Holiday Edition 2021 Newsletter

If 2021 is any indication, 2022 promises to be an eventful and productive year for MHDC. We closed 2021 with partnership agreements with the Lown Institute, 1upHealth, Blue Cross Blue Shield of Massachusetts (BCBS), and the New England Baptist Hospital (NEBH). These agreements will provide our members and community with the health data services that help make interoperability less complicated and more valuable.

The Lown Institute will contribute their measures of hospital and health system equity, low-value care, and outcomes to the case-mix analytics in our Spotlight analysis service. 1upHealth will work with us to offer MHDC CodeMap, a code translation service that enables healthcare organizations to convert their health data into the codes necessary to support exchange, coordinate care, manage risk, and promote health equity. With BCBS and NEBH, we will be launching an open, standards-based prototype of digital prior authorization that will identify the critical steps and missteps that organizations must understand if they’re to automate successfully.

We also expanded our events in 2021 - nearly forty in total between executive forums, community webinars, and Vantage Point interviews - to address health data management and its many touchpoints across the industry and in the lives of individuals. Our hosted events have grown to address essential topics in consumerism, behavioral health, telemedicine, interoperability, advanced technologies, privacy and consent, regulations and compliance, public health, equity, social determinants of health, and more.

So, what will constitute a successful 2022 for MHDC?

First, we will deliver on the agreements we have signed in 2021. Lown measures add equity insights, information on the value of care, and clinical outcome data to Spotlight. Current and future users will want to round out their strategic analyses in a way that makes this data actionable - for example, it’s one thing to know that your organization’s structure does not reflect the composition of your community and quite another to understand what your organization must do to change that.

Code mapping is an invaluable tool to add to a payer’s or provider’s kit, not just to comply with formats required for interoperability internally and with partner organizations, but to ensure that it's done using standards everyone understands in the most economical way possible. Our service will provide this to the community at large.

Doing electronic prior authorization well requires following a technically proven cookbook and close collaboration between IT, operations, and clinical care. Together with our partners in the prototype project, we'll figure out that cookbook and the right way to collaborate in our prototype project.

Second, MHDC will focus more in 2022 and beyond on the person, the patient, the member, and the family. The emerging patient-centered health economy cannot function unless health data governance is delegated substantially, if not wholly, to the individual. In the US, 334 million residents’ health data is distributed across a million physicians, 6,000+ hospitals, and nearly a thousand health insurance carriers – private and public. Not all current data and interoperability regulations touch all of them, especially payer regulations as only 91% of the population has any type of health insurance. Starting with clinical and claims data but quickly moving to demographic and equity-related data sets, health plans and providers will need the continued engagement of the member-patient community to supply, ratify, and engage with the data that describe them. At MHDC, we expect these industry-consumer collaborations to increase in 2022 and beyond.

Finally, MHDC will make it easier for everyone in the health data community to work with us. Our events, memberships, and subscriptions present an array of services and benefits that many more in our community would attend, use, and support if we made working with MHDC less complicated. In 2022, we will simplify and streamline the MHDC membership process and fee structure to help individuals and organizations in Massachusetts and beyond.

We have an exciting and challenging agenda for the year. We look forward to engaging with you to move from plans to reality.

Denny Brennan, Executive Director

Please let us know what you think of our newsletter at and look for our next issue. Thank you for your continued support and participation!

MHDC Events

Meetings through January:

  • DGC Working Group: December 15, 22, 11am-12:30pm
  • DGC Working Group: January 5, 12, 19, 26, 11am-12:30pm
  • DGC Steering Committee: January 12, 3-4:30pm
  • MHDC Board of Directors: January 20, 8-10am
  • Webinar: Goinvo: January 11, 10-11am

Want to learn more about any of these meetings? Email


MHDC Webinars

Join us for our upcoming webinar: 

Own Your Healthcare Experience: An Open-Source Path presented by Juhan Sonin of GoInvo on January 11 from 10 - 11am.

Missed any of our webinars in 2021? Click here to see what you've missed! 

