Continuing the Interoperability Journey—Three New Opportunities for HIM

Healthcare interoperability is a team sport, and information technology (IT) professionals aren’t the only players in the game. Professionals with heath information (HI) management skills, experience, and leadership also fill valuable interoperability roles.

The deep knowledge of privacy, health data integrity, and electronic protected health information (ePHI) is desperately needed to successfully continue the interoperability journey. Whether HI professionals serve in provider, payer, or vendor roles, they are important players.

Several interoperability milestones are planned for 2022 that HI professionals should know. This article lays out upcoming applicability dates and provides valuable insights for how HI professionals across domains can add their voices and expertise to the interoperability conversation.

What’s Ahead for 2022

The next six months hold particular significance for healthcare interoperability and health data sharing. What started nearly two decades ago with regional health information exchanges (HIEs) has evolved into an inexorable force for good under the Cures Act and the CMS Interoperability and Patient Access Final Rules. The act and its associated final rules set the guidelines for healthcare’s new path: easier patient access to medical records and nationwide sharing of health information.

As champions of access to health information through the release of information (ROI) function, HI professionals must be part of the interoperability team. Through the HI team’s involvement, patients realize many positive benefits of secure electronic health information exchange. Here’s what is ahead for 2022.

Beginning on October 6, 2022, the specific health data elements that can be shared expand beyond today’s current limit of the United States Core Data for Interoperability (USCDI) data set. USCDI is defined by the Office of the National Coordinator for Health Information Technology (ONC) as a standardized set of health data classes established by the ONC for nationwide, interoperable health information exchange. Beginning October 6, 2022, an actor will be required to share and exchange the “full definition” of electronic health information (EHI). ONC has defined EHI as “ePHI to the extent that it would be included in the designated record set, regardless of whether the group of records are used or maintained by or for a covered entity.” The EHI can be shared with the patient or their directive in the electronic form and format requested including via an API. Certification to EHI export capability by health IT developers is expected by December 31, 2023.

Second, the ONC is now placing greater emphasis on information blocking compliance. As he stated during recent ViVE and HIMSS22 conferences, Micky Tripathi, national coordinator for health IT (ONC), confirmed that compliance with the information blocking rules is one of the top five ONC goals for 2022. Tripathi also referred to the information blocking provisions of the Cures Act Final Rule as “information sharing” regulations placing the onus for sharing on providers, payers, and vendors.

According to Tripathi, information sharing is an obligation. Actors under the Cures Act Final Rule EHI cannot interfere with information sharing unless one of seven narrowly construed exceptions apply. Enforcement of the rules of health IT developers, health information networks, and health information exchanges will be conducted by the OIG. Under the Cures Act, providers are subject to “appropriate disincentives.” While the OIG has suggested that it will conduct investigations related to allegations of information blocking by providers, HHS has not undertaken any formal rulemaking that would impose penalties on providers found to be information blocking. According to the ONC information blocking webpage, there have been 364 claims for possible information blocking since April 5, 2021.

With the expansion of the definition of EHI and information blocking compliance in mind, here are specific actions for HI professionals to take now.

Master the New ABCs of EHI

The expansion of EHI beyond the data elements represented in the USCDI is an important interoperability milestone. HI professionals must be part of every healthcare organization’s effort to define EHI and map all the locations and input mechanisms for EHI collection across their organizations.

AHIMA, AMIA, and EHRA formed a task force in 2021 to examine the impact of the Cures Act Final Rule on the designated record set (DRS) and EHI. The task force report provides important information for all HI professionals and includes the following preliminary findings:

• DRS includes information used to care for or make decisions of care or payment of the claim. This might include clinical and administrative data, information drawn from within and outside of your facility, and analytical data specific to a patient’s condition.
• Status conditions should be considered when interpreting and applying the definition of EHI including unvalidated data, draft data, duplicative data maintained by both the health plan and health care provider, and data that does not meet the ePHI definition.
• Standardizing clinician and developer expectations around the definition of EHI will be critically important to successful operationalization of the Cures Act Final Rule.
• Determining what data classes are considered EHI will continue to evolve over time. Therefore, the task force will continue its work, including feedback from stakeholders and work with other constituents in the healthcare community to advance a common understanding of the definition of ePHI.

