CMS National Healthcare Directory RFI Blog Series: (A Quiet) HealthTech Response
By Justin Sims
In November, CMS published a Request for Information (RFI) asking the industry whether they should build a National Directory of Healthcare Providers and Services (NDH).
This is the 3rd post in the series summarizing feedback of various industry constituents. In this blog, we discuss responses from the HealthTech vendor community.
HealthTech vendors were fairly muted in their responses to CMS. Knowing that they are the potential “source of truth” for a directory, the silence was almost deafening from the beleaguered EHR vendors. Could it be that they are weary of CMS imposing a new set of complex requirements? Of the market-leading EHR vendors, only Epic, Athenahealth, and PointClickCare offered input.
There was a little more from Health Information Exchanges (HIEs). The Sequoia Project, CRISP, and Velatura responded, along with some of their brethren. A handful of Health Information Service Providers (HISPs) that run direct secure messaging services also responded.
So what did they all have to say?
If there was one common area of agreement, it was that access to a provider’s digital contact information (or rather a lack of it) is a significant barrier to health information exchange and must be fixed. Epic did a great job explaining how complex this simple statement sounds. They described how an individual provider at a single location has a need for multiple digital endpoints (Direct Addresses and FHIR endpoints).
Other respondents added these key points:
Multiple endpoints serve different purposes (referrals, chart updates, chart requests, and so on.) The problem is that even where that model is in place (not many places), there is no simple way of letting the other party know what all the different endpoints are and how they should be used.
Systems that do the sending or integrating (e.g., other EHRs or HIEs) aren’t yet mature enough to manage information exchange so precisely.
The community also agreed that the source of truth should be the providers, but not many of the HIT vendors put their hands up to offer help. And from our blog on healthcare provider responses, we learned that asking a physician what their digital endpoints are is like asking a payer for the exact cost of a procedure!
So that led several people to recommend leveraging the directories collated by organizations like DirectTrust, Carequality, and TEFCA/ RCE—in other words, focus on improving existing industry initiatives.
As to whether CMS should embark on this initiative, the feedback fell into three camps:
“No” (or not yet)
“Yes” but in a federated manner
“Hell yes!” this is long overdue
Since anyone reading this should understand the Yes and No positions, let me dig in some more on the federated concept. The Sequoia Project, for example, made the point that data deteriorates the further it gets from the “source of truth” (i.e., the provider). Therefore, rather than building a centralized directory, it made better sense for CMS to set a common standard that would help directories exchange information (I’ll show you mine if you show me yours).
Now to the subject of standards and FHIR
If you work in HIT, it’s almost sacrilege to suggest there is a better standard. It’s no great surprise that the industry swung strongly in favor of using FHIR to both submit and retrieve directory data. But these companies are at the sharp end of the standards and are cautious about moving too fast without the standards community finishing their work.
We, for one, believe FHIR is sacred and would never recommend anything less! Do you agree? Send us an email anytime.
Justin