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Countdown to October 6

During his keynote speech at the 2022 State Healthcare IT Connect summit, National Coordinator for Health Information Technology Micky Tripathi outlined the next stage in enforcement of the 21st Century Cures Act (‘Cures Act’): the requirement that healthcare providers, certified health IT developers, and health information networks share all electronically-accessible health information with each other and patients.

Under ONC’s current enforcement regime (as of April 5, 2021), covered entities are required to enable interoperability for a strictly-defined data set: the data elements represented in ONC standard USCDI V1. Broadly speaking, these elements include topics that the typical healthcare consumer might expect to find in a patient’s medical record:

• Allergies and intolerances

• Care team members

• Lab results

• Medical procedures

• Vital signs

• Clinical notes

• Prescriptions

• Patient demographic data

Since USCDI V1 adherence is required by many Medicare and Medicaid payment models, the standard enjoys near-universal support by healthcare providers and vendors.

After October 5, 2022, the organizations and institutions subject to Cures mandates will have to enable shareability of a far more inclusive data set: individually-identifiable health information that is “transmitted by electronic media, maintained in electronic media, or transmitted or maintained in any other form” (45 C.F.R 160.103). When the definition of health information shifts from a list of distinct elements to an inclusive class of data, every stakeholder in the healthcare data ecosystem will have to re-examine their approach to collecting, retaining, and sharing that data.

For some healthcare and healthcare-adjacent organizations, preparations for October 6, 2022 have been underway for months. For everyone else, Tripathi’s keynote address should serve as a call to arms.

Tuck Consulting Group is ready to help your organization navigate the challenges associated with the next phase of Cures Act compliance. Whether you are a software vendor, a healthcare provider, or a heath information network, Tuck Consulting Group brings the right blend of industry experience and technical training to our project management approach to tackle your interoperability challenges. We’re excited about the possibilities that the Cures Act opens for new and novel uses of healthcare data by clinicians, as well as enabling healthcare literacy for patients. We’re even more excited about helping developers obtain ONC certification for their health IT product by implementing a FHIR API by December 31, 2022 (more on that in a future blog post).

Credit to outside articles:

Synopsis of Tripathi’s ONC update address: Delivering On The Promise Of Health Information Technology In 2022 | Health Affairs

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