The 21st Century Cures Act: Interoperability, Information Blocking, and the Office of the National Coordinator for Health IT (ONC) Health IT Certification Program is in effect. Healthcare providers, health information networks, and health IT developers of certified health IT are mandated to take steps toward compliance by the deadline.
Healthcare providers do not want – and cannot afford – to scramble at each health IT regulatory step. Instead, they need to adopt a long-term plan to meet compliance deadlines and create a competitive edge to success in the future of health.
In this post, we explain the steps that organizations need to take to avoid the distress of CMS denying payment/reimbursement because of lack of compliance to the ONC Interoperability Rule information blocking provisions.
Key Milestones to Meet
The Centers for Medicare and Medicaid Services (CMS) developed and are following a roadmap to compliance1, even if some areas are delayed. Are you prepared for what’s next? Below, we’ve outlined the major milestones in play. Updates occur yearly so it is imperative to become compliant as soon as possible in order to keep things from getting more and more complex, and to prevent you from falling further behind the curve.
- Unlike self-attestations of the past, now providers must prove via certification that they are not information blocking. Each CMS milestone must be met to take advantage of reimbursements.
- The new 21st Century Cures Act ONC Final Rule provision includes penalties against information blocking, and updates to the Health IT Certification Program to enhance interoperability of Electronic Protected Health Information (ePHI).2
- Organizations must adopt the United States Core Data for Interoperability (USCDI) standard and standardized application programming interfaces (APIs).
- Data must be securely and easily exchanged and accessed in a convenient way.
This is the very definition of interoperability and, ultimately, the goal of the 21st Century Cures Act. Interoperability empowers patients to be active players in their healthcare and helps to streamline processes reducing burden for healthcare providers.
Although deadlines to compliance have been extended given the Covid-19 pandemic impact on the industry, the 21st Century Cures Act is still happening. Don’t fall behind!
Nine Steps to Keep Doing Business with CMS
You may not realize that you are information blocking until it's too late...and CMS is delaying your reimbursements because you aren't in compliance. You can avoid the shock and pain of not getting paid by taking action now.
If you want to continue doing business with CMS this year, here’s what you need to do:
- STEP 1 Understand the new 21st Century Cures Act ONC Final Rule and what is being asked of healthcare providers, health information networks, and health IT developers.
- STEP 2 Evaluate where your organization fits within the provisions and what you need to do to make sure you are compliant.
- STEP 3 Discover your organization's level of interoperability maturity and your compliance readiness.
- STEP 4 Consider your current organizational, local, and state policies and how the new provisions will juxtapose with these.
- STEP 5 Be familiar with how much of your business depends on CMS reimbursements/rates.
- STEP 6 Check in with your technology vendors to help ensure you aren't inadvertently information blocking.
- STEP 7 Review your business agreements regarding your information blocking liability.
- STEP 8 Ask your technology vendors how they plan to comply with the new regulations.
- STEP 9 Account for what types of technology upgrades and staff training will be required to meet the new regulations, how you will approach this, and the associated costs with each component.
Work with Standards & Interoperability Experts
Feeling overwhelmed? No healthcare provider can afford to struggle (or wants to) at each health IT regulatory step. As objective experts in healthcare standards and interoperability, we can help your organization adopt a long-term plan to meet compliance deadlines to ensure your business with CMS is not disrupted – and create a competitive edge to success in the future of health.
Enter BookZurman — a consulting firm that bridges the gap between healthcare and technology. We can:
- Conduct an assessment to determine your organization's current state of interoperability maturity, standards adoption and automation, as well as your compliance readiness for the future.
- Educate you and your stakeholders to help you understand how the new 21st Century Cures Act ONC Final Rule impacts your organization.
- Evaluate where your organization fits within the provisions and provide a checklist of what you need to do to make sure you are compliant.
- Create a roadmap to address known gaps and use cases to get your organization to 21st Century Interoperability.
- Help you interface with your technology vendors to help ensure that you are not inadvertently information blocking.
- Guide discussions surrounding your business agreements with your vendors and how they plan to comply with the new regulations.
that we can understand your organization’s health IT needs and desires and empower your organization with 21st Century Interoperability.
1 Centers for Medicare & Medicaid Services (CMS). (n.d.). CMS Interoperability Roadmap: A Proposed Rule to Help Patients Access their Health Information. https://www.healthit.gov/sites/default/files/facas/2019-04-10_CMS_Presentation_508.pdf
2 ONC’s Cures Act Final Rule: View Final Rules. (n.d.). https://www.healthit.gov/curesrule/download
Connect the Dots with BookZurman
BookZurman’s team of multidisciplinary, highly specialized experts continue to drive progress and innovation in the healthcare IT community. For more information on this and other work in the areas of standards and interoperability, informatics architecture or clinical decision support, follow us on Twitter and LinkedIn.
