Unanswered questions
When introducing the proposed interoperability rules, CMS administrator Seema Verma stressed the need for accessible data that enhances care coordination, yet the proposed rules don’t provide clear guidelines about how this should be achieved.

For example, how should a provider format data that is sent to another provider? Should details be in coded lists? How should unstructured free text be shared? Depending on the format, the sender might need to manipulate the data or put details into a codified format. On the receiving end, users may need to sort through pages and pages of data to determine what information is new, what details duplicate existing records, and what items should be accepted or disregarded.
Also unclear is whether EHR vendors will be required to allow users to incorporate shared records generated by other EHRs. Many EHRs currently don’t support the integration of outside records, which means physicians have to leave their standard workflows to access the clinical records sent from other providers.

The proposed rules include penalties for providers who fail to share clinical records, but don’t specify what data clinicians are required to share. For example, does a specialist need to send a patient’s primary care provider the patient’s complete record, or is it sufficient to only forward details from the most recent visit? And when a primary care provider sends records to a specialist, should the complete record be transmitted or only the patient’s problem list and medications?

It’s a long road ahead
When considering how best to address these and other unanswered questions, HHS leaders must prioritize efforts to ensure data usability. The electronic sharing of patient records is valuable, but only if clinicians have ready access to the right data for the right patient at the point of care.

By identifying a standard for the transmission of electronic clinical data, we are one step closer to having ready access to clinical data via a standardized “plug”. However, we must be cautious not to create a system that encourages (under the risk of penalties) the dumping of unmanageable volumes of clinical data between providers. To prevent this, HHS must continue identifying standards that keep us moving down the long road to the dream of true interoperability.

About the author: David Lareau is the chief executive officer of Medicomp Systems. Lareau, who joined Medicomp in 1995, is responsible for operations, strategy, customer success and product management.

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