Pooja Babbrah, Pharmacy & PBM lead with Point-of-Care Partners (POCP), NCPDP Board of Trustees Chair, and host of The Dish on Health IT kicked off the episode. This last episode of 2022 featuring POCP Regulatory Resource lead, Kim Boyd and Payer & Provider Practice Lead and Da Vinci Program Manager, Jocelyn Keegancame together to break down all the big things that have happened in 2022 and what we expect for 2023. 

Pooja explained that while this episode's discussion will primarily be policy related, the panelists will also talk about some of the real progress being made in the standards world and the interconnectedness between federal and state health IT policy and legislation and between standards and policy, and what it means to the industry. 

Pooja asked Jocelyn and Kim to briefly introduce themselves and to tell the audience what topics they are most excited about discussing. 

Jocelyn introduced herself as the POCP payer practice lead, devoted to positive change and building/getting stuff done. She went on to say that her focus at POCP is on interoperability, prior authorizations, and the convergence of tech, standards, and product strategy. She explained that she has spent her career moving people and organizations towards APIs, unleashing data for their highest, best-purpose uses. She expressed that she couldn't be more excited about where we've been this year and the precipice of where we are headed next year.

Kim expressed that it's always a pleasure convening with Pooja and Jocelyn to discuss the exciting world of health IT.  She went on to share her background which has spanned medical and pharmacy operations and implementations, with years of policy, industry, and standards development work on ePA, cost transparency, ePrescribing, and taking what she learned in these areas to work with policymakers on smart policies to advance interoperability and patient care.  Kim stated that it has been an exciting year leading POCP's Regulatory Resource Center and that so much is happening in the state and federal regulatory spaces that ties to the innovations and acceleration the industry has been experiencing in health care.   

Pooja thanked them both for their introductions and then dug into the discussion by asking each of them to share the biggest Health IT highlights of 2022. 

Kim explained that four things really stand out in 2022:

1. the requirements of the transparency in coverage and no surprises act going into effect and the various provisions requiring data and cost transparency and giving patients and their care teams access to information that will help them make informed decisions.  Many in the industry have been clamoring for transparency of this type for some time.
2. The incredible work happening to advance interoperability via the SDOs and Accelerators, like HL7 Da Vinci, CodeX, FAST, and NCPDP's Pharmacy Technology and Innovations group. 
3. how Federal agencies are collaborating on aligning requirements for interoperability, like the use of standards and FHIR-based standards specifically. This collaboration and proceeding regulatory action will help align the technical and interoperability stars.  
4. the all-hands-on-deck focus on patient health equity is a big area of concentration for not only innovators in the market but the White House, HHS, standards organizations like NCPDP and HL7, and community and public health organizations.  There is just so much happening to try and close gaps in equitable care and the data/digital transformation that needs to happen to help facilitate change.     

Jocelyn followed Kim to share her perspective on the biggest highlights of 2022 first joking that Kim got to go first and steal some of the things she was going to say.She laughingly shared that she agrees with all of Kim's points and then said that she wanted to focus more on the tone and the tenor of the work happening in the industry. Jocelyn shared that from her perspective it feels as though the industry has moved from thinking about interoperability projects as something that will happen "someday" to action and reality.  She clarified that this may not be the case for everyone, but many organizations and projects are moving forward to not only do the IT work but the business transformation. The examples she gave included the real progress made on TEFCA, real-world deployments of FHIR guides, live usage of APIs, prior authorization (PA) on pharmacy getting an infusion with last year's Medicare Part D

Jocelyn added that she wanted to focus on and add to Kim's comment about coordination at the federal level. She explained that policymakers at the federal level have been working for well over a decade and using their levers to make change extraordinarily well.  Jocelyn went on to say that as she sees it there are three camps of folks; people and organizations who are working ahead of policy by paying attention to published roadmaps and reading between the lines of public statements, folks trying to get their organizations prepared to respond to the next wave of policy, and others playing the waiting game to see if it's real and if they'll have to follow or if another path will emerge. 

Finally, she added, that the last highlight from 2022 is all the waiting! The industry keeps waiting for certain regulations to drop. She explained that she doesn't think she remembers another year where there has been this much policy anticipation at year-end. 

Pooja thanked Jocelyn and Kim for sharing their perspectives. She shared two important topics that have been more under the radar but are growing in importance and focus. The first is consent, specifically eConsent. Stewards of change published the report “Modernizing Consent to Advance Health and Equity” to bring more attention to the need to solve this issue – not only in the context of healthcare but also social services as those are such an important tie-in to health outcomes.  Add to that, the ONC half-day discovery workshop on eConsent.  Pooja explained to those who may not have attended – that it was an amazing session that brought together so many different people across the continuum of care in addition to the people working in the social services arena.

The other area is pharmacy and the growing role of pharmacists in the care team and the work that is being done to ensure that they have access to more data and information to support care teams and support patients.  Pooja explained that there has been a lot of movement by retail chains to add primary care services to their offering and community pharmacies are supporting more clinical services.  This has led to more focus and a flurry of discussion around interoperability in the pharmacy space. Pooja gave the example of the Health Information Technology Advisory Committee (HITAC) recently proposing adding a pharmacy-focused subcommittee which is a huge indicator. 

Pooja shifted the discussion to policy highlights, specifically, requirements that went into effect and whether the industry met the deadlines or is still working on it. She explained that she is thinking specifically of: 

• No Surprises Act
• Transparency in Coverage Rule
• Information Blocking

Kim jumped in by saying that with the No Surprises Act there is still some pushback and uncertainty about how providers are going to comply with having to pull together all the data to provide Advanced EOBs (AEOBs) and good faith estimates (GFEs) when there are multiple providers involved in delivering the expected care; however, the Da Vinci Project is working on advancing implementation guidance to support patient cost transparency. Kim encouraged folks and organizations listening to this episode to get involved in these efforts. Kim added that she expects to see more price transparency-related policies, especially given the latest request for information on AEOBs. 

Kim went on to say that compliance with the ONC 21st Century Cures Final Rule on information blocking has been a mixed bag. She added that she wished ONC had called this "information sharing" instead of information blocking. Kim went on to say that most of the non-compliance has been on the provider side because it is challenging when a provider falls under the rule as an actor but maybe the health system they work in does not, especially when the health system may hold the data being requested. She added that most of the EHRs have spoken with are up-to-speed on the full EHI sharing requirement. 

Jocelyn added her perspective on information sharing specifically around EHI. Technically all of this information needs to be put out there, while the industry waits for USCDI to fully encapsulate patient information, there is probably a lot of non-codified data in the system that isn't actionable or really useable. The EHR certification requirements will likely do more to move the industry forward.  Jocelyn confessed that she fell down the RFI response rabbit hole and spent an hour looking at the feedback to the RFIs.  She thinks there is a disconnect between the goal of the rule and how to operationally do the work. An example she provided was around PA and that it isn't automating the submission of the PA alone but how to automate the 10 step