Meeting Interoperability and Federal Data-Sharing Requirements

What is Informatica’s point of view on the CMS interoperability and

patient access final rule? Having more data from more places about your members and patients allows you to deliver bet- ter quality care, reduce the cost of care, improve efficiency, deliver exceptional patient/member experiences, manage the health of populations and all manner of other good outcomes that our healthcare desperately needs, at a lower cost. More data is always better. The interoper- ability rule is long overdue because payers and providers have hoarded the data out of fear that sharing it presents risk to them. CMS puts the patient in charge of their data and how it should be shared, relieving payers and providers of this concern – but also creates a new obligation to effectively and accurately manage patient consent for data sharing.

How are payers approaching

compliance with the rule? Many payer organizations see this as a compli- ance activity and think it is a Fast Healthcare Interoperability Eesource (FHIR) application programming interface (API) requirement: “Let’s just put a FHIR API on top of our existing data structure, and we will be able to respond to an API call and we will be compliant.” We are seeing a lot of organizations start with this approach; it’s an OK starting point since at the end of the day the rule absolutely requires being able to respond to an FHIR API call for a member’s information. However, when you look in greater

depth, there is a huge risk in not approaching com- pliance holistically. By this we mean compliance must include data governance that ties the rule to organizational data management policies and the physical implementation of data sharing. It requires you to know who your members are uniquely. It also requires you to have a very in- depth understanding of your members’ consent for their data to be shared and with whom, their ability to grant and withdraw that permis- sion, and their right to share some of their data or all of their data. You now are exposing your data to the out-

side world, so manual processes that you’ve been using to address any internal data quality issues (typically pervasive for payers) will no longer work in this world, where you need

to share data almost immediately in an elec- tronic format at scale. When we describe com- pliance in these terms to our customers and prospects, we frequently hear back, “You are right—the data management challenge is far bigger than just an FHIR API.”

How is Informatica helping your customers meet the requirements of

the rule? First, we have our thought-leadership point of view as healthcare data management experts: We educate and advocate for a holis- tic approach to meeting both the letter and intent of the interoperability rule. If somebody just wants to look at it as an FHIR API issue, we can certainly help organizations with that, since FHIR is just one of dozens of ways to connect and move data that Informatica supports. More broadly, we have a solution for consent

management that is robust and scalable; a solu- tion for identifying and resolving data qual- ity issues automatically and at scale; a solution for governing the data that you share to ensure inter- nal processes are documented, understood, and correctly applied; and a solution for ensuring the correct data is shared only with third parties that are authorized by the member. The breadth of our solutions addresses all of the data manage- ment requirements needed to comply with the rule, and these capabilities can be implemented incrementally or separately based on the specific needs of the customer. We are in a position to help our customers from their earliest steps of compliance all the way through a full data management approach for holistic compliance.

How has the pandemic accelerated the need for greater data access and

data sharing, in your view? This goes to our entire point of view on the CMS Interoperability rule and the fact that having more data from more places is vitally important for the benefit of the patient and providers. Looking at the pandemic from a patient-care perspective, when a patient comes into your hospital emergency department with COVID symptoms, you want to know as much as you can about that patient so that you can apply all of your predictive model- ing to know what the best treatments and the

Richard Cramer, Chief Healthcare Strategist, Informatica

best course of action is to achieve the best out- come. More data is better, and the more reliable and trustworthy it is, better still. People are going to be going to hos-

pitals where they haven’t been a patient before, so interoperability and data shar- ing are your friend. If you are a patient, you want your doctors and caregivers to know everything about you. If you’re a doctor or a caregiver, you always want to know as much as possible about your patient, but with COVID and all the various predictive models, having this data has been critical to clinical decision-making. Right now, the degree of analytics and pre-

dictive modeling that have gone into determin- ing what the best course of treatment is for an individual with these co-morbidities to deliver the best outcome is at a level of mod- eling and data-driven insight that we typi- cally haven’t ever done in healthcare. Data is important to you as a patient, data is important to the providers to gain the insights these models can provide, and it’s important to an organiza- tion that’s building these predictive models. COVID has created an awareness and acceler- ated interest and demand for predictive insights that would otherwise have taken years to real- ize. COVID has accelerated every organization’s interest in becoming data driven, and which in the long run will be beneficial to all.

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