Interested in holding an MHDC webinar or have an interesting topic you'd like to present? Contact us at

January 2022 Regulations: Payer => Payer Exchange

The Payer => Payer exchange as mandated in the May 2020 Interoperability rule from CMS is scheduled to go in effect on January 1, 2022. This rule requires payers to send clinical data within USCDI v1 related to events with dates of service on or after January 1, 2016 to another payer at the patient's request so long as the patient was a beneficiary of a plan with that payer within the five years immediately before the request was made. The rule recommended using FHIR for this exchange but did not require it.

CMS has decided to delay enforcement of this requirement pending new final rules that outline a more standardized exchange format. We anticipate a requirement to use FHIR, particularly as this data is already available in FHIR formats for the Patient Access APIs (the frozen Prior Authorization rule had this requirement in place). It also permitted an additional bulk FHIR option allowing payers to collect requests from new members during their onboarding process and send them en masse after the close of each open enrollment period (or at the end of Q1 each year for plans without open enrollment periods). This option is more complex and involves additional technical, process, education, and support cycles from payers. We do not expect it to be required at this time, although it's always possible. See our article on 2022 predictions for more on this topic.

Spotlight Analytics Update

Spotlight Business Analytics helps healthcare organizations run custom analytics on health data including market share, patient origin, disease prevalence, cost of care, and comparative costs and outcomes for acute care hospitals.

We are pleased to announce our partnership with the Lown Institute to add civic and care leadership measures to Spotlight. Augmenting Spotlight’s market share, disease prevalence, and demographic analyses with the Institute’s equity, value, and outcomes measures will provide Spotlight subscribers with a more comprehensive and relevant view of health system performance. We are working on and plan to have these new datasets incorporated into Spotlight for use at the beginning of the year.

The current data status is:

Loaded & available for use:

  • Massachusetts Hospital Inpatient Discharge Data FY19
  • Massachusetts Emergency Department Discharges FY19
  • Rhode Island Hospital Inpatient Discharge Data FY20

Received & ready for use soon:

  • Massachusetts Observation Data FY19
  • Lown Institute measures

  • Massachusetts Emergency Department Visit Data FY20

  • Massachusetts Hospital Inpatient Discharge Data FY20

  • Massachusetts Observation Data FY19

Future planned data:

  • Massachusetts Observation FY20
  • New Hampshire Facility Discharge Data Sets (Application pending)
  • Maine Hospital Inpatient and Outpatient Data (Application pending)

Please feel free to drop us a line with any questions or comments at In the meantime, thank you for being a Spotlight Analytics user and a member of this community! Feel free to visit our Spotlight Business Analytics page or email us at the address above for more information.

DGC Update

The Data Governance Collaborative (DGC) at MHDC is a collection of payers and providers throughout the region exploring ways to better exchange health-related data incorporating industry standards and automation as much as possible.

MHDC is moving to the implementation phase of the code mapping service - now called MHDC CodeMap - as this newsletter goes out; we hope to have a fully operational service early next year. It will support exchanging data from one location to another - either inside an organization or between organizations - via RESTful APIs as well as allow data to conform to USCDI, FHIR, and FHIR IG requirements. For example, it can be used to align data from a quality measures store to risk analysis management within a payer's organization or to provide information about an encounter to a patient app or send clinical data supporting prior authorization requests from providers to payers. DGC members get a discount, but this service will be available to anyone who wants to use it.

We held our latest deep dive on images on December 7 and learned quite a bit about the current state of image exchange, image support in FHIR, photographs for provider directories, photographs for telehealth visits, and more. Regulations are still a priority in our regular meetings, and we've also been reviewing several recent industry events. We've also explored the process and needs of third party app developers trying to use Patient Access APIs within our Steering Committee. Upcoming meetings will look deeper at the discussions during the December 7th deep dive, continue looking at what we've learned at various industry events, look at upcoming state and federal legislation and regulation, and take a deeper look at several industry projects and initiatives that the group is interested in exploring. We'd like to hold our next deep dive in late January or early February, but a specific date and topic have not been chosen yet. Watch our twitter feed, website, or mailings for more information, or email us to be notified about it directly.

