HHS’s New Rules on Interoperability and Patient Access

By Kevin Fleming

Just last week, two departments within the U.S. Department of Health and Human Services (HHS) proposed new rules that recognize an important and accelerating dynamic in the healthcare industry, patient consumerism.

These rules were designed to further the industry’s transition into a modern, consumer-driven operating model. Though commendable, these rules fall short of enabling a truly patient-friendly healthcare experience. Happily, however, the rules’ technology standards set the stage for hospitals who are committed to winning and keeping patient loyalty.

The rules from the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (OHM) offer similar and complementary provisions designed to improve patient access to their health information and the development of technology to enable the safe, yet free flow of that information between patients, providers and payers. This National Law Review article about the new rules provide an excellent snapshot of the rules, as well as key takeaways. If enacted, healthcare providers will have until 2020 to comply. Here at Loyale, we view these rules as an important next step toward something we’ve always been passionate about.

Bridging the Patient Affordability Gap

One of the most glaring deficiencies in a patient’s care experience continues to be cost, or the perception of cost. Nearly half of Americans avoid care because of concerns about how to pay for it. Unlike any other purchase decision in their lives, patients’ still don’t have the information needed to compare and select the provider that best meets their needs. This issue is being addressed to some degree by a recent CMS rule mandating price transparency, but the standards for price transparency remain too low for any real impact on patient choice or behavior.

But there is some good news…the new HHS rules, if enacted, will establish and promote standards for patient access to health records. Just as important, they specify technology standards to enable the secure, free movement of information across multiple, often disparate systems. These standards call for the development of Application Programming Interfaces (APIs) and Health Information Exchanges (HIEs) to make information more available to patients through third-party applications and developers, with an emphasis on applications that enable easy access via a patient’s smart phone.

The existence of these APIs will enable the rapid deployment of third-party applications like our own Loyale Patient Financial Manager™, a platform developed to inform and engage patients with cost, affordability, payment planning and secure patient communications. By uniting patient health records with financial transparency and choice, patients will stop delaying or avoiding care and choose the provider that meets their needs both clinically and financially.

Expanding the Universe of Patient-Centered Healthcare Providers

Loyale Patient Financial Manager™ is operating today at some of the country’s largest healthcare providers, representing more than $50 Billion in net patient revenue. Loyale’s platform architecture and API readiness aligns with the system structures promulgated in the new HHS rules. The implementation of these technology standards could open the door for providers of all kinds and sizes. Using APIs and HIEs, any provider in the industry will have the technology infrastructure it needs to level the playing field and compete for patients in a changing marketplace.

Wondering what the patient’s experience looks like in this environment? In our view, it looks something like this…

1.    After consulting with their primary caregiver and receiving an MRI, the patient is diagnosed as needing a rotator cuff procedure.
2.    Patient visits a number of accessible provider websites, where their insurance information is collected for verification of eligibility and to calculate remaining deductible.
3.    The Patient is then presented with an estimate for the procedure that includes the total cost. This is an all-inclusive estimate aggregating anesthesiology, surgeon, hospital, anticipated physical therapy and others. The patient estimate reflects this total, calculating the amount that will be covered by insurance and the amount to be paid by the patient.
4.    Additionally, the patient is offered as many as three different payment plan options, so the patient is able to fit their treatment into their household budget.
5.    The patient chooses the provider whose clinical quality and payment options are best suited to the patient’s circumstances.
6.    As the patient moves through their care experience, personalized communications via text, chat and email keep them apprised of the status of their clinical and financial affairs, with easy-to-read, easy-to-understand information about their care and the status of their payment obligations. Consolidated statements are delivered that combine charges from every billing entity in the care episode, presenting a single balance and one easy patient payment.
7.    Additionally, the patient enjoys on-demand access to all their clinical and financial information in a secure online portal, where they can get the information they need and interact with their provider as appropriate to help ensure a great care outcome.
8.    The patient’s care experience concludes, with better outcomes and high patient satisfaction because one of the biggest obstacles to care has effectively been removed. Affordability.

The experience I just described calls for the sophisticated integration of multiple (sometimes dozens of), widely varying systems into a single platform that delivers a seamless and elegant patient experience. Fortunately, HHS’s new rules recognize the importance of this kind of technology framework. A framework that’s being proven at some of the largest healthcare providers in the country. We’ve been saying all along that the future looks bright for healthcare providers and their patients. The new rules from CMS and OHM represent one more important step on that journey.

Kevin Fleming is the CEO of Loyale Healthcare.