Pooja Babbrah, Pharmacy & PBM lead with Point-of-Care Partners (POCP), NCPDP Board of Trustees Chair, and host of The Dish on Health IT kicked off the episode. This last episode of 2022 featuring POCP Regulatory Resource lead, Kim Boyd and Payer & Provider Practice Lead and Da Vinci Program Manager, Jocelyn Keegancame together to break down all the big things that have happened in 2022 and what we expect for 2023.
Pooja explained that while this episode's discussion will primarily be policy related, the panelists will also talk about some of the real progress being made in the standards world and the interconnectedness between federal and state health IT policy and legislation and between standards and policy, and what it means to the industry.
Pooja asked Jocelyn and Kim to briefly introduce themselves and to tell the audience what topics they are most excited about discussing.
Jocelyn introduced herself as the POCP payer practice lead, devoted to positive change and building/getting stuff done. She went on to say that her focus at POCP is on interoperability, prior authorizations, and the convergence of tech, standards, and product strategy. She explained that she has spent her career moving people and organizations towards APIs, unleashing data for their highest, best-purpose uses. She expressed that she couldn't be more excited about where we've been this year and the precipice of where we are headed next year.
Kim expressed that it's always a pleasure convening with Pooja and Jocelyn to discuss the exciting world of health IT. She went on to share her background which has spanned medical and pharmacy operations and implementations, with years of policy, industry, and standards development work on ePA, cost transparency, ePrescribing, and taking what she learned in these areas to work with policymakers on smart policies to advance interoperability and patient care. Kim stated that it has been an exciting year leading POCP's Regulatory Resource Center and that so much is happening in the state and federal regulatory spaces that ties to the innovations and acceleration the industry has been experiencing in health care.
Pooja thanked them both for their introductions and then dug into the discussion by asking each of them to share the biggest Health IT highlights of 2022.
Kim explained that four things really stand out in 2022:
- the requirements of the transparency in coverage and no surprises act going into effect and the various provisions requiring data and cost transparency and giving patients and their care teams access to information that will help them make informed decisions. Many in the industry have been clamoring for transparency of this type for some time.
- The incredible work happening to advance interoperability via the SDOs and Accelerators, like HL7 Da Vinci, CodeX, FAST, and NCPDP's Pharmacy Technology and Innovations group.
- how Federal agencies are collaborating on aligning requirements for interoperability, like the use of standards and FHIR-based standards specifically. This collaboration and proceeding regulatory action will help align the technical and interoperability stars.
- the all-hands-on-deck focus on patient health equity is a big area of concentration for not only innovators in the market but the White House, HHS, standards organizations like NCPDP and HL7, and community and public health organizations. There is just so much happening to try and close gaps in equitable care and the data/digital transformation that needs to happen to help facilitate change.
Jocelyn followed Kim to share her perspective on the biggest highlights of 2022 first joking that Kim got to go first and steal some of the things she was going to say.She laughingly shared that she agrees with all of Kim's points and then said that she wanted to focus more on the tone and the tenor of the work happening in the industry. Jocelyn shared that from her perspective it feels as though the industry has moved from thinking about interoperability projects as something that will happen "someday" to action and reality. She clarified that this may not be the case for everyone, but many organizations and projects are moving forward to not only do the IT work but the business transformation. The examples she gave included the real progress made on TEFCA, real-world deployments of FHIR guides, live usage of APIs, prior authorization (PA) on pharmacy getting an infusion with last year's Medicare Part D
Jocelyn added that she wanted to focus on and add to Kim's comment about coordination at the federal level. She explained that policymakers at the federal level have been working for well over a decade and using their levers to make change extraordinarily well. Jocelyn went on to say that as she sees it there are three camps of folks; people and organizations who are working ahead of policy by paying attention to published roadmaps and reading between the lines of public statements, folks trying to get their organizations prepared to respond to the next wave of policy, and others playing the waiting game to see if it's real and if they'll have to follow or if another path will emerge.
Finally, she added, that the last highlight from 2022 is all the waiting! The industry keeps waiting for certain regulations to drop. She explained that she doesn't think she remembers another year where there has been this much policy anticipation at year-end.
