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.
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").
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).
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).
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.
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.
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.
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.
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.