Newsletter Article

Myths vs. Facts About Interoperability Requirements

Key staff: Ken Riomales, Senior Director of Interoperability

As CalMHSA works to identify solutions for counties to meet state and federal interoperability requirements, we have developed the following common misconceptions and corresponding facts surrounding recent interoperability efforts:

Myth: HIE/HIO onboarding will automatically meet Centers for Medicare & Medicaid Services (CMS) interoperability and Behavioral Health Quality Improvement Program (BHQIP) requirements.

Fact: Due to their existing presence as interoperability facilitators in the market, HIEs/HIOs were viewed as a potential means to achieve these measures. However, not all HIEs/HIOs are the same, and onboarding with one does not necessarily guarantee compliance. Federal and state interoperability requirements are comprised of multiple components. When selecting an exchange partner, whether an HIE/HIO or other entity, be sure to ask the proper questions to ensure that entity will meet requirements.

Myth: If a system is Fast Health Interoperability Resources (FHIR)-compliant, the organization meets CMS interoperability requirements.

Fact: FHIR compliance is the first step toward meeting CMS requirements. Organizations must implement the appropriate application programming interfaces (APIs) that use their FHIR-compliant workflows. A FHIR-based API is an additional functionality for a native system’s FHIR capabilities. Additionally, for BHQIP, reporting entities must demonstrate FHIR transactions and provide a log of active exchange. Simply having the functionality does not meet requirements.

Myth: If we have a patient portal, we should be able to meet the CMS Patient Access regulations.

Fact: The CMS Patient Access rule requires open access API to allow for a client/patient to use a third-party app (i.e., Apple Health App) of their choosing to access their information. Additionally, client/patient data from a minimum of January 1, 2016, will need to be made available using FHIR APIs and comply with USCDI standards.

Additional information around CMS interoperability requirements can be found here; additional information on BHQIP requirements can be found here. CalMHSA continues to explore options to help our county partners meet interoperability goals. In the meantime, questions about interoperability can be directed to Senior Director of Interoperability Ken Riomales at [email protected].

March 28, 2023