Since the last HIT Policy & Standards Committee Enrollment Workgroup update, three workgroup meetings have been held and four tiger teams have been activated around privacy and security and in keeping with the think-big-but-start-small principle, said Aneesh Chopra, chair and chief technology officer of the Office of Science and Technology Policy (OSTP).
“There were several core components that are necessary for this enrollment process to work,” Chopra said. These aspects included verification and eligibility components, bringing a development-friendly nature to the business rules, the actual handoff of the plans and privacy and security.
Verification interface recommendations included the utilization of web services, as well as the use of National Information Exchange Model (NIEM) compliant exchanges where possible. In addition, a verification service construct, beginning with base services being developed with the goal of “building it once, not 50 plus times,” said Chopra.
The main principle of the business rules tiger team was “no ripping and replacing” of current state systems. “We must find a way to augment these existing systems,” Chopra stated. The impact of imperfect information and data should also be “buffered” where possible, he said.
“Once we’ve done the verification aspect, the plan/benefit handoff is an important area for our standards work,” Chopra said. The tiger team for this aspect is charged with identifying key data elements needed for data exchange between health plans, Medicaid and state and federal exchanges, as well as to explore various approaches for streamlined bi-directional data exchange and recommend standards where appropriate. Existing HIPAA standards--including 834, 270 and 271--can provide a framework to conduct these operations, noted Chopra. “However, there is obviously some challenge around the consumer communication and we are going to have to look for ways to close that gap,” he said.
Recommendations generated for privacy and security, perhaps the main aspect on the minds of the workgroup, included:
- Collection limitations: The collection the minimum data is necessary for enrollment and eligibility, taking into consideration desire to collect information once and reuse information.
- Data integrity and quality: Access to real-time data/mechanisms to maintain data accuracy.
- Accountability and oversight: Clear, transparent policies about authorizing access and use of data provided to the enrollee.
With the NIEM Data Harmonization Project under way, Chopra shared the “very effective” methodology currently being used by the group for eligibility enrollment. The process is made up of three steps, including:
- Step 1: Define scope - identify data elements, programs and sample states.
- Step 2: Analyze data - survey existing data models, collect data details and consolidate and analyze results.
- Step 3: Harmonize - review findings, refine data analysis and harmonize data definitions.
The bottom line, noted Chopra, is that the group has been getting “incredible public feedback,” in support of the efforts so far by various consumers and associations. The Federal Advisory Committee Act Blog has seen 41 responses and 13 responses via email so far, he added.
Most of the responses discuss the role standards play in simplification and use of multiple entry points, as well as the view that data standardization is better supporting enrollment across programs. In addition, many have expressed support for use of electronic verifications and encouragement for innovation, use of the web and shared business services--all of which are “very validating messages,” concluded Chopra.