CMS Proposed Rule Name of Rule Medicare and

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CMS Proposed Rule Name of Rule Medicare and Medicaid Programs; Patient Protection and Affordable

CMS Proposed Rule Name of Rule Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Interoperability and Patient Access for Medicare Advantage Organization and Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans in the Federally- Facilitated Exchanges and Health Care Providers Applies to MA Plans and Medicaid/CHIP Managed Care Plans Providers (hospitals) States (transmit Medicaid MMA info to CMS daily for dual eligible) Timing Many provisions proposed with a 1/1/2020 deadline 1 10/28/2020 Clinical Ancillary Services & Systems / Care Delivery Technology Services 2017 © All Rights Reserved.

CMS Proposed Rule 2 • Implement an API to allow members to use third-party

CMS Proposed Rule 2 • Implement an API to allow members to use third-party apps to access claims, provider directory, formulary data and plan Core coverage/cost data Requiremen • Send/Accept to/from next payer USCDI clinical data set ts available to the health plan (5 years back) via different Health methods, including API, Direct, HIE Plans • Health plan required to join a trusted exchange network (existing at time of rule deadline, even if ONC TEFCA rule not • completed) Information blocking: Public reporting of providers that responded “no” to three preventing info blocking attestation Core statements Requiremen • Publicly report provider who have not added a digital address ts for to their record in the NPPES system Providers • Hospitals required to provide electronic notification to known primary care provider of a patient when admitted, discharged • States: Transmit Medicaid MMA info to CMS daily or transferred • Comments on how incorporating Promoting Interop. in Other Innovative Models Requireme • RFI: Patient Matching (leveraging CMS authority to improve nts / patient ID) Provisions • RFI: How CMS can promote interoperable systems in LTC, post-acute care 10/28/2020 Clinical Ancillary Services & Systems / Care Delivery Technology Services 2017 © All Rights Reserved.

References on Quality, HL 7 Standards, FHIR • Several references to quality payment and

References on Quality, HL 7 Standards, FHIR • Several references to quality payment and quality improvement programs in the NPRM, mostly to explain how the new requirements on health plans and providers would be consistent with these programs • No specific references to quality reporting, e. CQMs, quality reporting standards • Several references to HL 7 FHIR, but in the context of APIs and consumer access to health information from health plans (claims, provider directories, formularies, etc), and hospitals (ADT notifications). • Don’t see specific areas for this Work Group to comment on 3 10/28/2020 Clinical Ancillary Services & Systems / Care Delivery Technology Services 2017 © All Rights Reserved.

ONC Proposed Rule Name of Rule Applies to Timing 4 10/28/2020 21 st Century

ONC Proposed Rule Name of Rule Applies to Timing 4 10/28/2020 21 st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Health IT Vendors required to: • Develop technology for new/modified ONC 2015 Edition CEHRT Criteria and Standards • Support interoperability, expand patient access, and avoid engaging in information blocking • Meet 7 new Conditions of Certification and ongoing Maintenance of Certification requirements Providers, who must use CEHRT for CMS programs, required to: • Implement new/modified ONC 2015 Edition CEHRT Criteria and Standards • Support interoperability, expand patient access, and avoid engaging in information blocking Generally changes to be implemented within 24 months of final rule Clinical Ancillary Services & Systems / Care Delivery Technology Services 2017 © All Rights Reserved.

ONC: 2015 Edition Certification Criteria Updates q Removes 2014 edition certification criteria as they

ONC: 2015 Edition Certification Criteria Updates q Removes 2014 edition certification criteria as they are no longer applicable q Removes 2015 edition certification criteria that were deemed unnecessary q Modifies 2015 edition certification criteria, such as: • Adopts e. Prescribing standard NCPDP SCRIPT 2017071, as expected (effective 1/1/2020) • Adopts the US Core Data for Interoperability (USCDI) standard to replace common clinical data set (CCDS) • Modifies criteria for EHI export that would require IT developers to provide the capability to electronically export all of patients EHI data • Modifies Data Segmentation for Privacy (DS 4 P) and Consent Management from document level to data element level • API changes (next Slide) 5 3/20/2017 Clinical Ancillary Services & System / Care Delivery Technology Services 2017 © All Rights Reserved.

ONC: 2015 Edition Certification Criteria Updates 6 3/20/2017 Clinical Ancillary Services & System /

ONC: 2015 Edition Certification Criteria Updates 6 3/20/2017 Clinical Ancillary Services & System / Care Delivery Technology Services 2017 © All Rights Reserved.

ONC: Information Blocking Provisions q Defines key terms, including Electronic Health Information (EHI) •

ONC: Information Blocking Provisions q Defines key terms, including Electronic Health Information (EHI) • EHI, in addition to patient personal and clinical data, includes data related to eligibility, benefits, billing information, and payment information q Provides examples of practices likely to interfere with access, exchange, or use of EHI • Restrictions on access, exchange, or use of EHI • Disabling interoperability capabilities of Health IT • Impeding interoperability innovations and advancement • Rent-seeking and other opportunistic pricing practices • Non-standard implementation practices q Codifies compliance with information blocking provisions as a Condition of Certification q Introduces 7 exceptions to the general prohibition on information blocking (next slides) q Requests for information 14 3/20/2017 • Disincentives for health care providers • Including pricing transparency as EHI in future • Clinical Ancillary Services & System / Care Delivery Technology Services 2017 © All TEFCA certification criteria Rights Reserved.

ONC: Information Blocking – Seven Exceptions q § 171. 201 Exception 1: Preventing Harm

ONC: Information Blocking – Seven Exceptions q § 171. 201 Exception 1: Preventing Harm q § 171. 202 Exception 2: Promoting the Privacy of EHI q § 171. 203 Exception 3: Promoting the Security of EHI q § 171. 204 Exception 4: Recovering Costs Reasonably Incurred q § 171. 205 Exception 5: Responding to Requests that are Infeasible q § 171. 206 Exception 6: Licensing of Interoperability Elements on Reasonable and Non-discriminatory Terms q § 171. 207 Exception 7: Maintaining and Improving Health IT Performance 15 3/20/2017 Clinical Ancillary Services & System / Care Delivery Technology Services 2017 © All Rights Reserved.

ONC: New Conditions of Certification for Vendors q Establishes seven conditions of certification with

ONC: New Conditions of Certification for Vendors q Establishes seven conditions of certification with accompanying maintenance of certification requirements that express initial and ongoing requirements for health IT developers and their certified Health IT Modules: (1) Information Blocking (2) Assurances (3) Communications (4) Application Programming Interfaces (APIs) (5) Real World Testing (6) Attestations (7) Future Electronic Health Record (EHR) reporting criteria submission 16 3/20/2017 Clinical Ancillary Services & System / Care Delivery Technology Services 2017 © All Rights Reserved.

Next Steps • Define comment statements on identified areas to comment • Present/discuss with

Next Steps • Define comment statements on identified areas to comment • Present/discuss with Work Group • Incorporate into comment template from HL 7 Policy Advisory Committee • Achieve WG approval (March 29) • Submit to HL 7 PAC (April 3) 17 10/28/2020 Clinical Ancillary Services & Systems / Care Delivery Technology Services 2017 © All Rights Reserved.

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