Membership in the DGC is open to any payer or provider with business in Massachusetts - big or small, general or specialist, traditional or alternative. Want to know more? Email

January 2022 Regulations: No Surprises Act

The No Surprises Act was part of the consolidated budget bill passed at the end of 2020. The law indicated most of its provisions take effect on the first day of new plan years on or after January 1, 2022. Two major regulations related to the law have been released as interim final rules (IFRs), but the vast majority of clauses do not yet have corresponding regulation. In an interesting move, several major clauses are supposed to be implemented anyway in a good faith effort to meet the requirements of the law. Regulation for most of these components are expected in the future at which time adjustments might be needed for existing implementations.

Let's take a look at the various clauses of the act and what we know about enforcement of each.

Price Transparency for Care

The price transparency components of No Surprises falls into three major categories: emergency services, non-emergency services, and continuity of care.

The first IFR covered emergency services, redefining the federal definition of what constitutes an emergency service and a rule that all emergency services must be covered at in-network cost sharing for patients and these payments must be included in in-network deductible and out of pocket maximum rules for the patient.

There are several different areas addressed for non-emergency services. First, any out-of-network providers practicing at an in-network facility must be covered as if they're in-network providers. This is true for hospitals, hospital outpatient centers, critical access hospitals, and ambulatory surgery centers; urgent care centers are not currently on the list but are being considered. Visits to these facilities do not have to be onsite; telehealth counts, as does imaging or laboratory work actually performed offsite or sent offsite for evaluation but offered through the facility. It is unclear if office visits at a separate location offered through the auspices of the facility also count; there are indications they do but it has not been explicitly stated either way. Patients may sign away this right in some but not all circumstances, but doing so must be voluntary with no coercion; a partial list of bad behaviors that invalidate consent is included in the IFR.

The major component of the rules for non-emergency services revolve around cost estimates for patients. The process and requirements for these differ depending on whether the patient is insured or uninsured/self-pay (defined as choosing not to use their insurance within the regulations).

In both cases, either when a service is scheduled or at the request of a patient, a provider organization initiates the process by creating a good faith estimate (GFE) of what the services will cost. The GFE is organized around a scheduled service even if it's performed by multiple providers or at multiple facilities or both. A primary provider is responsible for gathering estimate information from all of the other providers and including it in a single GFE.

For uninsured or self-pay patients, the GFE is sent directly to the patient in a format of the patient's choosing; this is outlined in IFR 2. For insured patients, the GFE is sent to the patient's payer. In both cases this must happen within three days if a service is more than ten days in the future (or not scheduled) and one day if it's within three days of the expected date of service.

After a payer is sent a GFE from a provider they have the same time frame of one or three days to produce an Advanced Explanation of Benefits and send it to the patient/member in the format of their choice.

While not binding, estimates are expected to be in the ballpark; patients are allowed to dispute bills from any provider when they differ from the estimate received for those services by more than $400.

Both patients and out-of-network providers have the ability to dispute bills (patients) or payer payment amounts (provider) using a process outlined in the second IFR.

Continuity of care requirements cover care that's already underway when a provider and payer sever their contract and a provider moves from in-network to out-of-network. The No Surprises Act requires that the payer continue to treat this care as if it were in-network for a minimum of 90 days after the relationship is severed and the provider continue to accept both payer and patient payment at in-network rates.

Enforcement expectations for these vary; see the summary chart below for specifics.

Patient/Member Services

There are a variety of patient and member services that can affect cost of services also included in the No Surprises law. There are strict new provider directory requirements for both payers and providers meant to ensure that provider directories are up to date and that, if they aren't, patients aren't responsible for bad information they contain. Providers are required to send payers updated information whenever they start a new contract, end a contract, have material changes, or if the payer requests them. Payers are required to verify the information in their provider directories at least every 90 days; if they can't verify a provider's information they must be removed from the directory. In addition, payers are required to respond within 1 business day to requests about provider or facility status. Patients relying on incorrect information gained from the directory or an inquiry cannot be penalized and services from the relevant providers or facilities must be treated as in-network in terms of cost sharing, deductibles, and out of pocket maximums.

