Discover and read the best of Twitter Threads about #curesnprm

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#CuresNPRM pricing policy recommendations.

To start with, a basic question: are market forces for interoperability good, or nah?

There are three basic positions that I hear articulated

a) "making money on interoperability is immoral"
b) "making 'unreasonable' profit on interoperability is immoral"
c) "extracting monopoly rents as an interoperability gatekeeper is immoral"

These are obviously *very* different stances, and the inability to articulate and distinguish them causes real problems. I often hear a silent assumption that all fees are monopoly rents and ipso facto immoral.
Read 11 tweets

Who is a Heath Information Network under #CuresNPRM?

Easy, right? a HIN is a network that shares health information, yes?


"Health Information Network or HIN means an individual or entity that satisfies one or both of the following—
(1) Determines, oversees, administers, controls, or substantially influences policies or agreements that define business, operational, technical, or…"

"other conditions or requirements for enabling or facilitating access, exchange, or use of electronic health information between or among two or more unaffiliated individuals or entities."
Read 11 tweets

#CuresNPRM tweetstorm time!

For context, the way "Information Blocking" provisions work is that electronic health information *must* flow for all permissible purposes, unless there's a good reason.

171.201-7 enumerate the possible good reasons information wouldn't flow

171.201 is the Good Reason to Block covering patient harm. Clearly, we wouldn't want to hurt the patient, yeah?

There are three subparts to 171.201 - (a)(1), (a)(2), (a)(3)
(a)(3) is simplest: on judgement of a licensed care professional, releasing data would cause direct harm & there is legally appropriate right to review by the patient.

Suicidal ideation, pattern of self-harm, overt threats etc are a Good Reason to Block. But very *rare*.
Read 9 tweets
Starting at page 221 with the regulation itself (see how I do this...I skip to the regs first, I’ll go back through the preface material later) #PatientAccess…
In the following, mom is simply how I think about the phrase "Medicare Enrollee". It could be dad, uncle Fred, my buddy Glen et cetera. #PatientAccess is about the patient.
So, mom's MA organization has to provide APIs that allow her to use an app (after mom approves it) to access standardized claim data, adjudications, appeals, provider payments (remittances) and co-payments (cost-sharing) within one business day of claim processing. #PatientAccess
Read 182 tweets

Verily this shall be an Account of the Seven Virtuous Exceptions to the Sin of Information Blocking.

For there are Seven. Not Six. Not Eight. Five is right out.


The First Virtuous Exception to the Sin of Information Blocking is:

Preventing Harm Including:
(a)(1) Corrupt/inaccurate data
(a)(2) Misidentified patient
(a)(3) Life & Safety

All policies need to be fair, and minimally targeted to prevent harm
1 (commentary)/

Being a Commentary on the First Virtuous Exception.

(a)(1) Seems like an excuse to slow/delay.

(a)(2) seems like a hole you could drive a truck through, yeah? If I don't have 100% confidence in my own patient matching (and who does), I can bail?
Read 16 tweets

#CuresNPRM Information Blocking deep dive.

As a reminder, the PHSA defines "provider" broadly & "permitted purposes" are purposes that are, well, permitted.
Therefore, unless there are specific exceptions noted, the legislative intent of #21CC could be interpreted that....

...if I ask a, say, pharmacy or physical therapist for information to justify a CQM or risk score for a patient we both share (both permitted payment/operations uses)
Read 17 tweets

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