In August, the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP) released a Notice of Proposed Rule on Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2). Comments were due on October 4, 2024.

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The LTPAC Health IT Collaborative submitted comments (see link to full letter below). Here are the key highlights: 

• ONC Health IT Certification Program Updates: The LTPAC Health IT Collaborative recommends that ASTP revisit the recommendations in the HITAC Annual Report for FY 2023 to support interoperability standards in LTPAC providers. We recommend that support programs be planned and prioritized for such financial support (e.g., grants), incentives and requirements, technical education and assistance for adopting and using interoperable tools, and funding to increase HIE integration. We also recommend ASTP review the standards referenced in the Certification Program to confirm relevance to LTPAC providers, confirm which require modification or exclusion, and identify the unique implementation challenges and strategies to address. 
• Information Blocking - Interference and Information Blocking Exceptions: In the absence of comprehensive information sharing capability support for LTPAC providers, we urge the ONC to place a special emphasis on educating consumers and other parties about these limitations, and to explain that there are legitimate circumstances where certain patient health information from LTPAC providers is not currently feasible to be exchanged interoperably.  
• APIs for Payers: We strongly request these standardized processes are first applied to payers and after that, they are applied to providers. The reasoning is simple. Providers need to get paid for the care they provide. IF the standards are applied to Providers first, then Providers will have to meet two standards–those set by the government (to remain in business) and those set by Payers (to get paid so they can remain in business).  
  
  

Within this set of comments were examples where policy changes could support and assist LTPAC providers so they can use interoperable tools to support a patient’s journey of care. We hope these are a reminder that the US healthcare system is made up of more than just acute and ambulatory care providers. Patients with acute care episode often find themselves being cared for in an LTPAC setting. This is especially true of patients with multiple comorbidities requiring chronic care.

With the constant changing of the healthcare systems and rapid evolution of health technologies happening today, it is critical to address the gap in policy, support, and funding to realize the goals of an interoperable healthcare system.

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Attachments: [Letter]

Links and References:

ASTP Website on HTI-2: Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) Proposed Rule | HealthIT.gov

Federal Register Link: Federal Register :: Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability

Health Information Technology Adoption and Utilization in Long-Term and Post-Acute Care Settings. Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health & Human Services by RTI International. December 2023. Health Information Technology Adoption and Utilization in Long-Term and Post-Acute Care Settings (hhs.gov)

Interoperable Exchange of Patient Health Information Among U.S. Hospitals: 2023. Office of the National Coordinator for Health Information Technology (ONC). May 2024. Interoperable Exchange of Patient Health Information Among U.S. Hospitals: 2023 | HealthIT.gov

Jordan Everson, Wei Chang, Vaishali Patel, Julia Adler-Milstein, The state of health information organizations and plans to participate in the federal exchange framework, Health Affairs Scholar, Volume 2, Issue 8, August 2024. The state of health information organizations and plans to participate in the federal exchange framework | Health Affairs Scholar | Oxford Academic (oup.com)

Health Information Technology Advisory Committee (HITAC) Annual Report for Fiscal Year 2023. February 8, 2024. https://www.healthit.gov/sites/default/files/page/2024-03/HITAC_Annual_Report_for_FY23_508.pdf 

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