Pooja thanked Jocelyn and Kim for sharing their perspectives. She shared two important topics that have been more under the radar but are growing in importance and focus. The first is consent, specifically eConsent. Stewards of change published the report “Modernizing Consent to Advance Health and Equity” to bring more attention to the need to solve this issue – not only in the context of healthcare but also social services as those are such an important tie-in to health outcomes. Add to that, the ONC half-day discovery workshop on eConsent. Pooja explained to those who may not have attended – that it was an amazing session that brought together so many different people across the continuum of care in addition to the people working in the social services arena.
The other area is pharmacy and the growing role of pharmacists in the care team and the work that is being done to ensure that they have access to more data and information to support care teams and support patients. Pooja explained that there has been a lot of movement by retail chains to add primary care services to their offering and community pharmacies are supporting more clinical services. This has led to more focus and a flurry of discussion around interoperability in the pharmacy space. Pooja gave the example of the Health Information Technology Advisory Committee (HITAC) recently proposing adding a pharmacy-focused subcommittee which is a huge indicator.
Pooja shifted the discussion to policy highlights, specifically, requirements that went into effect and whether the industry met the deadlines or is still working on it. She explained that she is thinking specifically of:
- No Surprises Act
- Transparency in Coverage Rule
- Information Blocking
Kim jumped in by saying that with the No Surprises Act there is still some pushback and uncertainty about how providers are going to comply with having to pull together all the data to provide Advanced EOBs (AEOBs) and good faith estimates (GFEs) when there are multiple providers involved in delivering the expected care; however, the Da Vinci Project is working on advancing implementation guidance to support patient cost transparency. Kim encouraged folks and organizations listening to this episode to get involved in these efforts. Kim added that she expects to see more price transparency-related policies, especially given the latest request for information on AEOBs.
Kim went on to say that compliance with the ONC 21st Century Cures Final Rule on information blocking has been a mixed bag. She added that she wished ONC had called this "information sharing" instead of information blocking. Kim went on to say that most of the non-compliance has been on the provider side because it is challenging when a provider falls under the rule as an actor but maybe the health system they work in does not, especially when the health system may hold the data being requested. She added that most of the EHRs have spoken with are up-to-speed on the full EHI sharing requirement.
Jocelyn added her perspective on information sharing specifically around EHI. Technically all of this information needs to be put out there, while the industry waits for USCDI to fully encapsulate patient information, there is probably a lot of non-codified data in the system that isn't actionable or really useable. The EHR certification requirements will likely do more to move the industry forward. Jocelyn confessed that she fell down the RFI response rabbit hole and spent an hour looking at the feedback to the RFIs. She thinks there is a disconnect between the goal of the rule and how to operationally do the work. An example she provided was around PA and that it isn't automating the submission of the PA alone but how to automate the 10 steps that need to happen before a PA is submitted.
Pooja shifted the conversation to ask Kim to talk a little about the state activity around price transparency and why it's so important for stakeholders to pay attention not only to federal policy but what's happening in the states.
Kim agreed that so many organizations forget that state policy is a big part of the equation too. She shared that on the data and cost transparency side, states doubling down to move the needle on data fluidity. The POCP Regulatory Resource center has its finger on this pulse. From the required patient-specific cost, benefit, coverage, and eligibility data sharing to confirmation of compliance enforcement of the No Surprises Act and Hospital Transparency, just to name a few.
Pooja concurred and added that many people forget the states can add enforcement teeth above and beyond federal enforcement. She then remarked that this has been a year of anticipation and asked Kim to share where the burden reduction and prior authorization rule that was shelved back in 2020 is currently.
Kim responded by explaining that there has been so much anticipation and even angst for some when the original rule came out in 2020 but then was pulled back.So many in the industry have been endeavoring to fulfill the promise the Da Vinci CRD, DTR, PAS IGs provide on solving for medical PA. Probably the most promising sign from CMS is the rule sitting at OMB since mid-October, waiting for review and then ultimately release. Given OMB has a max of 90 days to take action on the review, health plans, vendors, providers, and their partners should be closely monitoring for OMBs response and action.
