How a Directory Can Streamline Interoperability Rule Compliance

As payers and vendors scramble to comply with the interoperability rule, various nonprofits seek to streamline this interoperability process with innovative solutions, such as CAQH’s upcoming directory.

Streamlining is crucial given the hefty number of individual connections that the interoperability rule will require, according to April Todd, senior vice president of Committee on Operating Rules for Information Exchange (CORE) and explorations for CAQH.

“Putting the ability in patient's hands to get more of their healthcare data creates the need for a very large number of organizations to connect with each other,” Todd explained to HealthPayerIntelligence.

“We've calculated this as probably over 300,000 different potential connections that could occur between health plans and app vendors and Medicaid agencies. That’s a pretty unwieldy volume of connections for each one of those organizations to help support patients in getting their information.”

To streamline interoperability, CAQH is in the process of formulating a directory of health plan and vendor information. The directory enables entities to more safely connect with payers, providers, and vendors across the nation to create data pathways.

Todd characterized CAQH’s solution as a “matchmaker,” pairing public and private payers with vendors. CAQH is well-positioned to play the part: the nonprofit already works to connect and streamline interactions between 1,000 health plans, 1.6 million providers, government entities, and vendors, according to its website.

The directory does not make the connections on its own, Todd explained. Rather, it provides health plans and vendors with the necessary information to send each other data. It minimizes the amount of searching and endpoint testing that payers and vendors have to do in order to achieve interoperability and transfer patient data.

CAQH is still in the process of working with a work group of payers to assess what information would be most useful for them to know about the vendors with which they connect via the directory. But they have already established some of the categories of questions.

One category that payers will see when they search through the directory is the identity of the organization. This might be verified with a digital certificate or a chief financial officer’s attestation.

Another category would be security policies including specific privacy provisions.

Data use is also a key subject on which CAQH will request information from vendors.

CAQH will also ask vendors about FHIR compliance within their apps. Additionally, CAQH will test the endpoints to make sure that they have correct structure.

There have been a number of challenges that the nonprofit has faced when constructing this directory.

As with many healthcare initiatives, aligning expectations and objectives across the various parties is difficult. In this case, defining the provisions that healthcare organizations in the directory will use to evaluate one another is difficult to establish.

“One of the bigger challenges in a directory like this is making sure that we are collaborating broadly and across all types of plans to make sure that how the directory is structured will serve everyone's needs,” Todd added.

However, CAQH designed the tool to respond to two of the primary challenges that health plans face as they pursue interoperability rule compliance.

In October 2019, before the rule had been finalized, only a small percentage of payers reported that they were prepared for the changes the final rule could impose. Only 26 percent of payers said that they were “very familiar” with the legislation and the same percentage believed their payer organization to be “very prepared” for the changes.

That said, these payer responses exceeded provider confidence around interoperability readiness.

CMS finalized the interoperability rule for payers in early March 2020, just before the first wave of the coronavirus outbreak in the US. In light of COVID-19, CMS later pushed back the enforcement deadline from January 2021 to July 2021.

Less than a year away from the new enforcement deadline, Todd said that there is still a wide range of preparedness in the healthcare industry. The coronavirus pandemic has certainly added to the challenge of preparing for such a major shift. However, during a technology transition, it is not unusual to see different levels of readiness between the transition participants, Todd indicated.

Nevertheless, the interoperability rule deadline remains top-of-mind. Even with the July 2021 enforcement date, the timeframe remains ambitious, by CMS officials’ own admission.

“The timeline for compliance with the CMS Interoperability and Patient Access final rule is aggressive, and CMS is committed to providing states with the necessary technical assistance to implement these advancements in improving patient access to their data and interoperability,” read the guidance published mid-August 2020.

“That's one of the things that the directory can help with, it can help cut down some of that time to help them find each other,” said Todd.

Simplifying the connection process for payers, providers, and vendors by consolidating each entities’ connection information is key to helping the parties comply with the interoperability rule more quickly.

Ensuring that these hundreds of thousands of individual connections can occur securely also beleaguers payers.

“From a privacy and security perspective, part of what the directory will do is collect information from all participating entities around a whole host of different things and privacy policies,” Todd added. “Security policies are a couple of those elements that we'll be collecting information from for participants and providing that as information to others who may want to connect with them.”

Although CAQH is not establishing a secure connection between payers and vendors, the directory can help provide additional security-related information for payers as they seek to connect with vendors.

CAQH poses a number of questions to directory participants including security-related questions. Participants can choose whether or not they want to answer the question and how much information they want to provide.

“From a vetting perspective, transparently, this is what has been shared with us. So we are doing that vetting and collecting of information, but it will be up to each of the specific participants to decide whether that information is enough and is valid for them to make their own decisions,” said Todd.

Todd expects that CAQH will have a beta test ready later in 2020 and a live version of the directory starting in 2021.

“We're doing a number of different demos in different settings that they can see how the system works and ask questions, get more information,” Todd shared. “We also are engaging different payers along the way to get their perspectives and also app vendors and Medicaid agencies as well. So depending on what kind of interest they express and the questions they have, we can follow up and answer any questions that they have.”