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Going beyond compliance to achieve radical interoperability

by Anne Phelps, Jason Wainstein, Claire Boozer Cruse
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4 minute read 28 August 2019

Going beyond compliance to achieve radical interoperability Pulse survey on CMS and ONC proposed rules

4 minute read 29 August 2019
  • Anne Phelps United States
  • Jason Wainstein United States
  • Claire Boozer Cruse United States
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  • Background
  • Findings
  • Seizing the opportunity to go beyond compliance

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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Learn more about the Future of Health

Explore the Life sciences and health care collections

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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.

Acknowledgments

Wendy Gerhardt, Christine Chang, and Maulesh Shukla helped drive this research, from assistance with developing the quantitative survey to conducting background research on the key topics included herein. Daniel Esquibel and Ethan Joselow served as key subject matter experts throughout the research process.

The authors would also like to thank John Vitale, Gerry Yantis, Chris Harris, Sarah Danielson, Mike Delone, Wade Horn, Tuan Tran, Lauren Wallace, and the many others who helped throughout the project.

Cover image: Kevin Weier

Endnotes
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Topics in this article

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.

Learn more
Get in touch
Contact
  • Anne Phelps
  • Principal, US health care regulatory leader
  • Deloitte & Touche LLP
  • annephelps@deloitte.com
  • +1 202 220 2702

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Anne Phelps

Anne Phelps

Principal

Anne Phelps is a Deloitte & Touche LLP principal in the Life Sciences and Health Care practice. As the US Health Care Regulatory leader for Deloitte, she manages the Health Care Strategic Regulatory Implementation Services practice. In this capacity, she helps clients navigate the complex world of health care regulatory changes to set their business priorities and strategic opportunities in the midst of a dynamic environment.

  • annephelps@deloitte.com
  • +1 202 297 1378
Jason Wainstein

Jason Wainstein

Jason Wainstein, Deloitte Consulting LLP, is a principal and national leader for Health Plan Technology Strategy, Consumer Experience, and Information Management/Analytics. He specializes in health care business optimization, enterprise transformation, and technology strategy. Wainstein leads engagements focused on advanced retail and consumer capabilities, analytics, platform modernization, M&A, and IT delivery. He joined Deloitte in 1996 and won the Philadelphia Business Journal “40 Under 40” award in 2009.

  • jwainstein@deloitte.com
Claire Boozer Cruse

Claire Boozer Cruse

Manager | Deloitte Services LP

Claire Boozer Cruse, Deloitte Services LP, is the chief of staff for the Deloitte Center for Health Solutions. In addition to leading operations for the team, she drives research projects in the areas of Medicare, Medicare Advantage, payment reform, post-acute care, and the individual health insurance market. Cruse earned BS and BA degrees and a certificate of gerontology from the University of Georgia and holds a master’s degree of public health in health policy from the George Washington University. She is based out of Denver and can be reached at https://www.linkedin.com/in/claireboozercruse.

  • cboozer@deloitte.com
  • +1 202 220 2011

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