No Surprises also has new requirements for insurance cards. Insurance cards must include a patient's major medical deductible, major medical out of pocket maximum, a telephone and website for consumer assistance, and either information about or a website containing information on additional deductibles and out of pocket maximums if they exist.

Provider Directory and insurance card clauses don't have regulations yet but are enforced to a "good faith effort to implement" level starting in January 2022.

No Surprises also includes requirements around education, notification, and promotion of its other requirements. These include requirements that payers and providers post public notices about no surprise billing and patient rights in each physical facility, provide a one page written document about their new rights to patients, and post information about patient rights on their public websites. The requirement to supply these with some basic information about the required content is covered in IFR 1 but additional information about these and possibly additional disclosures is expected in future rules.

Other Clauses

The No Surprises Act also includes other requirements. It prohibits gag clauses or similar clauses in agreements between payers and providers that directly or indirectly prevent disclosure or access to provider-specific price, cost, or quality data. It also includes compensation disclosure requirements for insurance brokers, plan managers, benefits consultants and similar personnel.

Quick Summary of Enforcement

In summary, here's a list of what is and is not being enforced right away:

Enforced January 1, 2022 (or first plan rollover thereafter):

  1. Gag clause prohibition (no regulation expected)
  2. Emergency services clauses (IFR 1)
  3. Rules and payment models for out-of-network providers at in-network facilities (IFR 1)
  4. Patient consent requirements for signing away out-of-network protections for non-emergency services (IFR 1)
  5. Good Faith Estimates for uninsured/self-pay patients covering a single provider/facility (IFR 2)
  6. Dispute resolution for uninsured/self-pay patients (IFR 2)
  7. External review eligibility (IFR 2)
  8. Coordination of care clauses (good faith effort, regs to come)
  9. Insurance ID cards (good faith effort, regs to come)
  10. Provider Directory (good faith effort, regs to come)
  11. Disclosures, education, notifications, and promotion (general content in IFR 1, specifics as good faith effort, additional regs to come)

Not Enforced until later:

  1. Good Faith Estimates and Advanced Explanation of Benefits for insured patients using their insurance
  2. Consolidated Good Faith Estimates for uninsured/self-pay individuals containing all providers/facilities for a single service (delayed one year, IFR 2)
  3. Dispute resolution for patients using insurance (outlined in IFR 2 but not applicable until related estimates are required)


  1. Compensation transparency rules

And there you have it - everything we currently know about No Surprises so it doesn't surprise you as much as it surprised us.

NEHEN Update

NEHEN reduces administrative burden through the adoption of standardized transactions. It is a cornerstone service for payer and provider trading partners wishing to exchange industry standard X12, HIPAA compliant transactions in a real-time, integrated manner using APIs. Because of our unique governance, non-profit status, and membership-based model, NEHEN is able to offer very competitively priced services relative to the market.

At the December 2nd NEHEN Business User's meeting we revisited the topic of using specific Service Type Codes (STCs) for telemedicine visits and where that stands from an X12 industry exchange perspective. We also discussed the active Draft Request for Interpretation (RFI) #2486 filed with X12 to address the need for an industry specific STCs for telemedicine encounters (you can find it and other X12 RFIs here).

These changes would apply to the X12 v5010 270/271 transactions currently in use by NEHEN and our members. This is important because there was no previous indication that the 5010 version of X12 would make any accommodation for telemedicine specific STCs as addressed in the next version (6020) of the X12 standard which has no announced adoption date. According to a CAQH CORE straw poll, 90% of organizations support this approach. Adopting this new approach would allow for concise, clear, standardized communication about telehealth benefits.

