The Interoperability of Health IT
Policymakers focus on which systems and devices can exchange and interpret shared data — and radiology is key to the discussions.
Most of us have had the following experience: We are either preparing for a procedure or interpreting an imaging examination, when we realize we do not have access to prior images from an outside facility. Even when prior images are available, basic clinical information (such as operative reports or pathology reports) may be missing. This shortcoming may result in unnecessary imaging, an inconclusive report, needless follow-up, or an unwarranted intervention.
This occurrence is not radiology-specific, as universal availability of clinical information falls short across medicine, affecting all specialties. In fact, two out of three U.S. hospitals cannot locate, retrieve, send, and/or meaningfully integrate EHRs for patients from other sites.1 Policymakers are pushing forward an initiative too big for radiology to ignore: interoperability.
At the 2018 Healthcare Information and Management Systems Society meeting in March, Jared C. Kushner, director of the White House Office of American Innovation, remarked, “The president is determined to make interoperability a reality for all Americans.” During the same session’s Q&A portion, CMS administrator Seema Verma, MPH, stated, “What we’re envisioning is being able to gather all of your healthcare data in one particular place.” Verma went on to describe several CMS initiatives aimed at empowering patients by giving them control of their own medical data, including the following:
• MyHealthEData is intended to provide patients with electronic access to their own health records and empowers them to share that information safely and securely with providers of their choice.
• Medicare’s Blue Button 2.0 (an upgrade from the 2010 launch of Blue Button) provides beneficiaries with their medical claims data in a universal and secure digital format.2
A few weeks later, CMS announced that the Merit-Based Incentive Payment System (MIPS) performance category, Advancing Care Information, would be renamed as Promoting Interoperability (PI). At the same time, the hospital EHR Incentive Program was renamed as the Promoting Interoperability (PI) Program. Also relevant to this discussion is the December 2016 passage of the 21st Century Cures Act, which provides stronger definitions of information blocking and interoperability. The law created a fine of up to $1 million for vendors guilty of blocking the free flow of data and prescribed penalties for providers who do the same.
What does all this mean for our field? Radiology has a history of encouraging the availability of images. Under the old Physician Quality Reporting System (since replaced by the MIPS Quality Performance category), radiology had a measure related to searching for prior CT scans through a secure, shared archive. Nonetheless, radiology has been slow to embrace the meaningful use of EHRs. This is somewhat understandable, as the meaningful use requirements have generally been directed more toward primary care than imaging. In addition, we received a hardship exemption from the old pre-MACRA meaningful use program from 2015 through 2019. That exemption largely continues under MACRA and its Quality Payment Program, since most diagnostic radiologists are classified as non-patient-facing. But this exemption may not last forever.
The steps necessary to achieve universal interoperability largely fall on our facilities, healthcare systems, and the vendor community. However, as imaging professionals, we can inform the discussions. Most radiology professionals do not need to be experts on interoperability, but general knowledge of the applicable terms is important. This will allow for more effective communication with the vendor community and inform actions such as PACS upgrades toward interconnectivity and interoperability. Several relevant terms are included below.
There is also a secondary benefit to be gained. Enabling greater interoperability allows us to score better under MIPS. Specifically, when reporting under the PI Program becomes mandatory, an attestation that we are not engaged in information blocking is necessary. Further, performance points are awarded for enabling patient access to medical records.
Let’s return to my opening scenario: Imagine seamlessly accessing all prior images from different sources at the start of a procedure or when interpreting an imaging examination. Imagine how much more informed our reports and clinical decision-making would be. Making this dream a reality is doable, and we have a responsibility to ensure that we get there in the best way possible.
By Ezequiel Silva III, MD, FACR, Chair.
1. Holmgren AJ, Patel, V, Adler-Milstein, J. et al. Progress in Interoperability: Measuring US Hospitals’ Engagement in Sharing Patient Data. Health Affairs. 2017;36(10):1820–27. Available at bit.ly/Progress_Interoperability. Accessed June 10, 2018.
2. Trump Administration Announces MyHealthEData Initiative to Put Patients at the Center of the US Healthcare System; 2018. Available at bit.ly/CMSPressRelease. Accessed June 10, 2018.