June 2021 Newsletter

As of May 29th, Massachusetts has lifted many of the public health measures put in place to control the pandemic. While we are not out of the woods, the increase in vaccinations coupled with a decrease in the rate of disease spread has made a big difference. Masks and social distancing are still required in healthcare settings, when using non-private transportation services, in congregate care facilities, and a few other situations. Safety indicates they should still be used by those who aren't fully vaccinated, by the immuno-compromised and other high risk populations, and at the direction of public health or medical personnel. Many businesses still require masks and retain their other mitigation efforts and many individuals feel more comfortable continuing to mask and distance either to keep others safe or to avoid other illnesses that were reduced by the practice. For the most part, this will be self-regulated now.

As we transition back to something closer to pre-pandemic life, we must recognize that it is a transition and that our eventual new steady state environment is still unknown. This is true generally, but also within healthcare. While it's clear most of us expect telehealth to remain part of the healthcare ecosystem, it's unclear how laws, regulations, and practices will change to support it moving forward. Ditto remote monitoring and expanded home health services such as hospital-at-home. The pandemic didn't create health inequities, but it shone a bright light on them and also made it clear just how much social determinants of health affect absolutely everything. The industry is scrambling to do better, to fix inequities and address institutional or systemic issues related to race, gender, sexual orientation, disability, and other areas that lead to implicit or explicit biases. Increased interoperability and the rapid advent of FHIR-enabled services are both a huge opportunity to evolve what we do and how we do it and a potential albatross around the neck of people and organizations who cannot change fast enough to succeed in the new world.

Where will we land? No one knows for certain, but we do know that it will likely take a while to figure it all out. That's okay. At the same time, regulations moving us into the future are upon us and more are coming. It's a brave new world that's still changing below our feet. Here at MHDC we believe that we'll emerge in a better place, but to get there we all need to work together to collaborate where we can, solve the big problems together, and envision the future we want as we work toward making it a reality.

Be safe, stay well, and fasten your seat belt.

Denny Brennan, Executive Director

Please let us know what you think of our newsletter at newsletter@mahealthdata.org and look for our next issue. Thank you for your continued support and participation!

MHDC Events

Meetings this month:

  • DGC Steering Committee: June 16, 2:30-4pm
  • DGC Working Group: June 2, 9, 16, 23, 30 11am-12:30pm
  • NEHEN Business Users Group: June 3, 9-10am
  • Webinar: Hooper, Lundy & Bookman: June 10, 10:30am-12pm
  • Vantage Point: Micky Tripathi: June 3, 11am-12pm

Want to learn more about any of these meetings? Email info@mahealthdata.org

MHDC Webinars

Join us for our upcoming webinar Owning an Opportunity: Digital Health Developments for 2021 presented by Hooper, Lundy & Bookman on June 10 from 10:30am - noon.

Missed any of our webinars in 2021? Click here to see what you've missed! 

Interested in holding an MHDC webinar or have an interesting topic you'd like to present? Contact us at webinars@mahealthdata.org

Introducing The Vantage Point Series

 Join us for exclusive interviews with some of healthcare’s most recognized leaders as they reveal how and why they chose their careers, what they learned on their journey, and how to apply their insights to the everchanging future of healthcare.

Our next Vantage Point Series event features Micky Tripathi, National Coordinator for Health Information Technology, on June 3rd from 11am-12pm.

Missed our previous Vantage Point Series interviews? You can find the recordings here.

Spotlight Analytics Update

Spotlight Business Analytics helps healthcare organizations run custom analytics on health data including market share, patient origin, disease prevalence, cost of care, and comparative costs and outcomes for acute care hospitals.

MHDC recently updated the home page dashboard in Spotlight to better match user need and make navigation easier. We are also working on incorporating new datasets in Spotlight to enhance the analytics and reporting including local and national comparison metrics. We'll keep you posted on our progress.

We are also planning to schedule meetings with current Spotlight users to discuss how to make Spotlight better and meet the different needs and objectives of each user.

