Health information exchange in US hospitals: The current landscape and a path to improved information sharing

Numerous, Complex Barriers Spanning Multiple Stakeholders

In the context of any individual HIE effort, even after the goal is defined, there are a myriad of challenges. In a recent survey of HIO efforts, many identified the following barriers as substantially impeding their development: establishing a sustainable business model, lack of funding, integration of HIE into provider workflow, limitations of current data standards, and working with governmental policy and mandates.³⁰ What is notable about this list is that the barriers span an array of areas, including financial incentives and identifying a sustainable business model, technical barriers such as working within the limitations of data standards, and regulatory issues such as state laws that govern the requirements for patient consent to exchange personal health information. Overcoming any of these issues is challenging, but trying to tackle all of them simultaneously clearly reveals why progress has been slow. Further, resolving many of the issues involve different groups of stakeholders. For example, implementing appropriate patient consent procedures can require engaging with and harmonizing the regulations of multiple states, as well as the Health Insurance Portability and Accountability Act (HIPAA) and regulations specific to substance abuse data.

Weak or Misaligned Incentives

Among the top barriers to HIE efforts are those related to funding and lack of a sustainable business model. This reflects the fact that economic incentives in the current market have not promoted provider engagement in HIE. Traditional fee-for-service payment structures do not reward providers for avoiding duplicative care.³¹ Further, hospitals perceive patient data as a “key strategic asset, tying physicians and patients to their organization,”²⁴ and are reluctant to share data with competitors. Compounding the problem is that EHR vendors have a business interest in using HIE as a lever to increase revenue. In the short-term, they can charge high fees for interfaces and other HIE-related functionality. In the long-run, vendors may try to influence provider choice of system by making it difficult to engage in cross-vendor exchange.³² Information blocking—when providers or vendors knowingly interfere with HIE³³—reflects not only weak incentives, but perverse incentives. While not all providers and vendors experience perverse incentives, the combination of weak and perverse incentives suggests the need to strengthen incentives, so that both types of stakeholders are motivated to tackle the barriers to HIE development. Key to strengthening incentives are payers, who are thought to be the largest beneficiaries of HIE. Payers have been reluctant to make significant investments in HIE without a more active voice in its implementation,³⁴ but a shift to value-based payment may increase their engagement.

Despite the continued challenges to nationwide HIE, several policy and technology developments show promise. Stage 3 meaningful use criteria continue to build on previous stages in increasing HIE requirements, raising the threshold for electronic exchange and EHR integration of summary of care documentation in patient transitions. The recently released Medicare Access and CHIP Reauthorization Act (MACRA) Merit-based Incentive Payment System (MIPS) proposed rule replaces stage 3 meaningful use for Medicare-eligible providers with advancing care information (ACI), which accounts for 25% of a provider’s overall incentive reimbursement and includes multiple HIE criteria for providers to report as part of the base and performance score, and follows a very similar framework to stage 3 MU with its criteria regarding HIE.³⁵ While the Centers for Medicare and Medicaid Services (CMS) has not publicly declared that stage 3 MU will be replaced by ACI for hospitals and Medicaid providers, it is likely it will align those programs with the newly announced Medicare incentives.

MACRA also included changes to the Office of the National Coordinator (ONC) EHR certification program in an attempt to further encourage HIE. Vendors and providers must attest that they do not engage in information blocking and will cooperate with the Office’s surveillance programs to that effect. They also must attest that, to the greatest degree possible, their EHR systems allow for bi-directional interoperability with other providers, including those with different EHR vendors, and timely access for patients to view, download, and transmit their health data. In addition, there are emerging federal efforts to pursue a more standardized approach to patient matching and harmonize consent policies across states. These types of new policy initiatives indicate a continued interest in prioritizing HIE and interoperability.²¹

New technologies may also help spur HIE progress. The newest policy initiatives from CMS, including stage 3 MU and MACRA, have looked to incentivize the creation of application program interfaces (APIs), a set of publicly available tools from EHR vendors to allow developers to build applications that can directly interface with, and retrieve data from, their EHRs. While most patient access to electronic health data to date has been accomplished via patient portals, open APIs would enable developers to build an array of programs for consumers to view, download, and transmit their health data.

Even more promising is the development of the newest Health Level 7 data transmission standard, Fast Healthcare Interoperability Resources (FHIR), which promises to dramatically simplify the technical aspects of interoperability. FHIR utilizes a human-readable, easy to implement modular “resources” standard that may alleviate many technical challenges that come with implementation of an HIE system, enabling cheaper and simpler interoperability.³⁶ A consortium of EHR vendors are working together to test these standards.²⁸ The new FHIR standards also work in conjunction with APIs to allow easier development of consumer-facing applications³⁷ that may empower patients to take ownership of their health data.