Interoperability in Action: ONC Informs CMS Ruling on Hospital Measures for Public Health and Health Equity Reporting

Alex Baker and Elisabeth Myers | October 25, 2022

This is the second blog post in a two-part series that examines how policies finalized by the Centers for Medicare & Medicaid Services (CMS) in the 2023 Inpatient Prospective Payment System (IPPS) final rule are advancing the use of interoperable health IT. Previously, we looked at a new measure under CMS’s Promoting Interoperability Program that rewards hospitals for exchanging information under the Trusted Exchange Framework and Common Agreement, or TEFCA. 

ONC works closely with CMS on the Promoting Interoperability Program to ensure certified health IT and other initiatives support the program’s objectives for eligible hospitals and critical access hospitals. In this blog post, we examine an additional update to the Promoting Interoperability Program that reflects collaboration between CMS, ONC, and the Centers for Disease Control and Prevention (CDC). We also look at new policy in the Inpatient Quality Reporting program aimed at advancing health equity. 

Expanding and Incentivizing Public Health Reporting  

The Promoting Interoperability Program has been an important mechanism for driving improvement in public health reporting through the program’s Public Health and Clinical Data Exchange Objective. By including measures that require hospitals to use certified health IT to capture and share public health data (e.g., immunization reporting, syndromic surveillance, reportable lab tests and results, case reporting) the program supports nationwide early warning of emerging outbreaks and threats, faster public health response, and greater visibility into immunization uptake which, in turn, can inform tailored vaccine distribution strategies.  

The 2023 IPPS rule expands the list of required public health measures under the Promoting Interoperability Program to include antimicrobial use and resistance (AUR) surveillance. Beginning in 2024, to earn full credit under the Public Health Objective, hospitals must report AUR data to CDC’s National Healthcare Safety Network (NHSN). In order to complete this reporting, hospitals must use health IT certified under ONC’s certification program to the “Transmission to public health agencies — antimicrobial use and resistance reporting” certification criterion. More information about the criterion’s capabilities, associated standards, and guidance for health IT developers can be found in the Certification Companion Guide 

While this capability has been included in the ONC Health IT Certification Program since 2015 and many hospitals are already tracking AUR data, this new, dedicated, measure will help to ensure this important reporting activity is conducted at a national scale.  

For 2023, CMS has also increased the points available under the Public Health and Clinical Data Exchange Objective to strengthen participation in these vital activities. Finally, starting in 2024, CMS will require that hospitals demonstrate progress towards exchange of data in production with public health agencies, by limiting the time an eligible hospital or CAH can spend on registration or testing activities before moving to full production. These changes acknowledge advances in data modernization, widespread technical capabilities in public health agencies to receive standardized data from providers, and the critical role that public health reporting plays in responding to public health emergencies and closing gaps and inconsistencies revealed—and exacerbated—by the COVID-19 pandemic 

Building Health Equity into Quality Reporting 

The 2023 IPPS final rule also adds new measures (voluntary for 2023 but required beginning in 2024) under the Hospital Inpatient Quality Reporting (IQR) program that address health equity. These measures are designed to build health equity into their core functions in three ways by assessing:  

1) the degree of hospital leadership commitment to collecting and monitoring health equity performance data;  

2) the percent of patients admitted to the hospital who are 18 years or older at time of admission and are screened for food insecurity, housing instability, transportation problems, utility help needs, and interpersonal safety; and,  

3) by identifying the proportion of patients who screened positive on the date of hospital admission for one or more of these health-related social needs.  

Capturing information on these social determinants of health (SDOH) can help clinicians understand environmental factors—such as where people live, work, learn, or play—that influence a wide range of health conditions including the risk for heart disease, diabetes, obesity, and other medical conditions. These health equity measures can also reinforce ONC’s work to include SDOH data in clinician systems, as well as efforts to ensure that health IT be designed with health equity in mind. 

As part of the final rule, CMS encouraged hospitals to capture this information using screening tools that record data in a standardized format in accordance with health IT vocabulary standards. By using tools that capture the social drivers of health screening results in a standardized way, hospitals can ensure this critical information is available to other providers delivering care and services to a patient, including community-based organizations that receive referrals to support individuals’ social needs.  

CMS also highlighted Version 2 of the United States Core Data Interoperability (USCDI), published in July 2021, which included new data classes for SDOH Problems/Health Concerns, SDOH Interventions, SDOH Goals, and SDOH Assessments. ONC recently published USCDI Version 3, which maintains the SDOH elements in Version 2. Under ONC’s Standards Version Advancement Process (SVAP), hospitals can work with developers of certified health IT to upgrade their certified health IT products to USCDI Version 2 to support ensure availability of standardized, interoperable information about social determinants of health captured in their systems.  

In response to these new CMS requirements, a new stakeholder coalition, called Sync for Social Needs, will help to test out and demonstrate best practices for standardizing and digitizing related processes. ONC will share more about these stakeholders’ implementation experiences in the coming months. 

Better Health for All Americans  

The new policies in the 2023 IPPS final rule represent exciting ways that use of health IT and increased interoperability can help to advance priorities for improving health and health care for patients and consumers across the country.  While the policies discussed in this blog series have focused on hospitals, CMS and ONC have also worked together to extend related proposals around use of TEFCA, strengthening public health reporting, and measures addressing health disparities to clinicians outside of hospitals through the 2023 Physician Fee Schedule proposed rule. ONC looks forward to continued collaboration with CMS and the CDC to make progress on shared goals for resilient public health, health equity, and better health care for all Americans.