Thank you for tuning into The Dish on Health IT’s 2023 end-of-year recap. Point-of-Care Partners' (POCP) subject matter experts, including, Pooja Babbrah, Pharmacy and PBM Practice Lead; Jocelyn Keegan, Payer Provider Practice Lead; and Kim Boyd, Regulatory Resource Center Lead, gathered to discuss their top 3 health IT milestones for 2023 and their expectations for 2024. They also delved into the highly anticipated final version of the Interop 3, focused on advancing interoperability and improving prior authorization rules. Offering insights and advice, they guided listeners on approaching the initial review of this significant final rule. Point-of-Care Partners extends warm holiday wishes and a Happy New Year to all.
Host, Pooja Babbrah kicked off the episode informing listeners that this episode will be a special format. POCP has subject matter experts galore so this episode will bring together a small group of POCPers to look back at 2023, discuss what 2024 will have in store and talk a bit about the anticipated final Interop 3 rule.
Cohosts Jocelyn Keegan, recently honored as the DirectTrust Interoperability Hero, and Kim Boyd, a contributor steeped in policy knowledge and serving as POCP’s Regulatory Resource Center Lead, introduced themselves before the trio transitioned to the main discussion.
They contemplated a format for the day, aiming to dedicate the first half of the conversation to a round-robin, where each would share their personal top three events or trends from 2023. Pooja referenced the HIT Perspectives 2023 trends article, outlining POCP's collective trends. However, today's discussion allowed each participant to present their individual lists before delving into the much-anticipated final rule.Top of Form
Kim initiated the round robin by expressing that her top priority is healthcare interoperability, acknowledging its vast scope emerging from the 21st Century Cures Act and beyond. Within this expansive interoperability landscape, she highlighted the advancements within the FHIR community, predicting a swifter adoption of FHIR than previously witnessed. Her second ranking milestone revolves around artificial intelligence and machine learning, particularly their rapid uptake and integration into policy. Kim anticipated a more robust policy oversight of AI in the future. Her third notable milestone encompasses telehealth and telepharmacy, noting that the COVID-19 pandemic significantly increased patient reliance on remote visits for healthcare.
Jocelyn followed, emphasizing that her list complemented Kim’s perspective, offering a different angle. Her primary inclusion highlighted the industry's transition into implementation mode in 2023, witnessing real-world progress and widespread adoption of FHIR at scale.
Jocelyn provided examples supporting these observations. The first involves the reaction to the proposed attachments rule, released alongside the prior authorization proposed rule. While many organizations expressed their belief that attachments might not be crucial for future progress, the responses to the Interop 3 proposed rule were predominantly positive.
Her second HIT milestone relates to AI but primarily focuses on acknowledging and addressing the baked-in bias potentially inherent in AI and other advanced technologies. She highlighted the steps included in the HTI-1 proposed rule, aiming to mitigate bias and initiate discussions on ensuring the unintentional disruption of the path towards equity.
Jocelyn's third milestone centers on TEFCA, highlighting the progress made and the anticipated clarification expected in 2024 regarding its scope and limitations.
She connected TEFCA back to the first topic, emphasizing the necessity for alignment between the TEFCA infrastructure, rule framework, and the emerging API world. There have been ongoing discussions and industry feedback stressing the need for better alignment between the FHIR roadmap and the TEFCA roadmap as the industry shifts towards more real-time interactions.
Finally, Pooja presented her list, with pharmacy interoperability holding the top spot as her absolute milestone. She expressed her honor in participating in the HITAC Pharmacy Interoperability Task Force, emphasizing POCP's long-standing advocacy for integrating pharmacists into continuity of care discussions. She highlighted the importance of this focus in bridging access gaps, facilitating genomics testing, and building momentum for sharing data with pharmacists. This includes ensuring their access to patient records and their ability to share data with the broader care team, a significant development.
Her second and third priorities revolved around emerging trends in pharmacy with broader implications. Second on her list was Pharmacogenomics, involving genetic testing to discern the effectiveness or ineffectiveness of certain medications for specific patients. Pooja's third priority was digital therapeutics, an area where POCP has already made strides. She noted the growing emphasis, not only for pharmacies in understanding how to administer these therapeutics but also for payers in determining coverage policies.
