""],"acf":[],"builder_content":"","_links":{"self":[{"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/posts\/3387","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/users\/34"}],"replies":[{"embeddable":true,"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/comments?post=3387"}],"version-history":[{"count":0,"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/posts\/3387\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/media\/29498"}],"wp:attachment":[{"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/media?parent=3387"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/categories?post=3387"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/prolifics.com\/usa\/wp-json\/wp\/v2\/tags?post=3387"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}