Physical Therapy and ONC Health IT

The country has been making slow but steady progress on the road to better healthcare. There have been several Health IT Programs from the ONC (Office of the National Coordinator for Health Information Technology). In the physical therapy world, there may have been some confusion about these programs and their relevance. To attempt to clear the fog, a sliver of relevant history may be helpful.

ONC Health IT ? The Timeline

It all began with the Meaningful Use Program from 2009 to accelerate the adoption of electronic health records. The Meaningful Use Program (today, the Promoting Interoperability Program) was an incentive program for physicians and hospitals to step up EHR implementation and share health information digitally. Use of certified electronic health records technology was one of the program requirements. In 2010, the ONC Health IT Certification Program was established as part of the Meaningful Use program. The program was voluntary but to become eligible for financial incentives, most hospital-based and physician-based EHRs obtained ONC certification. All along, physical therapists were largely kept out of the loop. The Practice Pro platform and others like it in the physical therapy industry fell under an exception to the interoperability standards that were aimed at Certified Health IT systems. The ONC Health IT Certification Program has a long history of excluding physical therapy providers and vendors, dating back to the Meaningful Use Program to the current day Merit-based Incentive Payment System (MIPS) eligibility. The certification is designed around physician-based data standards, which have never been formally implemented in the physical therapy industry. To promote innovation in the Health IT ecosystem by delivering high quality health information to patients and clinicians, the 21st Century Cures Act was signed into law in 2016. The act gave a boost to technology-driven transparency for enabling patients and customers to achieve increased visibility into the services, quality, and cost of health care. In 2017, the Meaningful Use Program was renamed as the Promoting Interoperability Program as part of MIPS. ONC published the Cures Act Final Rule in 2020 with two component rules: Implementing interoperability and giving patients full access to their healthcare data. The Final Rule is commonly referred to as the Information Blocking Final Rule. Passage of the Final Rule was a heads-up for physical therapists to start paying more attention to the regulation in order to remain compliant and avoid potential penalties or disincentives down the road. The Final Rule includes specific terminology on regulation parameters:

• Interoperability: Ability of an electronic system or software to exchange or share information
• Information Blocking: An action that could interfere with, prevent, or discourage access, exchange, or use of electronic health information
• Actors: Includes healthcare providers, health IT developers, and health information networks or exchanges
• Electronic Health Information: Protected Electronic Health Information that is contained in a designated record set as per HIPAA

The second lot of changes kick in July, 2021, when organizations are expected to share data through application programming interfaces (APIs).

ONC Health IT ? Implication for Physical Therapists

Health IT developers of Certified Health IT are required to comply with information blocking provisions, and could be hit with penalties and disincentives if deemed to be an information blocker. Health IT developers of health IT that is not certified do not directly come under the purview of information blocking provisions and potential penalties. But here is the rub. Physical therapists, like other healthcare providers, are also considered to be actors and would need to stay aligned with the ?spirit? of the legislation. And, because physical therapists use EMRs/EHRs that lack ONC certification for creating, maintaining, and transmitting EHI, the EMR/EHR vendors would need to be ready to access, exchange, or use EHI on behalf of their clients. While health IT developers do not need to have their products or applications certified under as per ONC criteria, all health IT developers and EMR/EHR vendors would have to respond to client requests for accessing, exchanging, or using EHI in a timely manner so as to stay compliant with information blocking mandates. Practice Pro remains fully committed to enabling the exchange and access of healthcare data between providers, patients, and payers. We do this in a variety of innovative ways from built-in electronic faxing to portal access for patients to even integrating with interoperability vendors, partnering with our clients to help them achieve their compliance goals. Hopefully, end of the day, all of us are moving together, albeit in fits and bursts, toward the goal of better healthcare, a worthy cause if there was one.