Our current status is:

Loaded and available for use:

  • Massachusetts Hospital Inpatient Discharge Data FY19 (HIDD)
  • Rhode Island Hospital Inpatient Discharge Data FY19
  • Massachusetts Emergency Department Discharges FY19 (ED)

Expected very soon (CHIA has begun distributing this dataset): 

  • Massachusetts Outpatient and Observation FY19 (OOD)

Future planned data:

  • New Hampshire Facility Discharge Data Sets (Application pending)
  • Maine Hospital Inpatient and Outpatient Data

Please feel free to drop us a line with any questions or comments at spotlight@mahealthdata.org. In the meantime, thank you for being a Spotlight Analytics user and a member of this community! Feel free to visit our Spotlight Business Analytics page or email us at the address above for more information.

DGC Update

The Data Governance Collaborative (DGC) at MHDC is a collection of payers and providers throughout the region exploring ways to better exchange health-related data incorporating industry standards and automation as much as possible.

The DGC expects to move to the implementation phase of the code mapping service soon. This system will be available to anyone (with a discounted rate for DGC members).

We continued our successful series of deep dives, holding a discussion on immunizations that looked at the workflows and related data on May 26. We plan to spend time over the next few weeks collating what we learned and tying it back to FHIR resources and possible extensions needed to support the identified data.

We are currently determining which type of data to delve into next and consider in detail for future exchange support. We have also been participating in industry events and workgroups that help inform our work and looking more closely at the work of HITAC and new guidance and documents flowing out of both CMS and ONC related to standards and interoperability.

Membership in the DGC is open to any payer or provider with business in Massachusetts - big or small, general or specialist, traditional or alternative. Want to know more? Email datagovernance@mahealthdata.org

NEHEN Update

NEHEN reduces administrative burden through the adoption of standard X12 (HIPAA) transactions for payer and provider trading partners. It is a cornerstone service for payer and provider trading partners wishing to exchange industry standard X12, HIPAA compliant transactions in a real-time, integrated manner using APIs. Because of our unique governance, non-profit status, and membership-based model, NEHEN is able to offer very competitively priced services relative to the market at large.

Working with our technology services provider TriZetto Provider Solutions (TPS), NEHEN has built an advanced development roadmap including a real-time, API-based pre-payment estimator (PRE) that gives patients an estimate of the expected cost of specific services. This will help providers and payers meet the requirements of the No Surprises Act recently passed by Congress.

For information about NEHEN please contact us at members@nehen.org.

Electronic Prior Authorization Initiative 

This project is a prototype implementation that automates prior authorization transactions using the industry standard, open platform methods developed by the HL7 DaVinci Prior Authorization workgroup. This project will be compliant with the three related implementation guides which utilize open, FHIR based API exchange methods. This will allow each payer and each provider to implement a single prior authorization process and format for exchange so long as all of their exchange partners adhere to the same standards.

Last week DaVinci announced a program offering a temporary exception to the HIPAA requirement forcing prior authorization requests to use the X12 278 format. This allows a limited set of approved payer-provider pairs to accept and process prior authorization requests directly in FHIR without converting to X12 during data exchange. This program has strict requirements and participants must be approved by CMS. We will be evaluating whether our project is suitable and, if so, if we want to accept the additional program requirements. Watch this space.

Meanwhile, project members have begun meeting to discuss detailed implementation components and plans and have decided to use separate solution providers on the payer and provider sides of the ePA exchange. We are also refining the selected use cases and our approach to implementing them and working to finalize the participation agreements with our payer and provider partners.

For more information email us at epa@mahealthdata.org.

Industry Events

Interested in webinars and online conferences through June? Here are some we recommend (they're free unless otherwise noted):

We do periodically post webinars we plan to attend on social media, so feel free to follow us on Twitter (@mahealthdata) and LinkedIn for more webinar ideas and for our take on interoperability, data, health equity, telehealth, APIs, and other topics of interest.

Have an upcoming event next month to suggest? Write us at newsletter@mahealthdata.org - no self-promotion please.

WEDI Spring Forum 2021 Overview

The WEDI Spring Forum 2021 was a five day conference (split into two preview days and three formal conference days) from May 14-20. Although generally not official, each day had its own flavor and area or areas of focus. The standard Friday preview day was expanded a bit and covered prior authorization and burden reduction. The Monday preview day, traditionally a time for WEDI workgroups to meet, was split between Da Vinci overviews and sponsor demo sessions. After keynote sessions from the ONC and CMS, Tuesday was loosely focused on third party apps and digital identity. Wednesday was policy and regulation day, while Thursday was split with the morning focused on health equity and the afternoon returning a bit toward third party apps but with a focus on innovative uses for them and a tie in to price transparency (which was the focus of the final session). The three days of the conference proper did not strictly adhere to these themes, but they did loosely connect several of the sessions.