For information about NEHEN please contact us at

Electronic Prior Authorization (ePA) Initiative 

This project is a prototype implementation that automates prior authorization transactions using the industry standard, open platform methods developed by the HL7 DaVinci Prior Authorization workgroup. This project will be compliant with the three related implementation guides which utilize open, FHIR based API exchange methods. This will allow payers and providers to implement a single prior authorization process and format for exchange so long as all of their exchange partners adhere to the same standards.

We are pleased to announce that we have a signed agreement with Blue Cross Blue Shield of Massachusetts and New England Baptist Hospital. We will officially kickoff the prototype project at the start of 2022.

Concurrently, we continue to participate in the DaVinci Workgroup and provide feedback and input into the work product of the final implementation guide. The focus of the DaVinci WG at this time is defining the actions and functions allowed within a PA-related questionnaire used to collect additional details regarding a specific PA request from providers at the behest of payers. Questionnaires are launched by an installed SMART on FHIR app which walks a provider through the information needed for a specific clinical scenario. Once complete, the EHR saves the questionnaire responses within the clinical and patient context for delivery back to the payer. Details about the specific actions needed to accommodate the various PA use cases will be incorporated into the relevant Da Vinci IGs once this work is complete.

For more information email us at

Industry Events

Interested in webinars and online conferences in late December and January? Here are some we recommend (they're free unless otherwise noted):

    We do periodically post webinars we plan to attend on social media, so feel free to follow us on Twitter (@mahealthdata) and LinkedIn for more webinar ideas and for our take on interoperability, data, health equity, telehealth, APIs, and other topics of interest.

    Have an upcoming event next month to suggest? Write us at - no self-promotion please.

    Looking Back at 2021

    2021 started with a rushed Prior Authorization final rule from CMS - one that followed a draft with only 17 days of public comment over the holidays. It had inconsistencies and included a lot more than prior authorization features - most notably, it mandated that payer => payer exchange use FHIR and added a Provider Access API mandating payer => provider data exchange - but it was a logical follow up to the May 2020 interoperability rules and as well as an attempt to address and automate a process (prior authorization) most folks agree is burdensome on payers, providers, and patients.

    The Biden Administration put a 60 day hold on all regulations put forward in the later days of the Trump Administration and, somewhat surprisingly, this rule is still on hold nearly a year later. We agree that the rule needed some revising - getting rid of those inconsistencies and putting it through a normal comment period come immediately to mind - but it addressed some important areas and made some useful modifications to existing regulations. One of the big questions for 2022 is whether it will come back and, if so, in what form? Check out our 2022 predictions for some thoughts on this.

    Also at the start of the year, new hospital price transparency requirements started. They were just the tip of the iceberg, as we soon discovered. As the year moved forward, we discovered that a law passed without a lot of fanfare in late 2020 (as part of the consolidated budget) would become more and more of a focus. The No Surprises Act included a wide ranging set of policies and requirements around price transparency and continuity of care. While most people focus on the requirements around good faith estimates from providers and advanced explanation of benefits from payers, there's a lot more to the law that affects everything from insurance cards, out-of-network payments, end of payer-provider contract requirements, provider directory validation with related patient responsibility requirements, and more. It's big, and most of it goes into effect at the start of the first new insurance plan year on or after January 1, 2022. Only a small portion of the bill has corresponding regulations. A few of the provisions have been put on enforcement holds pending related regulation, but in many cases folks are supposed to make their best effort to comply without regulation until that regulation can happen. We'll discuss this further in our predictions for 2022 and in our standalone article on the No Surprises Act.

    With the change of administration came personnel changes and our longtime friend Micky Tripathi became the National Coordinator for Health IT (head of ONC). One of the big pushes that followed is the idea of "equity by design" or trying to ensure health equity by consciously thinking about it as part of planning everything they do. Health equity and SDOH were big in other ways this year, with numerous events focusing on it (our own DGC Deep Dive on SDOH was by far our most attended with over 300 people registered and, at its height, more than 200 concurrent attendees). Congress is also on the bandwagon with several bills in process on SDOH, SDOH data, SDOH analysis, and more. If passed and signed into law most of these will have data and interoperability implications. Again, more on this in our 2022 predictions.

