The Interoperability and Patient Access Rule: Getting the Order Right (Part Two)

In the first blog of our series, we explored how a waiter’s role in your dinner order is much like the role of an application programming interface (API) in delivering data. Like a waiter, an API receives a set of instructions, takes the request to a database, and retrieves the data, or enables a set of actions before sending a response back to the application or engineer that requested it. APIs have recently taken center stage in healthcare due to the Interoperability and Patient Access Rule issued by the Centers for Medicare & Medicaid Services (CMS). The rule aims to equip patients with access to their health information when, where, and how they need to use it.

In addition to the considerations surrounding data strategy, third-party applications, and patient access that we explored in our first blog, there are several other critical aspects of Interoperability Rule compliance. These include:

API management:  Establish a set of processes and infrastructure components that enable you to produce strong API documentation, develop the API, and make the API discoverable by consumers. In addition, provide robust security control through the API gateway utilizing a Fast Healthcare Interoperability Resources (FHIR) server.

Our API Management services include helping you identify or procure an API Gateway/FHIR Server, develop or leverage API lifecycle management processes, and integrate your security framework into your API strategy. We can help evaluate available open-source APIs, develop a testing strategy for conformance and certifications of your APIs, and build infrastructure requirements.

Project planning and management: Get ready to plan and execute – achieving federal interoperability requirements will involve significant upfront planning – e.g., procurement, implementation, and funding – and then managing the execution of those plans. Essential considerations include how to best leverage existing contractors and technologies, such as Health Information Exchange (HIE) assets. You’ll also need a funding plan to secure the state and federal funds necessary for a successful implementation; CMS has estimated that state implementation costs could range from more than $700,000 to $2.3 million per organization. In certain cases, CMS will pick up part of the tab.

North Highland has experience helping organizations plan and execute large, complex Medicaid IT projects in response to changing federal regulations, including designing procurement and implementation strategies consistent with state and federal objectives. If you're at risk of missing the impending 2021 deadlines, it will be critical to show CMS that you have established a thorough, feasible plan and are moving toward compliance.

In procuring new vendors to support these projects, we have ample experience helping organizations determine a program budget, specify the work breakdown and budget for vendors and internal staff, and estimate a funding breakdown for each stakeholder. Together, we’ll develop a roadmap to show how the interoperability project intersects with your MMIS modernization effort and your state’s interoperability efforts.

Governance: Instill transparent governance to support the complex decision-making processes surrounding your design, development, and implementation approach. Implementing interoperability will have far-reaching impacts on state agencies, managed care organizations, third-party application providers, and healthcare providers. Ensuring that stakeholder expectations are managed and roles and responsibilities are clearly defined can help mitigate implementation risks. 

We can help you identify stakeholders, design governance structures, determine which decisions are made at which levels of the governance structure, and communicate with affected organizations and stakeholders.

So, what’s for dinner at your house tonight? When you’re ordering takeout, you likely expect the restaurant to get your order right each and every time. Doing so requires having the strategy, structure, and processes in place to get your order from the waiter to the kitchen and back to you, just as you’ve requested it. It’s no different for the MCOs, health plans, and states facing the CMS Interoperability and Patient Access Rule, though it won't take the form of menus, ingredients, and chefs. Instead, you'll need to consider data strategy, third-party application onboarding and support, patient access and authorization, API management, project planning and management, and governance. By tackling these challenges, you’ll create the perfect recipe for giving patients access to their health information, when and where they need it.