The discussion then pivoted to sharing reactions and perspectives on each other’s lists. Kim expressed her delight in hearing pharmacy interoperability as Pooja’s top priority. She highlighted the dichotomy within the healthcare ecosystem, emphasizing the divide between pharmacy services and NCPDP standards on one side, and clinical services with HL7 standards, including FHIR, on the other. Kim noted the increasing convergence between these realms, particularly with enhanced collaboration between NCPDP and HL7. She anticipated continued advancements in NCPDP concerning pharmacogenomics, digital therapeutics, social determinants, and the flow of relevant health data.
When questioned, Jocelyn emphasized the criticality of integrating pharmacy into data flow and recognizing pharmacists as integral members of the care team. She stressed the impact of provider shortages in recent engagements with the US healthcare system.
Jocelyn echoed Kim’s perspective on the alignment of pharmacy and clinical standards, emphasizing their collaborative synergy rather than competition. She emphasized the need to ensure the right patient data reaches the appropriate care team members, including pharmacists, at the opportune moment, asserting that this alignment significantly enhances patient care.
Jocelyn highlighted that technology is designed to facilitate transitioning from one standard to another. She emphasized the increasing significance of robust data exchange, particularly the exchange of quality data, between payers and pharmacies as the industry transitions towards value-based care.
Agreeing with Jocelyn, Pooja explained the challenges in integrating pharmacists into value-based care contracts consistently. However, she noted that as data exchange between pharmacies, other healthcare settings, and payers improves, barriers diminish. Pooja underscored the broader benefits of enhancing pharmacy interoperability, emphasizing advantages not only for pharmacists but also for providers and payers.
Highlighting the pivotal role of pharmacists, Pooja stressed their potential as invaluable resources for gathering social determinants of health data. She emphasized their significance in care delivery, identifying patient needs, and facilitating connections with community services. Given the frequency of pharmacist-patient interactions, she emphasized the criticality of collecting and sharing this information with the broader provider team.
The conversation then shifted to the Interop 3 – Advancing Interoperability and Improving Prior Authorization rule, expected to be released by the end of 2023 or early 2024. Kim initiated the discussion, focusing primarily on the prior authorization aspect of the rule, acknowledging its broader scope.
Kim emphasized the crucial need to establish transparency and automation to address the delays in treatment caused by prior authorization or impeding patients' understanding of their coverage when a PA is not approved. The rule encompasses various APIs facilitating exchanges among payers, providers, and patients, utilizing the Da Vinci implementation guides.
Regarding industry feedback on the proposed Interop 3 rules, Kim highlighted the notably high volume of comments, predominantly expressing overwhelming positivity. Approximately 68% of the comments agreed with the rule's intent. Although some HIPAA-related concerns were expressed, very few disagreed with the rule overall, which was intriguing given its extensive scope. Providers consistently voiced their desire for a more efficient prior authorization process, advocating for faster turnaround times and increased transparency regarding reasons for denial.
Kim underscored the significance of the inclusion of the patient access API, stressing its value for all individuals as patients. She emphasized the importance of augmented access and transparency, not only concerning clinical information like test results but also regarding payer information related to coverage and reasons for prior authorization denial.
Jocelyn aligned with Kim’s overall assessment and expressed disappointment over the proposed rules' omission of automation for specialty medications or treatments covered under the medical benefit. She highlighted this overlooked area, expressing disappointment at its continued exclusion.
One thing that brought Jocelyn immense satisfaction was the inclusion and acknowledgment of the Da Vinci Guides' role, which significantly boosted morale. There has been noticeable maturity and widespread adoption of Da Vinci guides this year.
Jocelyn expressed surprise at the absence of staggered deadlines in the proposed Interop 3 rule. From the Da Vinci community perspective, strong opinions have been consistently voiced to all HHS colleagues—ONC and CMS—over the past couple of years, emphasizing the importance of promoting gradual progress rather than imposing substantial leaps. Hence, the alignment of everything with the 2026 deadline was quite unexpected.
Pooja expressed her appreciation for Jocelyn's mention of the absence of specialty medication. She highlighted the stakeholders' growing interest in addressing specialty automation. Notably, many specialty medications require prior authorization, making it surprising that a proposed rule focused on prior authorization didn’t include items covered under the medical benefit, such as specialty medications.
