1/ Sorry for the top quote, but imma thread(*):
I'm on the "Intersection of Clinical and Administrative Data Task Force" which is a joint task force of NCVHS and HITAC.
So, there are *two* FACAs that deal with health technology standards.
(*) yes, I verbed "thread"
I'm on the "Intersection of Clinical and Administrative Data Task Force" which is a joint task force of NCVHS and HITAC.
So, there are *two* FACAs that deal with health technology standards.
(*) yes, I verbed "thread"
2/
NCVHS was created forever ago, but it's mission was updated w/ HIPAA to advise the secretary on, among other things, the administrative transactions created for HIPAA (& as a reminder, the privacy & security stuff in HIPAA was sideline in the day…
NCVHS was created forever ago, but it's mission was updated w/ HIPAA to advise the secretary on, among other things, the administrative transactions created for HIPAA (& as a reminder, the privacy & security stuff in HIPAA was sideline in the day…
3/
b/c HIPAA was about insurance portability & administrative efficiency & health data privacy came along for the ride).
HITAC, defined in Cures was the update to HITSC/HITPC which was created for HITAC. Fhew.
Anyway 2 FACAs advising on standards tells you a lot.
b/c HIPAA was about insurance portability & administrative efficiency & health data privacy came along for the ride).
HITAC, defined in Cures was the update to HITSC/HITPC which was created for HITAC. Fhew.
Anyway 2 FACAs advising on standards tells you a lot.
4/
There are different standards evolution processes. The @ONC_HealthIT one that names standards for #EHR certification is rigid and slow and defined through reg.
We've tried to engineer that process to prototype, drive standards evolution, etc.
There are different standards evolution processes. The @ONC_HealthIT one that names standards for #EHR certification is rigid and slow and defined through reg.
We've tried to engineer that process to prototype, drive standards evolution, etc.
5/
The CMS one, that names standards for administrative transactions (eligibility, claiming, & ePA) is, uh, rigider and slowerer.
e.g., they can name one & only one standard for a HIPAA named transaction (& yes, they are named in law, which seems like a bad idea).
The CMS one, that names standards for administrative transactions (eligibility, claiming, & ePA) is, uh, rigider and slowerer.
e.g., they can name one & only one standard for a HIPAA named transaction (& yes, they are named in law, which seems like a bad idea).
6/
(law vs reg trips people up but this one is a literal act of Congress: law.cornell.edu/uscode/text/42…)
There's no good process to evolve from one version to another & you see that list above? Not all of them have working named production standards.
(law vs reg trips people up but this one is a literal act of Congress: law.cornell.edu/uscode/text/42…)
There's no good process to evolve from one version to another & you see that list above? Not all of them have working named production standards.
7/
I'll remind you that HIPAA was signed in '96, and EDI transition was in '03, so we aren't talking Internet time here. We aren't even talking Health IT adoption time.
I'll remind you that HIPAA was signed in '96, and EDI transition was in '03, so we aren't talking Internet time here. We aren't even talking Health IT adoption time.
8/
Y'know how we are complaining about how we are 10 years into EHR incentives & we don't have X, Y, & Z? Well, that's rocket speed compared to administrative standards.
Y'know how we are complaining about how we are 10 years into EHR incentives & we don't have X, Y, & Z? Well, that's rocket speed compared to administrative standards.
9/
Because there are conspiracy theories that we don't have ePA standards because payers want it to be dumb & slow & painful, let's look at "attachments"
Claims attachments are the ability to provide additional documentation for a claim.
Because there are conspiracy theories that we don't have ePA standards because payers want it to be dumb & slow & painful, let's look at "attachments"
Claims attachments are the ability to provide additional documentation for a claim.
10/
There's zero conspiracy theory about claims attachments. It's just painful for payers & providers to do this via fax, portal uploads, etc.
There's zero conspiracy theory about claims attachments. It's just painful for payers & providers to do this via fax, portal uploads, etc.
11/
We have a standard. It's just not a named standard. Because CMS won't name the standard. So nobody will test the standard. So it's untested. So CMS won't name it.
Nevertheless, attachments is slowly happening because not doing it is super dumb.
We have a standard. It's just not a named standard. Because CMS won't name the standard. So nobody will test the standard. So it's untested. So CMS won't name it.
Nevertheless, attachments is slowly happening because not doing it is super dumb.
12/
But *slowly*.
So the root of this issue is a "network economics" who moves first issue. CMS won't name a standard that's untested. Providers and EHR vendors won't build to a standard that payers don't support.
But *slowly*.
So the root of this issue is a "network economics" who moves first issue. CMS won't name a standard that's untested. Providers and EHR vendors won't build to a standard that payers don't support.
13/
Payers won't build support for a standard that not endorsed by CMS & not supported by providers & the technology they use. So the standard is untested. So CMS won't name a standard. So…
Payers won't build support for a standard that not endorsed by CMS & not supported by providers & the technology they use. So the standard is untested. So CMS won't name a standard. So…
14/
& that's attachments. ePA is harder because it requires some real-time adjudication and adjudication is batch base and blah blah blah, but the "who moves first" problem is near the root of the issue.
& that's attachments. ePA is harder because it requires some real-time adjudication and adjudication is batch base and blah blah blah, but the "who moves first" problem is near the root of the issue.
15/
🧵getting deep & I haven't talked about the MACs or FHIR or API transition or…. but for now:
THE END.
🧵getting deep & I haven't talked about the MACs or FHIR or API transition or…. but for now:
THE END.