In general the sessions were varied and good, although there were a few disappointments. We missed much of policy day because of previous commitments, but we hope to watch recordings of some of those sessions to see if anything new and interesting came up. We also missed a keynote address from our friend Micky Tripathi, now the National Coordinator for Health IT. We're sure he had really interesting things to say. We'll get our own chance to hear from him at our upcoming Vantage Point interview on June 3. If you haven't already, you can register to attend here.

Thankfully we managed to attend most of the rest of the conference. Some of the highlights included a session on X12-FHIR data mapping from Cathy Sheppard (the executive director of X12), a discussion of third party app developer expectations, a really fascinating session on the role of a chief burden reduction officer, a look at the CARIN Alliance initiatives around digital identity, and a look at current Mayo Clinic work (ostensibly on health equity in AI but it went well beyond that).

The X12-FHIR mapping session led by Cathy Sheppard was really interesting given the current need to translate FHIR resources to and from X12 278 format when following the Da Vinci Prior Authorization workflows to meet HIPAA requirements (note that Da Vinci just announced a limited test program that permits payers to apply for exceptions if they meet certain criteria, agree to perform specific analysis, and are approved by CMS so this requirement may eventually go away). The defined mappings are based specifically on the resources used by the relevant Da Vinci implementation guides; this is not a general X12-FHIR mapping and they happen at the embedded element level within X12. The updated X12 implementation guides will include mapping information for each element and also be included in a single table in an appendix of each guide that collates together all of the mappings relevant to that guide.

The third party app developer expectations session was technically a sponsored session from Axway, led by Ruby Raley and third party developer Jennifer Blumenthal of OneRecord. They had a discussion about what a developer expects in the way of documentation, support, registration information, and more. Some of the key takeaways from this session include that third party apps are not necessarily mobile apps; they can be desktop apps, browser extensions, back end apps that pull data to provide data visualization, or more. If you can imagine it and it can send API requests it qualifies. Also, as we move from a project/team based world to a self-serve/automated world it's not just about the technology; a lot of the work has to be about process change to support the new models and workflows. From a technical perspective, patient matching came up as a major pain point - having some reasonable mechanism for taking the data available to a third party app developer and matching it to internal data at a payer is going to be important. Interestingly, there was a session later in the conference on one payer's view of third party developer needs and, while they've clearly put some time and effort into thinking about this issue, it was a much more traditional view focused on basic API documentation. The Axway session took that as a given and talked about what's needed beyond the basics.

Perhaps the most interesting session of the whole conference was led by Claudia Williams of Manifest Medex. It posed the idea that healthcare organizations should appoint a Chief Burden Reduction Officer to monitor not just clinician burden but also patient burden (and healthcare related burden on other parties as well). Interoperability generally and a move toward more automated prior authorization specifically helps, but it's just addressing one piece of the puzzle. One thing that particularly struck us was the notion that in many ways the industry currently asks patients to be their own population health officer, gathering and organizing data to determine what health needs have and have not been met, gathering summary treatment data, and coordinating communication with others involved in their own healthcare. The burden is just as real for engaged patients as it is for engaged providers and we need to consider those burdens too - hopefully the Patient Access APIs and other interoperability advances will help.

The CARIN Alliance has really branched out lately and one current area of focus is digital identity. Ryan Howells presented some of their recent work in this area including the idea of digital identity cards like digital driver's licenses. He noted five areas that need to be addressed to move forward in this area: identity itself, authentication, trust, consent, and matching (it always comes back to matching people records, be it patient, member, or some other role). He also talked about the need for centralized, standardized identity providers with some type of independent certifying organization ensuring that they are at least as accurate and secure as the solutions currently in use. One of his colleagues presented a more specific use case for digital insurance cards at the Da Vinci Education event a few weeks ago; their work in this area is really interesting and something that bears watching in the future.

