Mirror, Mirror on the Wall, Who’s the FHIRest of Them All?

We have all heard the fairytale of the Snow White and the Evil Queen. It has always been a mystery to me how the magic mirror decided what was “fair”. Could we have a similar mirror that tells us which solution is the right fit when we need one? Earlier this year, the U.S. Department of Health and Human Services (HHS) announced two final rules, one by the Centers for Medicare & Medicaid Services (CMS) and the other by the ONC for implementation of the 21st Century Cures Act. These final rules established certain requirements for healthcare providers, EHR vendors and payers to support patients’ access and control of their electronic health information. These requirements are based on HL7® FHIR® R4 standard. In the last few months, there has been an inundation of new offerings in the healthcare IT marketplace all claiming to be able to meet or even exceed these requirements. Unfortunately, there is no magic mirror available that can tell you which solution is truly ready to meet these requirements.

So, how do you really decide which FHIR® solution is the fairest choice for your organization? Let’s start with some facts and follow a logical path.

Cover the Basics

Fast Healthcare Interoperability Resources - FHIR® is a next generation healthcare standards framework created by HL7. It is a very elaborate specification built on a set of modular healthcare data components called “Resources”. These Resources can be assembled in various ways to solve real-world clinical and administrative problems. No FHIR solution provider claims to support every single feature. The final rule does NOT require you to support all the Resources, or all the other features included in the FHIR specification either. When selecting a FHIR solution, you should ensure that the solution, at a minimum supports the features required for compliance for your organization.

Compliance is Just a Means to an End. Reach Beyond.

The ONC rule requirements focus on a minimum data set based on USCDI v1 standard. We discussed in our previous blog how this dataset aligns with the most common standard today – CCDA. Although the EHR developers do NOT need to update their certification to support the USCDI dependent certification criteria until December 31st, 2022, they will still need to support data-sharing, so they are not counted as a Information Blocker by Apr 5, 2021. As most EHRs currently support data-sharing through CCDA as part of their certification, EHR vendors will need to do the following:

Update their current CCDA to include the additional data elements included in the USCDI v1
Make the updated CCDA available electronically to patients through a patient portal and/or the API
Make the updated CCDA available electronically to other providers using the Direct Method (Edge Protocol)

The Information Blocking requirements can be met by just updating the CCDA to meet the Apr 5th, 2021 deadline. However, if I had the magic mirror, I could show you that working towards making this data available through a FHIR API now would be a better approach to meeting current and future Cures Act requirements.

The compliance pressure may cause organizations to see FHIR-based solutions as commodities and select solutions based on short-term goals. This could be a costly mistake. That is exactly what happened with meaningful use and the EHR solutions a decade ago. The stakes are a lot higher this time with penalties up to a million dollars. Rather than just focusing on meeting the compliance requirements, organizations should view FHIR as an opportunity to support multiple new complex use-cases that are being created by the democratization of healthcare solution development through FHIR. These use-cases include but are not limited to consumer generated data. By adopting a strategy that looks beyond just meeting compliance requirements, organizations will be able to prepare to leverage FHIR to create a foundation for providing better patient care.

Go with the Seal of Approval

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With a multitude of options available to pick from, looking at solutions with 2015 Edition Cures Update Certified API is a smart way of narrowing down your options. ONC adopted a rich and rigorous testing tool called Inferno to ensure and verify that Health IT vendors are following the industry standards for FHIR and complying with Cures Act requirements. The certification from Drummond Group, which is authorized by ONC to test FHIR servers using Inferno, validated BlueButtonPRO as the first FHIR based API to pass all the requirements.

While ONC had a clearly defined certification requirements for healthcare providers, EHR vendors and Health Information Exchanges (HIEs), the CMS regulation requirements were not as well defined. However, thanks to CARIN alliance’s recent contribution, CMS did provide an update and officially announced the specifications for supporting FHIR related requirements for payers. A lot of these requirements like the Patient Access API overlap with the ONC rule. These deadlines are just few months away and BlueButtonPRO solution is well positioned to help you with CMS-9115 (Interoperability and Patient Access Rule) as well.