As a next step in this journey, AHIMA joined The Sequoia Project, an independent, trusted advocate for nationwide health information exchange. Lauren Riplinger, JD, AHIMA vice president of policy and government affairs, co-chairs The Sequoia Project EHI Task Group with Josh Mast, JD, CHC, director and project regulatory specialist at Cerner, and Jim Jirjis, MD, vice president and chief health information officer at HCA. HI professionals should maintain a close watch on both the AHIMA and The Sequoia Project websites as work continues by both organizations to define EHI and develop new best practices.

Get Involved with Defining EHI at Your Own Organization

There is much that HI professionals across every HIM domain can do within their own organizations while important work proceeds at a national level. Ownership of EHI definitions is not the sole responsibility of clinicians, data scientists, or IT departments. HIM must also be involved. Here’s one way to position your involvement at the organizational level.

Within this industry, there has been a longstanding analogy to compare the roles of IT and HIM in healthcare data, the “water pipes” that exist in buildings and homes. These pipes are the IT systems, infrastructure, and security valves that transport information from one place to another across a health system or organization. Health information (data) is the water that moves through these pipes. And, most important, HI professionals are the water quality specialists that oversee and protect the quality of health information and data contained within the pipes. This analogy remains accurate and relevant today.

Here are three steps HI professionals can take now to lean into interoperability and define EHI within their own organizations:

1. Include the definition of EHI as part of your organization’s overall interoperability governance plan and compliance roadmap. Include clear issue ownership within the organization.
2. Engage your internal stakeholders through education on near-term regulatory requirements, analysis, and summary of work already done by the organization, and compliance planning.
3. Partner with compliance peers to develop checklists, sample policies, and workflows to monitor issues. Once you decide what constitutes EHI for your facility, it must be available to the patient and cannot be blocked, unless one of the eight exceptions is applicable.

Perhaps most importantly, HI professionals are encouraged to take a seat at the interoperability table—regardless of the HIM domain they represent. Advanced steps for engagement are included below.

Add Your Voice to the Discussion: New Opportunities for HIM

HIM is made up of multiple disciplines. Each one has a role to play in the continuing interoperability journey today and for many years to come. The following are valuable examples for HI professionals to consider:

• Coding professionals may be ideally suited to become EHI data managers determining how data will move forward, what data elements should be included in EHI, and how information should flow.
• Chart analysts and CDI professionals could lend a hand in identifying the source of truth for each data element and data mapping.
• ROI staff have the potential to serve as data flow managers, defining and monitoring where information comes from and where it is going (who it is shared with).
• ROI staff can also serve as patient information advocates as more patients interact via portals and ask for addendums or corrections to their medical records.
• Privacy experts can serve as strategic counsel and day-to-day watchdogs for data integrity related to incoming information from outside sources such as remote patient monitoring (RPM) devices and consumer health applications.
• HIM directors should be active with state and regional HIEs to stay abreast of interoperability progress, initiatives, and outcomes. If direct involvement isn’t possible, connect with someone else from your state who works with the HIE.

The journey toward interoperability in healthcare will move HIM departments beyond a repository of information to true management of health data. Now is not the time for HI professionals to sit on the bench. Be engaged, speak up, and lend your knowledge to advance healthcare interoperability

Advancing Interoperability: Five Additional Steps for HIM to Take

• Establish guidelines to identify, manage, and respond to EHI requests. Determine if requests are episodic or ongoing, prioritize requests, understand bulk data access/EHI export, know where EHI is located, and document if any blocking has occurred.
• Define any issues related to multi-state actors including providers, developers, and HIE or HINs.
• Build rules to manage exceptions with documentation to support exceptions.
• Know your organization’s capability gaps and patient usability issues that may implicate information blocking.
• Prepare action plans for responding to complaints of information blocking, OIG violations and potential penalties.

Rita Bowen is the vice president of privacy, compliance, and HIM policy at MRO. Bowen is also the treasurer on The Sequoia Project’s board of directors and serves on the Interoperability Good Practices task group.