The discussion shifted towards offering advice to listeners on how to approach their initial review of the final rule when it's released. Pooja inquired if there were any specific strategies to consider. Jocelyn openly admitted that she would start her review by performing a search using control + F for the words "Da Vinci" before delving into noting the specific IGs named and understanding the timeline. Additionally, she highly recommended reviewers commence with the rule's introduction, as it sets the expected scope for the details.
Kim humorously mentioned her plan to break out the eggnog before diving into the review, expressing eagerness due to its overdue nature. She echoed Jocelyn's emphasis on paying special attention to standards requirements, specifications, and particularly the timelines. She's curious if any staggering will be introduced.
Kim highlighted her interest in uncovering any mentions of TEFCA and seeking details regarding prior authorization. Anticipating stakeholders' keenness for the timeline, she pondered how organizations less proactive in their approach might adjust their interoperability roadmaps.
The trio acknowledged the waiting game as they anticipated the final rule, expecting it to drop within a week or a few weeks. In closing the episode, they shifted focus to their expectations for progress in 2024, sharing their final thoughts.
Expressing gratitude, Jocelyn thanked Pooja, Kim, and all the dedicated Da Vinci members committed to transforming healthcare. She emphasized the privilege of their work and the influential role they play in driving industry progress forward.
Continuing, Jocelyn emphasized the importance of stakeholders having a plan in place, having selected partners, and scoped out project requirements, considering the multiple requirements in proposed rules like HTI-1 or disincentives related to information blocking. With policy activity accumulating, starting work becomes increasingly challenging if stakeholders haven't initiated their projects.
She highlighted that interoperability and emerging policies transcend mere technology, impacting fundamental business transformation. It's about establishing collaborative frameworks with partners, providers, suppliers, pharmacies, and community members.
Recognizing the learning curve, Jocelyn stressed the need to leverage collective experience, emphasizing the necessity of investing in building skilled professionals for this transformative journey.
Additionally, Jocelyn pointed out the considerable activity at the state level, highlighting states like Washington, California, and Utah potentially setting more aggressive deadlines than anticipated by CMS.
Kim contributed by mentioning the Office of the National Coordinator's rule-making efforts around certification. Specifically, she referenced the FY2025 rule encompassing real-time prescription benefit and the new SCRIPT standard, particularly pertinent to pharmacy interoperability.
Agreeing with Jocelyn's state-level observation, Kim highlighted a Wisconsin Bill allocating $500,000 annually to drive the adoption of real-time prescription benefit tools. States like Wisconsin actively support moving patient empowerment solutions forward where progress has been slower.
In 2024, increased AI-related policy activity is expected, not only at the federal level but also within certain states as they unveil details regarding the integration of artificial intelligence in healthcare. Privacy and security will be pivotal aspects of these developments. TEFCA's prominence, especially in the initial six months of 2024, cannot be overstated.
POCP houses experts deeply entrenched in these areas, dedicating their days to aiding organizations in navigating the landscape, aligning strategies with competitive trends and policy shifts, as they are intrinsically intertwined. Further industry consolidations are anticipated, influencing healthcare interoperability and patient care delivery.
Looking ahead, there's a breadth of promising developments on the horizon, but staying abreast of these changes requires daily vigilance—a facet in which we aim to empower and assist. Pooja echoed these sentiments about 2024, emphasizing the significance of pharmacy interoperability.
She highlighted the recent recommendations from high-tech quarters, advocating for pharmacy inclusion at the table. Pooja referenced the Sequoia annual conference, where the importance of not overlooking pharmacists was underscored. She hinted at discussions swirling around the potential formation of a pharmacy workgroup under the Sequoia project.
The recommendations stemming from the HITAC pharmacy interoperability task force aimed to unite stakeholders and emphasize various focal points in the field.
Reflecting on 2024, Pooja's closing thoughts emphasized the importance of collaboration. Encouraging individuals with substantial pharmacy knowledge and hands-on experience in operability to step up and contribute, she urged for their active involvement to ensure the comprehensive inclusion of this expertise.
Closing the episode, Pooja extended her gratitude to her esteemed colleagues, Jocelyn Keegan and Kim Boyd, and expressed sincere appreciation to the audience for their unwavering support of The Dish on Health IT, underscoring its immense value to everyone involved.