    Also from ONC came enforcement of the first information blocking requirements in the spring, requiring providers to share requested health information (within consent frameworks). Initially only clinical data within USCDI is required, but more comprehensive data requirements (EHI) are coming in 2022. This information - including notes - must be shared in the format requested (if feasible) unless one of eight allowed exceptions can reasonably be applied to a request.

    Halfway through the year on July 1 came the official enforcement date from CMS for Patient Access APIs and Provider Directory APIs. Some payers did the bare minimum to meet the requirements and some went all in. According to some industry surveys and analysis as many as 75% of payers still weren't in full compliance with Patient Access APIs in the late fall. Edifecs reported some of their payers had difficulty implementing FHIR facades; others were overwhelmed by the amount of data going through the pipes. Many payers who did comply waited to see patients arrive in droves, requesting their data, but it didn't always happen for a variety of reasons: lack of patient knowledge that they can get this data, lack of patient connection between API support and app support, and the difficulty third party apps had in finding and connecting to payers. When they did connect with payers, third party app developers had trouble dealing with the variance in the data sent by the payers, the lack of test data and environments, and with understanding which plans each payer did and did not support. Hopefully this will start sorting itself out better in 2022, but we're not making any specific predictions about it.

    Underlying all of it was the continued effects of the pandemic which still remains with us, sucking up much of the oxygen in the industry. Providers are still in overdrive - Massachusetts has a new order delaying some non-emergency surgeries and other care because hospitals are overwhelmed again despite the relatively high vaccination rates here. The vaccination process highlighted many additional deficiencies in public health data and interoperability (on top of those discovered in testing, contact tracing, and outcomes reporting in 2020).

    2021 - it's been a busy, invigorating, frustrating, and complex year that's brought us closer to data standardization, interoperability, and understanding how to successfully collaborate across organizations. Most importantly, it's brought us closer to a patient-centric healthcare system, one that enables each patient to access and control their own data. It's also shown us how far there is to go and the role data and interoperability needs to play in areas like health equity and addressing SDOH, improving public health capabilities, and moving even further into patient-centric healthcare. What's next on this journey? Who knows? We're making some predictions about 2022 - only time will tell if they come true.

    Looking Forward at 2022 Crossword

    We'll take a serious look at 2022 momentarily, but in the meantime here's a crossword puzzle for a lighter look at what's ahead. Send us your answers at if you'd like but we'll post an answer key next time! 

    2. They're at the center of everything
    3. Healthcare API framework
    5. ONC is doing it by design
    7. Uses data to predict outcomes
    10. Know the cost
    13. Chairman of the Board

    1. They oversee privacy and security of third party apps
    2. Get permission for a service from a payer
    4. Translating the vocabulary of healthcare from one standard to another
    6. Our new analytics partner
    8. She's retiring and we'll miss her
    9. All outcomes are known
    10. CMS regulated exchange starting in 2022
    11. Our exchange services arm
    12. Food insecurity, homelessness, etc.

    Looking Forward at 2022

    What will 2022 bring? What will we be focusing on this time next year? The simple truth is that we don't know. Price transparency and other No Surprises Act clauses weren't on our radar this time last year but it consumed many of our cycles as we moved further and further into 2021. That said, we do know some of the items currently on the agenda for 2022 and some other things Congress, HHS, and others have said will be priorities for them moving forward. Given that, here's our best guess at what we can expect in health IT in 2022:

    1. Payer => Payer exchange, technically required as of January 1, 2022, is under enforcement discretion pending further regulation. We predict this will continue until FHIR is required for all, likely in 2023. We recommend implementing this exchange via FHIR when you're able to do so; this one is going to happen at some point and better to be ahead of the curve rather than behind it. See the Payer => Payer Exchange article elsewhere in this newsletter for more on this requirement and the enforcement discretion.

