With the U.S. Department of Health and Human Services’ (HHS’) release of its final interoperability and information blocking rules, providers, payers and technology vendors are no longer off the hook when it comes to giving patients safe and secure access to their electronic health data.
The rules, which fulfill provisions of the 21st Century Cures Act, serve an undoubtedly worthwhile purpose. Unfortunately, these rules, along with some of the other steps the government is taking to improve data sharing and interoperability (TEFCA, FHIR, open APIs, etc.), are not sufficient in and of themselves.
The goal of TEFCA, for example, is to “create a single onramp for nationwide interoperability,” enabling a standardized system among health information networks to share data in a way that reduces unnecessary cost and complexity for providers.
Accomplishing this feat requires more than a common agreement, however. It requires a highly scalable multisided platform (MSP), or what most in healthcare will recognize more generally as health information exchanges (HIEs).
Multisided platforms rely on “network effects” to create value: the more users that use the platform, the more value there is for all users. But figuring out the mechanics of how to attract users requires knowing what specific problem they are trying to solve for. Without MSPs built for specific information exchange use cases, the recent and pending regulations are regrettably nothing more than a matchbox without a flame.
Platform dominationAs of midsummer 2019, the 21 public platform companies in the S&P 500 (just 5 percent of the companies on the index) accounted for 20 percent of the entire S&P 500’s net income. Translation? MSPs at scale are fast becoming the dominant business model—which is to the benefit of healthcare information exchange.
Why? As explained in the book Platform Revolution, network effects are real and they matter. For Uber and Lyft, riders attract drivers, and drivers attract riders. On Amazon, sellers attract buyers, and buyers attract sellers. And on Airbnb, hosts attract guests, and guests attract hosts.
In each of these examples, there are positive network effects at work, and the same thinking can and must be applied in healthcare, where an MSP can connect multiple sides of a network to improve data exchange. The challenge? Different stakeholders tend to have diverging interests and different workflow needs.
Today’s leading interoperability organizations (CareQuality and CommonWell) provide legal and connectivity frameworks, and standards organizations play a critical role in developing and securing consensus around technical specifications (HL7 and NCPDP) that play a foundational role in improving health information exchange. However, these organizations do not operate the technical platform (CommonWell uses Change Healthcare as a technical service provider); they were not designed with specific information exchange use cases in mind (they use standards that allow for communication of many different types of data and use cases); and they do not provide real-time operational or technical support for users. All of these are critical, as only an operational MSP has enough insight and flexibility to quickly adapt and evolve to figure out how their end-users want to transact and incorporate transactions into their workflow.
In healthcare, operational MSPs that develop and evolve to meet specific use cases will be uniquely positioned to facilitate nationally scalable health information exchange, while addressing the many challenges that exist when trying to do so in a way that creates value for all users.
The role they were meant to play: MSPs as interoperability facilitatorsThere are several reasons why MSPs, when developed for a specific data exchange use case, are in a unique position to enable broader information exchange. For example, MSPs:
Offer global, end-to-end technical support and coordination protocols for users.
Go beyond governance to focus on improving and optimizing platform operations, including user experience, transaction processes, value delivered, etc.
Provide version control services (e.g., ensuring that two participants using different versions of an information exchange standard can still “talk”).
Certify technology and ensure ongoing participant compliance with specifications and processes.
Provide quality oversight and a continuous quality improvement program.
These services that occur on top of the actual platform may seem extraneous for local hospital-to-hospital information exchange, but are critical when health information exchange starts to scale and becomes many-to-many connections.
Consider a primary care physician trying to send a referral to a cardiologist, who requires different information than the vascular surgeon. Determining the data elements and cadence of needs on a point-to-point basis is simply not scalable, and the ability to scale is a requirement when it comes to improving information exchange more broadly. Even something as simple as a hospital sending a patient discharge summary to a doctor using multiple EHRs can become a labyrinthine, bureaucratic nightmare.
Deriving value by taking a use-case approach to MSP developmentDeveloping nationally-scalable MSPs with specific use cases in mind is a necessity when it comes to improving health data exchange at scale. And in healthcare, there are few established data exchange platforms that have successfully scaled through this approach.
In the case of CoverMyMeds, the health data platform approached pharmacies with a way to help them resolve prescription prior authorizations faster, while leveraging pharmacies’ day-to-day relationships with doctors to spur doctor adoption of the platform.
As more doctors came onto the CoverMyMeds’ platform, it created more value for pharmacy users, who were seeing prior authorizations resolved more quickly. In turn, these pharmacists recruited more doctors to the network, which drove activity and continued to enhance its value.
Surescripts, the nation’s largest health information platform responsible for routing the majority of the country’s e-prescriptions, creates value for its users by continuously working with them to improve the e-prescribing transaction process for all parties involved (EHRs, pharmacies, PBMs). This “inside baseball” assessment of health information exchange can only be discovered and worked through on a use-case basis, though — in a real-world environment, where the nuances of information exchange directly impact clinical workflows.
As we have seen in healthcare with both Surescripts and CoverMyMeds, MSPs are in the unique position to achieve economies of scale, aggregate massive user-bases and add value for users — harmonizing requirements and transactions for greater efficiency. And newer organizations are following suit in terms of approach, focused on developing platforms for a specific purpose.
MSPs leading the way to better information exchangeWhether it’s solving a gap in care problem, or a payer/doctor connectivity problem, or any of the many different scenarios that exist today, there will always be individual use cases where MSPs can and should connect to solve for information exchange at scale. Opening APIs and finalizing information blocking mandates are a great step forward, but as the regulations are today, they won’t solve for a specific problem, and the networks developed won’t scale enough to make an impact.
We’re moving to a world of best-of-breed technology in healthcare. From an interoperability standpoint, there will continue to be numerous information exchange use cases that need solving for — and now more than ever, we need MSPs to make that connection.
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