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Going beyond compliance to achieve radical interoperability Pulse survey on CMS and ONC proposed rules
4 minute read
29, August, 2019
Are health plans and health systems making interoperability a strategic objective—or just ticking off the boxes? Many organizations are using the rules as a first step toward broader strategies on interoperability.
Background
Proposed rules from the US Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health Information Technology (ONC), published earlier this year, are likely to drive the US health care system toward greater interoperability. We expect the administration to finalize the rules in fall 2019, and many of the provisions would go into effect on January 1, 2020 (see the February 11, 2019 Reg Pulse Blog). Through other levers such as new payment models, the Trusted Exchange Framework and Common Agreement (TEFCA), and a recent executive order on transparency, the administration is laying out a plan to drive the industry toward widespread interoperability. Taken together, these initiatives showcase the administration’s continued push to make health care information more accessible by encouraging plans and providers to share data with each other to improve the quality and efficiency of health care and with patients to help them make informed decisions.
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As described in Forces of change: The future of health, today, the US health care system is a collection of disconnected components (health plans, hospital systems, pharmaceutical companies, medical device manufacturers, etc.). By 2040, we expect the system to be dramatically different than it is today. Health will likely be driven by digital transformation enabled by radically interoperable data and open, secure platforms. Moreover, consumers will own their health data and play a central role in making decisions about their health and well-being. Health care organizations that fail to see beyond compliance deadlines and realize the greater strategic value of interoperability and data could risk falling behind.
From early May to mid-June 2019, the Deloitte Center for Health Solutions polled technology leaders at large health plans (n=35) and health systems (n=35) to gauge their attitudes and priorities around the CMS and ONC proposed rules (see sidebar, "Methodology").
Findings
Overall, many respondents said they are using the proposed rules as a foundation for their broader strategic interoperability initiatives. Moreover, many believe they will have to go beyond what their vendors provide to achieve that strategic aspiration.
Most (63 percent) health plan and nearly half (43 percent) of health system leaders say they plan to use the compliance requirements as part of their broader strategy around interoperability (see figure 1).
Figure 1
Link to Figure 1
Moreover, many organizations reported that they plan to go beyond compliance. More than half of health system (55 percent) and health plan (60 percent) respondents say they are either building their own application programming interface (API) solutions or are doing so even while they work with a vendor to build solutions (see figure 2).
Figure 2
Link to Figure 2
Seizing the opportunity to go beyond compliance
The administration is using multiple regulatory levers to advance interoperability. The draft rules call for organizations to meet many of the requirements starting on January 1, 2020. Organizations that develop and implement a strategic approach to interoperability are likely to have a competitive advantage with insights, affordability, and consumer engagement in the future of health. Some of the next steps to consider in establishing a strategic approach to interoperability are discussed below.
Define the organization’s broader strategy
Organizations should leverage the regulatory requirements on interoperability as a jumping off point for their broader strategy for sharing data with industry stakeholders and with patients.
- Define the interoperability vision for the organization
- Establish an initial interoperability governance structure
- Perform a market scan
- Develop a business case and key business/technology benefits
- Develop high-value use cases such as enhanced care management and/or improved consumer and patient engagement
Define desired future state and maturity and compare against current capabilities
- Assess current interoperability capabilities and define desired future state
- Conduct a gap analysis between current and future state
- Develop an external engagement plan (for example, partnerships and collaboration with external entities to better enable interoperability vision)
- Evaluate your overall consent and risk management strategies for use of data
Develop an execution road map
- Prioritize a set of initiatives and road map to achieve compliance by the proposed January 1, 2020 deadline
- Identify longer-term goals beyond the January 1, 2020 compliance date around data exchange, digital tool adoption, and enhanced consumer engagement
- Assign “high priority” to the must-do/critical capabilities
Implementing a strategic interoperability plan can position health plans and health systems to gain insights and opportunities to provide more effective care, reduce inefficiencies, meet consumers’ demands, and better enable the organization to compete effectively in the future.
Methodology
The Deloitte Center for Health Solutions fielded a quantitative survey from early May through mid-June 2019.
Most respondents were chief technology officers, chief information officers, or EVPs/SVPs/VPs of technology for large (greater than US$750 million in revenue) health plans (n=35) and health systems (n=35).
Questions focused on leaders’ priorities, awareness, and preparedness in reaction to the proposed rules.
Stay tuned
In October 2019, the Deloitte Center for Health Solutions will be launching another piece on interoperability and how health systems, health plans, and life sciences companies are developing long-term strategies to prepare for a transformed health care landscape in 2040. To receive the report when it's available, subscribe at www.deloitte.com/us/LSHC-subscribe.
The future of health
The health industry is on the cusp of a major transformation that will affect all stakeholders. Incumbent players can either lead this transformation as innovative and well-connected market leaders or they can try to resist this inevitable change. A wide range of companies—from inside and outside of the health care sector—are already making strategic investments that could form the foundation for a future of health that is defined by radically interoperable data, open and secure platforms, and consumer-driven care.
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Get in touch
- Anne Phelps
- Principal, US health care regulatory leader
- Deloitte & Touche LLP
- annephelps@deloitte.com
- +1 202 220 2702
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