Makes recommendations to get the right data to the right people at the right time while keeping it private and secure
Washington (June 3, 2019) – The
Alliance of Community Health Plans (ACHP) fully supports the modernization
of data systems and seamless health care data exchange. ACHP members are
leaders in providing consumers with timely, relevant health information such as
cost estimates that include an individual’s deductible and copay. But ACHP has
concerns with the health data interoperability rules proposed by both ONC and
CMS, particularly around implementation timing and data security. Given the
complexity and sensitivity of widespread data sharing, ACHP proposes CMS issue
an interim final rule, to provide adequate time for consumers, health plans,
clinicians and other stakeholders to weigh in on proposed systems, operational
requirements and feasibility of changes suggested in the rule.
“These rules are an important step in health care affordability, putting patients first and giving them the power to make wise health care decisions. Safe and secure information sharing is critical to improving coordinated patient care and health outcomes,” said ACHP President and CEO Ceci Connolly. “We are concerned that the pace of implementation and the heavy reliance on third party apps not covered by HIPAA will jeopardize the security of patient information. We also believe medical providers should be responsible for providing patients accurate, private medical information – and have serious concerns about the unintended consequences of health plans being required to provide that data.”
The technical standards required to implement the proposed rule are not ripe for adoption. For this reason, ACHP recommends CMS issue an interim final rule to provide more time for maturity of the standards, greater clarity about the expectations of health plans and allow for additional stakeholder feedback to refine and strengthen the rule. ACHP’s 24 member organizations are eager to work with HHS to continue refining the rule, particularly around implementation and nonprofit, regional health plans.
ACHP also recommends that CMS updates the implementation timeline with requirements phased in 18 months from the issue of the final rule. Ideally, CMS would synchronize the requirements of health plans and providers to a 2022 timeline, which would allow for a reasonable timeframe for consumer education, the maturity of standards to make sure consumers are provided actionable information and help ensure cost efficiencies in modernizing the technology.
Nonprofit health plan members of ACHP are dedicated to making sure the right data is received at the right time from the right source by the right person while making sure information is kept private and secure. They take their commitment to health plan members — their care, their information, and their privacy — very seriously and are weary of a technology solution that endangers that privacy just for the sake of deploying technology.
ACHP member health plans often work with small margins, operating judiciously and maximizing the value of every dollar. As a result, finding sufficient funding to implement the interoperability rules would place additional burdens on plans already attempting to deliver the most valuable care possible. That is why ACHP also recommends that CMS consider grant funding be made available, particularly for smaller, community-based organizations, to fully stand up the systems required ensuring privacy and safety of patient data.
Lastly, ACHP encourages HHS to collaborate with Congress on a reasonable federal solution to the difficult problem of consumers being surprised by large and or unreasonable provider charges, and refrain from attempting to resolve this problem via data regulation. HHS should work with Congress to work to better understand that surprise bills are generated by health care providers, not health plans, and are the result of non-contracted providers billing patients for emergency or involuntary care.
“ACHP and its members are committed to patient safety and quality coverage,” said Connolly. “We look forward to serving as a resource to ONC and CMS as we collectively work to modernize current health data systems and improve care coordination.”
Full comment letter to CMS here.
Full comment letter to ONC here.
The Alliance of Community Health Plans (ACHP) is a national leadership organization bringing together innovative health plans and provider groups that are among America’s best at delivering affordable, high-quality coverage and care. ACHP’s member health plans provide coverage and care for more than 21 million Americans across 34 states and the District of Columbia. These organizations focus on improving the health of the communities they serve and are on the leading edge of innovations in affordability and quality of care, including primary care redesign, payment reform, accountable health care delivery and use of information technology. To learn more, go to www.achp.org and follow ACHP on Twitter @_ACHP.