Jocelyn joined in to say that the rule that came out in 2020 was definitely more than just burden reduction and it would have codified the use of patient-access APIs. She added that the 2020 rule didn't just require FHIR but named a particular implementation guide or "recipe" for the industry to use. Jocelyn anticipates that the version of the rule that has reemerged and is sitting with OMB likely includes Medicare Advantage plans which weren't included in the 2020 version. She's really interested to see what the NPRM will include. Jocelyn added that there is legislation pending that includes prior authorization and many are hoping the proposed rule drops before the legislation passes.
Pooja thanked Jocelyn for bringing up the pending legislation and then moved on to ask about the recent CMS requests for information out there. She asked about what kinds of questions is the government asking and what do these questions tell us about where their heads are at?
Jocelyn started by saying that the industry is seeing an unprecedented amount of coordination and policy-making activity. It has been a challenge to marshall the resources to respond to these RFIs and participate in the conversations and discussions these RFIs generate. Clearly, the industry is leading and the RFIs are an indication that CMS and ONC want industry input into their policymaking.
Jocelyn went on to say that after reviewing the comments to these RFIs, the common themes were that the industry needs time and an incremental approach is needed but no one is saying what is being explored can't be accomplished.
Kim added that she was struck by how aligned the agencies releasing these RFIs seemed to be on solving for interoperability, digitization, using/reusing or referencing FHIR resources for use and across different areas of health care, from the public health infrastructure, TEFCA, Certification of HIT, PAs and more, even the RFI from CMS related to the National Directory wants to hear from health care on the applicability of the use of FHIR standards.
In transition, Pooja remarked that POCP and everyone on the podcast work in the standards development space through the support of some of the Accelerators like FAST, CodeX, CARIN Alliance, and of course, Da Vinci. She asked for the discussion to now cover the biggest accomplishments so far and what's expected in 2023.
Kim responded by saying that while not officially announced, the CodeX PA in Oncology Use case – focused on solving for automating PA for cancer patients using the Da Vinci IGs is progressing to the Execution Phase. Members represented in this use case are payers, EHRs, physician groups, and health systems and they have collaboratively moved the needle on this use case and will execute the proof of concept for prostate cancer in 2023.
Kim added that she is proud that NCPDP for their October Pilot launch announcement of the National Facilitator Model to strengthen pandemic and epidemic preparedness using industry standards and technology to enable pharmacies, prescribers, and government agencies to access real-time information on prescription, testing, immunization, and related data – across state lines - to support patient health interventions during public health crises. The model can also be used to effectively support public health surveillance.
Jocelyn chimed in to express her awe at the pace of work on IGs and new use cases. She added that another big milestone is that FHIR at Scale Taskforce (FAST) transitioned out of ONC into the HL7 Accelerator program. FAST progressed work on Security, Identity, and Exchange and they are pulling the TEFCA team in to align their work.
She added that Da Vinci has made a lot of progress on Risk Adjustment, allowing payers and providers to share information to inform a change in a patient's risk status.
Jocelyn went on to say that there are also some exciting real-world implementations happening with a specific shout out to the team comprised of MultiCare, Providence, Regence, leadership from Optum, and Da Vinci champions launching the first in the nation FHIR-based pre-authorization embedded into the clinical workflow.
Pooja seconded the kudos for the NPCPD vaccine pilot and she also mentioned the CodeX REMS use case which is marching toward a pilot and is once again bringing NCPDP and HL7 together. Pooja went on to recognize Helios as an Accelerator that is starting to gain traction and the industry should pay attention to their work.
Pooja commented that while price and cost transparency for the patient will always be a passion of mine, the growing role of pharmacists in the care team is another area she is really excited about. Additional services are being performed by pharmacists, the prescribing authority is being extended to pharmacists, and the need for standards and technology to enable clinical data to flow from pharmacists to care team members in other environments like doctors' offices and hospitals.
