ONC’s Interoperability Plan: a Day Late and $19bn Short

Screen Shot 2015-10-21 at 8.40.34 AMEarlier this month, the Office of the National Coordinator for Health Information Technology released an update to Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap. The roadmap was first announced back in January, and the changes shared this month aren’t significant.

Ultimately, it calls for all healthcare providers nationwide to be able to send and receive electronic clinical information by the end of 2017.

This is a good plan on the surface, although it comes six years and millions of dollars late, and like other programs it may be more cumbersome that it first seems. Essentially, there are three facets:

1) Data standards to format and request/receive data

2) Incentives (again!)

3) Governance

Despite the intention to move data across the Union, each state will have the right to create its own unique rules on how to manage the exchange of information. This is a problem as we have seen before in the simple Case of e-prescription routing. A few states make it almost impossible to send e-scripts and layer on their own special form of bureaucracy. This inhibits the ultimate goal of reducing costs and errors and increasing Efficiency at the expense of both providers and patients.

The plan brings back the old carrot and stick we saw with Meaningful Use. The ONC proposes to offer Incentives to share data. I am doubtful that the industry will get behind this given the waning success of Meaningful Use. There is a major shift happening. Change is being driven more by providers and market factors and less by government regulations. I see the potential for push back from the innovative companies appearing daily on the healthcare scene.

The standards within the proposal are also missing a critical standard for patient identification, which is the starting point for any type of exchange. Without it success seems unreachable. The payer side of healthcare seemed to figure this out many years ago. They essentially created a basic functional standard that comes in one flavor, and they did not offer it up for endless debate and over engineering by informaticians. They dropped the standard and said if you want to get paid figure it out. Within a matter of months the industry did figure it out and with a high degree of success and utilization.

All along, success may have been more likely if all of the meaningful use and interoperability efforts had been spent on a simpler structure:

1) Each system is required (by penalty of fraud)  to create a structured clinical summary document of a specific form without variance and export it on every encounter to a central repository

2) Upon deposit you gain one download credit from the repository

3) If you want to download from the repository and you are authorized to do so for the patient requested, you can use your upload credits or pay a small fee to support the repository infrastructure.

There would be no other standards. The central repository would be designed to offer data services for individual and aggregate data. The result would be unobstructed healthcare exchange, open source nationwide population health and predictive analytics insights, and a simple way to identify fraud, abuse, and over utilization. The future value of such a repository when paired with genetic data could lead to drug breakthroughs and other benefits. This may be oversimplifying, but the “less is more” concept has been proven to work in this industry in the past, and not taking this route is an opportunity lost.

Tom Giannulli, MD is a clinical advisor to Kareo

1 reply »

  1. “Governance”

    That’s one of those words used to set forth diffusion of responsibility sufficient to ensure that nothing ever gets done.

    “send and receive electronic clinical information” is not the same as interoperability.