Friday, August 23, 2019

The 3rd Annual ONC Interoperability Forum

A dozen years ago, there were 200 people deeply involved in Interoperability programs in the US.  Over this last week I attended the third annual Interoperability Forum hosted by ONC, and I can safely say that there are at least 1000 people deeply involved in Interoperability programs.  It was hard enough then to keep track of it all back then, and I can honestly say that I don't envy Steve Posnack his new role (nor his past one), as well served as we are in this country by having him in it.

I would have to say that 21st Century Cures represents the second reboot of our Interoperability program in the US.  The "first" program was under the ONC created by Bush's Executive Order 13555.  The first reboot of the US program via ARRA/HITECH when ONC was enshrined in law by congress.  Having followed national programs in Canada, Europe, Asia and the Middle East, I can safely say that programs at this level reboot about every 5-7 years.

Big themes this year:

  • Not just payer engagement, but strong payer leadership in interoperability initiatives.
  • Learning from the international community ... International keynotes book-ended this conference, the Dr. Simon Eccles from the UK and NHS program kicked things off, and a team from the Netherlands including long time IHE participant Vincent van Pelt wrapped it up.
  • APIs was watchword 1, quickly followed by TEFCA and then Privacy.
    • Ready, FHIR, Aim... that's the state of FHIR right now.  In Garner hype cycle terms, we are so at the peak of inflated expectations.  This isn't a bad thing, or even a ding, it's just me acknowledging where we are at.  We have to be there at some point.  I expect that FHIR will cross the chasm swiftly though, with the brain power that is working on uses of it to solve so many challenges.
    • TEFCA and the framework are still on the ramp up from what I can figure, there's so much that people have yet to work out (but are working madly to do so).  The big challenges: How to get to an endpoint given a patient, provider or payer identity.
    • The biggest concern of many around APIs is about how to protect consumers (b/c this data isn't protected by HIPAA).  I'll say this again: 20 years ago you never would enter your credit card number on the web, we will figure this out, and mistakes will be made, just as before.  Yes, we can learn from mistakes of the past, but the reality is, you won't discover the real problems until they crop up.
      As to the assertion that consumers aren't ready for APIs, that's like saying that consumers weren't ready for the internal combustion engine.  It's also the wrong concern. Consumers are ready for what the APIs (internal combustion engine) will be used for: Apps (cars, tractors and lawnmowers).
  • The thing that everyone wanted to know and nobody could figure out was "When's the (Cures|CMS|HIPAA) Regulation|Next version of TEFCA going to show up?" 
    • Cures had 2000 comments, it was planned for in Q3 this year, but then there was a shutdown before it ever got published (that was planned for Q4 last year).  The pressure is still on, but my bet: Q1 2020, and I'm sure that ONC wants it out sooner, but I don't see how it could happen in Q3 at this stage (it would already need to be in OMB at this stage), and in my opinion, Q4 is still dicey based on what we heard about the review that's still going on from Elise Anthony on day 1 (recall that last year, it was in OMB in October, and we still didn't see it before Christmas).
    • I heard that the CMS regulatory agenda (the RegInfo site is down this morning so I cannot verify) is suggesting November for it's final rule (Learn how to use these tools if you need to track this stuff).
    • In case you missed it, the 42 CFR Part 2 Update just came out, which is why it isn't listed above.


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  4. I would add to APIs that the big discussion was how do consumers/patients trust Apps. Also how do providers trust third party Apps, even with HIPAA Patient Right of Access. Yes, a patient can ask for their data to be sent/retrieved by a third party App or other means. Providers are concerned about institutional reputation, and getting tainted if the App is a bad actor. 21st Century Cures and the Proposed Rules do not cover this area. It will be the wild west with data loss. Once that genie is out of the bottle, a patient could be harmed for the rest of their life.

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