    2. No Surprises implementations and enforcement will be haphazard at best. A huge law with a ton of separate and distinct requirements, only a small portion of No Surprises has regulatory support at this time. Some clauses have been delayed either for a set time period or until regulations are released, but other components are supposed to be implemented with a best effort implementation by individual payers and providers. This will result in a slew of incompatible implementations that will likely have to be redone once regulation occurs. Hopefully we're wrong about this one and things are a bit more orderly than anticipated but we're not holding our breath.

    3. Information blocking rules expand to require exchange of all Electronic Health Information (EHI) on October 6, 2022. Until then only USCDI falls under this rule. EHI is a major expansion - essentially a superset of the HIPAA designated record set and all available PHI - and making it available in mechanisms requested by patients will take effort. Providers should probably start planning now if they haven't already.

    4. More provider directory regulations are coming. Nearly all interoperability or interoperability-adjacent regulations from CMS have included some form of provider directory improvements and the CMS Office of Burden Reduction and Health Informatics indicated that it's one of their major priorities for the near future. What form this will take is anyone's guess, but we'd be shocked if this trend doesn't continue.

    5. ICD-11 is on the horizon. CMS is starting to look at its adoption. We don't expect implementation requirements during 2022 but we might get a requirement for future use during 2022 or early 2023.

    6. New regulations are going to start requiring USCDI v2. While CMS regulations with implementation dates through 2023 all require using USCDI v1, we expect that new regulations will start requiring USCDI v2 at some point next year, both for existing APIs and exchanges and for new ones.

    7. The frozen CMS Prior Authorization Rule will remain frozen. However, major components of it will be revived in other forms over time. In particular, we expect updates requiring Payer => Payer exchange to use FHIR (likely before enforcement discretion is lifted), regulation outlining Provider Access API requirements, and some form of electronic Prior Authorization requirements revolving around the three related DaVinci implementation guides to come out, although perhaps not all in 2022. See our discussion Payer => Payer exchange for more about expectations for early 2022.

    8. Regulations around post-acute care interoperability are coming, particularly to support transfer of care location. The CMS Office of Burden Reduction and Health Informatics indicated that this is another priority looking forward.

    9. Regulations around use of AI and machine learning are coming, particularly around reducing bias and transparency of use. ONC has made equity by design a major priority and CMS is also interested in improvements in this area. What form this takes is anyone's guess, but something's coming.

    10. We'll see new interoperability requirements for public health reporting including around health equity and SDOH. In addition to vaccine, condition, and side effect reporting and collation to improve pandemic readiness, we'll see other interoperability improvements for public health reporting in the areas of health equity and SDOH needs/interventions. Basic SDOH data is part of USCDI v2 and may see some exchange just by virtue of version requirement updates, but more standardized reporting of demographic and similar data is likely also coming at both state and federal levels.

    11. Consolidation of quality measures. CMS has already started doing preparatory work in this area and seems very keen on moving forward across the industry as much as possible. What form that takes or how fast it actually happens is anyone's guess, but expect some moves in this direction in 2022.

    12. Patient Access API write operations. This is a pie in the sky item to wrap things up because sometimes you have to think big. It would allow patients to add notes or data or make corrections to existing data that's wrong from within the third party apps they use to view the data and have it flow back through the system in some form. Provider Access APIs are likely needed first, as the logical flow would be patient => payer => provider, but we'll have our fingers crossed. If not in 2022, then maybe in 2023 or 2024.

    So there you have it - 12 predictions for 2022, some based on currently announced plans and regulations, some best guesses based on industry chatter and comments by regulators, and a couple of wilder suppositions that may or may not have any basis in reality. We'll see how we did at the end of next year. What do you think will happen in 2022? Let us know at

    Wrapping Up

    Before we go, here's a reminder of upcoming data exchange deadlines from ONC and CMS (including the CMS rule that's currently frozen, as noted by *):

    And that's it, folks. Loved it? Hated it? Have an idea for next time? Send us feedback and suggestions about this newsletter at or send us feedback and suggestions about anything else at

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