Pooja continued by saying that the pandemic and really the Federal PREP act accelerated this movement. Now pharmacists can administer pretty much any vaccine on CDC's list, and there are around 25 states that allow pharmacists to prescribe HIV medications. Pooja explained that this expanding role and some of the regulatory requirements make pharmacy interoperability and connection with the rest of the care team critical. For example, for pharmacists to prescribe Paxlovid, they must order or access labs for the patients. Unless pharmacists are in a health system they will likely not have access to a patient's lab report. If the industry wants pharmacists to continue to support providers and patients with more clinical services – there has to be a focus on interoperability.
Kim agreed that it is an exciting time for the pharmacy community. The need for clinical and administrative data access, use, storage, and exchange to improve and coordinate patient care knows no boundaries – the whole of the care team, including the pharmacist, must be able to operate in an environment where this takes place.
Kim added that the NCPDP Strategic Planning Committee Value-Based Care Subcommittee acknowledged that the industry is well positioned to support pharmacists as a part of a value-based arrangement and we have the standards to support all types of clinical care and exchange so pharmacists can provide services like dispensing, screening for Social Determinants of Health or taking and reporting labs or blood pressure, etc.
2023 will be filled with opportunities within the NCPDP standards development process, the industry, and policy, to further the role of the pharmacist, closing gaps in care and the innovations needed for the future of pharmacists as part of the care team.
Pooja asked to do a round-robin weigh-in on TEFCA, HIPAA 2.0, and Health Equity. What's new, what's real, and what should our listeners be on the lookout for in 2023?
Jocelyn responded by saying that each of these topics has so many sub-topics and what will be interesting is to see how these all intersect with one another. She added that there is a movement to the platform where companies are partnering to solve some of the challenges related to these areas and make data fluid but secure.
Kim responded by saying that there is still confusion and conflict between HIPAA and the ONC Information blocking rules. Technology has evolved and new interpretations and requirements are needed that provide patient data security without limiting data sharing. The industry will see some movement from OCR in 2023.
TEFCA is real and moving forward in establishing the infrastructure model and rules that will govern how different networks and their stakeholders (including providers, payers, and public health) securely share clinically relevant information with each other. Nine organizations have provided letters of intent to the Sequoia Project, the recognized coordinating entity on behalf of ONC, to apply to become QHINs including EHR vendors such as Epic and Nextgen, national networks such as the eHealth Exchange and the CommonWell Health Alliance, and tech vendors such as Health Gorilla. More organizations are expected to apply. It will be interesting to see how successful TEFCA will be in incorporating FHIR into the framework over the next few years
There is a united effort that includes government entities, health systems, pharmaceutical companies, private payer groups, and community organizations working together to overcome disparities and improve equity. This requires improved access to shared clinical and social needs data.
Just last week CMS released its “Path Forward to improving data to advance health equity solutions” which aims to increase the collection of standardized sociodemographic and social determinants of health (SDOH) data across the healthcare industry as an important first step towards improving population
In closing, Pooja asked everyone to share what they are most hopeful to see in 2023. She kicked it off by saying that for her it's the continued focus on pharmacists.
Kim responded by saying many great things are happening in health care and that she is excited as a patient. There is more focus on helping patients grow as consumers of their own health care, providing data and insights into what options are available to obtain quality, timely and cost-effective care.
She also expressed excitement about working with industry and policymakers to advance medical ePA in 2023 via the HL7 Da Vinci standards and leading the CodeX work on a pilot to advance PA for cancer patients.
She concluded by echoing what Pooja said about her excitement about leading and partnering with others at NCPDP to promote and advance the role of the pharmacist as a part of the care team.
Jocelyn joined in to say that she is hopeful for the momentum that has built up and she is super excited to see stakeholders build their toolboxes and embark on real-world implementations.
Pooja closed out the episode by thanking her POCP cohosts, Jocelyn and Kim, and wishing our audience the happiest of holidays and the best for 2023.
She reminded listeners that they can find The Dish on Health IT on Apple Podcast, Spotify, or whatever platform they use to pick up their podcasts, including HealthcareNOW Radio and the Podcast Channel. And that videos of the podcast episodes can be found o on the POCP YouTube channel. Adding, Health IT is a dish best served Hot!