The keynote session on the final day of the conference was given by our friend Dr. John Halamka from the Mayo Clinic. For those of you who attended our recent CIO Forum with John there wasn't much new ground here, but it was an interesting overview of work at Mayo around the collation and use of large data sets for various uses including machine learning and AI. He discussed their decision to collate millions of records in the cloud but only make the data accessible inside containers - it cannot be exported for external use - and how everything they do uses RESTful APIs, usually FHIR or FHIR extensions - it's a foundational principle of their work. He also talked about the need for nutritional labels for machine learning algorithms that tell users what ground truth data was used, the types of algorithms and approaches used, and the performance of the algorithm for different use cases. Perhaps most interesting was his discussion of SDOH data and some of the potential sources including using data from grocery store loyalty programs and comparing it to health outcomes - but only if it can be done ethically and within reasonable privacy and consent frameworks.

The final session of the conference was on the new No Surprises Act, a law covering price transparency and several other areas of interest to health IT (and a whole bunch of other things that are unrelated to our areas of interest). Interestingly, the DGC Steering Committee had just looked at this same rule the day before. The two perspectives were quite different. Clearly there is much confusion about this law which goes into effect at the start of the plan year beginning on or after January 1, 2022. Since this article is about WEDI we're going to present the WEDI perspective here - stay tuned for future discussion that refines the rules as we get closer to the enforcement date.

This was a panel discussion moderated by WEDI's VP of Federal Affairs Robert Tennant with Beth Davis of Allscripts, Matthew Albright of Zelis, and Stanley Nachimson of Nachimson Advisors. They see the required process for compliance as something like the following:

1. A patient schedules an encounter, test, procedure, or treatment at a specific provider organization

2. The provider has either 1 day (if the appointment is in less than 10 business days) or 3 days (if the appointment is more than 10 business days away) to send a good faith estimate to the patient's payer

3. The payer has either 1 day (if the appointment is in less than 10 business days) or 3 days (if the appointment is more than 10 business days away) to send the patient/member an Advanced Explanation of Benefits document via either postal mail or electronically

This process may also be initiated at the request of a patient without scheduling any actual services. This allows a patient to request information about the same type of visit, test, procedure, or treatment from multiple providers for the purposes of comparison shopping based on price.

Again, the process and steps - even the triggers - listed above are a bit different from those we discussed in the DGC. More investigation is certainly warranted. Regulations related to the rule are supposedly in process and expected later this year - hopefully they will clear up any confusion that remains after more research.

Tying in with the third party app theme of the day, there was a fair bit of discussion around a new type of third party app that might crop up just to process and compare these Advanced EOB documents and cover various use cases using price transparency data. It wasn't clear if there was any expectation that this data would be added to the Patient Access API requirements in the future, but it's clear folks expect it to be available via some form of APIs sooner rather than later.

There are other clauses in the law including a continuity of care clause that requires payers and providers to both carry on with previously scheduled service under the rules and payment terms of a terminated contract for 90 days after the termination - both the payer and the provider organization must act as if the termination had not occurred in terms of pricing, cost sharing, and other financial arrangements.

It also provides rules and guidelines for providers around updating payers with information for their provider directories in a timely manner and requires payers to verify the information they receive for that purpose.

All in all, the WEDI Spring Forum 2021 was a success from our perspective. MHDC wasn't able to participate as fully as we'd hoped and there were some sessions that raised more questions than they provided answers, but WEDI generally has good content on pertinent topics that help us learn more about a wide variety of areas of interest to us and to you, our members. We believe this helps us serve you better which is our ultimate goal.

LGBTQ+ Pride Month

LGBTQ+ Pride Month is a time to celebrate LGBTQ+ identities, progress, and contributions, learn about the history of this community, and also to highlight continued inequities and to advocate for LGBTQ+ rights. In recent months there has been a rise in anti-trans legislation, especially targeting trans youth and access to healthcare. This article discusses the issue from the perspective of a Boston Children’s Hospital pediatrician that works with trans youth.

Learn more about Pride Month:

Wrapping Up

Before we go, here's a reminder of upcoming data exchange deadlines from ONC and CMS (including the CMS rule that's currently frozen, as noted by *):

And that's it, folks. Loved it? Hated it? Have an idea for next time? Send us feedback and suggestions about this newsletter at newsletter@mahealthdata.org or send us feedback and suggestions about anything else at info@mahealthdata.org.

Massachusetts Health Data Consortium
460 Totten Pond Road | Suite 690
Waltham, Massachusetts 02451

For more information,
please contact us at info@mahealthdata.org

join our mailing list

© Massachusetts Health Data Consortium