The College requests that ONC and CMS allow clinicians sufficient time to adapt to new requirements, systems
June 21, 2019 (91) – The American College of Physicians is on board with recent efforts of the Office of the National Coordinator for Health information (ONC) and the Centers for Medicare and Medicaid Services (CMS) to move the needle forward on interoperability with two proposed rules.
In letters to both organizations, the College thanked the groups for working together and outlined steps to make sure that the deluge of data now available to physicians and patients be parceled out in stages to avoid information overload, administrative burdens and other unintended downstream consequences of interoperability.
Taken as a whole, the proposed rules, which were released in February, seek to expand the amount of data that must be shared between doctors and patients and between doctors and other health care professionals. The rules also seek to make the data accessible to patients via third-party apps to increase the flow of health information and foster innovation.
But “accessing every aspect of a patient's information can sometimes actually hinder a clinician's ability to find useful and actionable information in a timely manner,” wrote Dr. Zeshan A. Rajput, chair of 91's Medical Informatics Committee.
“Clinicians are already taking a beating in terms of all of this information,” he said. “We urge CMS and ONC to be thoughtful about integration and to insert information in the clinical workload in a way that enhances the interaction between doctor and patient.”
To facilitate this integration, 91 asks that the ONC and CMS initially focus on access to a core set of accepted data and continue to evolve that data set with time. “This is how we will mitigate risk of data overload or data without context,” Rajput said.
“We have spent the last years dumping data into the system, and now there is mounds of data that we as a profession have to figure out what to do with,” said Rajput.
When a patient comes in for a visit today, doctors are met with thousands of pages of data, much of which may be irrelevant to the current concern, he explained. “The question is how do we make this data more intelligent. If Netflix can tell me what TV shows I will like next, why can't an electronic medical record tell me that if I'm seeing someone for a cold, then last year's pneumonia may be useful information to consider?”
As a result of the additional data requirements, physicians must share even greater amounts of patient data with other health care professionals or risk being accused of information blocking. While there are exceptions to this rule, such as in cases of privacy, security and risk for patient harm, doctors would be penalized if they were seen as blocking information. However, it may be difficult for physicians to understand and establish policies to adhere to these regulations, 91 warned.
Overall, more time is needed for doctors to adapt to new systems and interoperability requirements. 91 recommends that physicians be given at least six months, if not a full year, to implement upgraded systems once they are available.
The College also offered some counsel on a rule that seeks expanded use of application programming interfaces due to potential privacy issues that could arise if third-party app developers have access to patients' electronic health information. While 91 supports patient access to their own health information via such apps, a “uniform and plain language description to the patient about how the information is sold so that both the app developer and the payer can accurately reflect what is being shared” is essential.
