Understand the opportunities and risks to drive engagement and growth
Interoperability seeks to remove barriers and breakdown silos to facilitate the exchange of health information, while still protecting individual privacy. The goal is to ensure that healthcare IT systems can improve their ability to exchange, process and interpret shared health information between devices, applications and systems across the entire healthcare landscape. It also aims to drive innovation and new entrants and ultimately, to build a more connected, consumer centric healthcare system.
As consumerism, innovation and value-based care increase, consumers desire easy access to their health records and want to know their data is protected. The seamless and secure access, exchange and use of protected consumer health data has become increasingly important.
The Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC) finalized rules to address this. The ONC Cures Act Final Rule and CMS Interoperability and Patient Access Final Rule aim to eliminate barriers to health information interoperability and put individuals in control, shifting the industry from one in which you may share data in accordance with HIPAA, to one in which you must share data at the behest of the individual.
The implementation timeline requires rapid mobilization and execution. Among several other new capabilities, the rules will require providers and payers to share personal health data with consumers through application programming interfaces (APIs) based on Health Level 7® (HL7) Fast Healthcare Interoperability Resources® (FHIR) Release 4.0.1 as a foundational standard.
Leading health systems are capitalizing on regulatory mandates to amplify and evolve their consumerism strategy. Key considerations to take your interoperability program to the next level:
Interoperability requirements and impacts:
Interoperability’s aim for a more seamless data exchange can reduce redundancies and gaps that patients, providers and payers face.
The result? A more productive, coordinated, safe and accurate patient experience that enables providers to access data from disparate sources to more holistically understand the patient’s medical history and inform treatment decisions. Fewer hospital losses and clinical errors can reduce costs and increase industry margins for payers, with greater likelihood of retaining consumers.
The implications of interoperability span across industry stakeholders. Payers and providers need whole organizational responses to prepare for the changing regulatory environment, with key consideration towards: the right leadership, a review of business partnerships and agreements, new processes and data needs.
How should we define, refine, align and monitor our interoperability program? How do we get buy-in and alignment?
Program management to coordinate cross-functional delivery teams, decision making and escalation, and performance tracking.
Support and execute the interoperability program and implement change management, in coordination with use case delivery, to help drive awareness and organization alignment
Program management to coordinate with cross-functional delivery teams, IT, risk, compliance and business, decisions making and escalation and performance tracking
Establish a core management function that can inventory and coordinate all of the in-flight projects affected, new projects needed, and any dependencies, synergies across the portfolio, and risks
Align on an integrated work plan, a delivery method, and ways of working can provide both flexibility and visibility across all projects and teams
Interoperability requires buy-in and commitment from all business areas. Policies, processes, and procedures will have to be updated.
Both employees and customers will have to be educated on the benefits—and the risks—of sharing data, whether among providers and payers or among patients sharing data with third-party apps.
The introduction of new business activities and third-party developers will require new processes and workflow changes to comply with regulations and develop additional business value
Multiple functions will certainly have roles in measuring and monitoring adoption, performance, and compliance.
What underlying technical capabilities/platform do we need to make interoperability a reality (e.g. data ingestion, integration and sharing considerations, including controls and infrastructure)?
The Interoperability Rules rely on the precedents of HIPAA and HITECH, along with a patchwork of state laws, in order to address the privacy and security considerations which are illustrated below. Further, organizations must understand the broader implications of the Interoperability Rules and their impact on current capabilities.
Health Services Consulting Solutions leader, PwC US
Principal, Health Services Payer, PwC US
Principal, Health Services Cybersecurity & Privacy, PwC US
Partner, Health Services Risk and Regulatory, PwC US