New proposed flow and intermediary roles for health data

Word coming out of the Health IT Standards Committee last week is that the panel has approved a framework for the transmission of patient data from providers to federal government agencies such as the Centers for Medicare and Medicaid services. The proposal came out of a progress report from the committee’s Clinical Quality Workgroup presented on September 15. The process for gathering and reporting the quality measures (as shown in the image at right) involves the use of two intermediaries between sender and receiver: the first would be a health information exchange or other data collection and aggregation service provider, while the second would be responsible for processing and reporting quality data from the health records being transmitted.

While the usual emphasis in this space is on security and privacy issues (several of which are relevant to a multi-entity transaction flow such as this one), just as noteworthy for this proposal is the possibility that it represents a business opportunity for participation in health information exchange efforts. One of the big unanswered questions in the health IT debate is what incentive private-sector players will have to facilitate, enable, or provide health information exchange services. To date, no one has proposed any sort of revenue generation model whereby service providers or data owners might be paid on either a per-transaction or per-record basis for responding to health data requests, yet the overall success of health information exchange depends on high levels of participation. The incentives included in the Recovery Act are designed to offset the costs of acquiring and implementing electronic health record systems, and are therefore targeted at health care providers. What is less clear is how health information exchanges, such as the ones envisioned to link large numbers of providers together using the NHIN or other infrastructure, will be compensated for their services. Some of the key technical roles being proposed for health information exchange seem to present a need for service providers to fulfill the roles. The health data quality intermediary featured in the HITSC proposal is one such opportunity; others might include local or regional health information exchange operators that offer connectivity to health IT infrastructure, software-as-a-service or cloud-based EHR solutions offering access to small physician practices or other health care providers unwilling to implement their own local EHR systems, and credential issuers (in the form of security token services) that would provide identification and authentication claims to data requesters in a federated authentication model.