In the past few years, interoperability has become a buzzword making the rounds in health data and regulatory circles. Whether or not your roles have brought you into contact with this term, it is important to understand how interoperability will impact the way clinical health data will be managed and exchanged in the future. Interoperability refers to the ability for health care professionals to exchange and use electronic health information (EHI) across systems. It has become a clear near-term priority for the federal government, as the Department of Health and Human Services (HHS) Office of the National Coordinator for Health IT (ONC) released two large sets of proposed regulatory changes in 2023 alone. As your advocates in the federal government, ASA responded during the public comment periods for these regulations. Importantly, the Centers for Medicare & Medicaid Services (CMS) have indicated their intent for quality measures to be housed within ONC’s standards for interoperability in the future, one indicator of the importance of anesthesiologists’ awareness and engagement on these regulations that may impact our work.

The implications of interoperability and its accompanying regulations on anesthesiology are substantial. For one, a growing number of anesthesiologists are having their administrative responsibilities comprising inputting, retrieving, and communicating patient data on an electronic health record (EHR) system. ONC aims to achieve increased interoperability by implementing standards for EHR developers, which would allow for the more seamless exchange of data between health systems (especially those with different EHR vendors) and provide physicians and other staff with a more complete view of a patient’s medical history. This cause-and-effect chain, in theory, would ultimately lead to less burdened physician workflows and improved patient safety and quality of care through increased staff availability and better-informed decision-making. For the practicing anesthesiologist, this may mean less time tracking down an outside echocardiogram, greater awareness of previous anesthetic complications such as malignant hyperthermia susceptibility or difficult airway, and a broader view into the prior general medical condition of patients presenting for our care.

However, there are numerous roadblocks against regulators’ vision for greater standardization and interoperability, particularly as those goals pertain to anesthesiology and other medical specialties. Anesthesiologists oftentimes have difficulty accessing and using EHRs, and in many care settings, the anesthesiologist does not control or own the EHR. Further, many anesthesiologists work at ambulatory surgical centers and office-based locations that use paper charting for anesthesia records. Regardless of setting, anesthesia records contain multiple clinical data points and free text that cannot always easily be discretely captured for simpler transmission between medical records. ASA has advocated directly with ONC on this issue to ensure anesthesia is not left behind or left out of the benefits that interoperability poses for health data and patient care.

One of ONC’s main mechanisms for building out interoperability across the nation’s health IT systems has been implementing USCDI, a standardized set of health data classes and elements built from existing terminology standards, such as LOINC and SNOMED. ONC requires EHR developers and vendors to implement USCDI’s standard dataset in order to participate in their Health IT Certification Program, which is the basis for most of the agency’s standards and regulatory requirements.

ONC has issued four increasingly comprehensive versions of USCDI dating back to 2020, and ASA has supported this standard’s advancement of interoperability while advocating for data classes and elements that incorporate the specific parameters of an anesthesia record, which will more fully integrate anesthesia data into EHR systems. This year, ASA provided comments on ONC’s draft USCDI Version 4 to request clarity on some of the new data elements and support more seamless clinical use of the dataset. Among these comments, ASA requested information on how race and ethnicity data elements could be reported, recommended greater functionality within the “Time of Procedure” data element to allow for the inclusion of “Anesthesia Start Time” and “Anesthesia End (Finish) Time,” and supported an expanded and clearer definition of the “Average Blood Pressure” data element. Details aside, our advocacy is intended to ensure that the ONC is aware of the special needs of the anesthesiology community and that regulatory proposals encompass these needs.

In April 2023, ONC published the first proposed rule in a set of forthcoming regulations to implement provisions of the 21st Century Cures Act, signed into law in 2016. ASA submitted comments on the wide-ranging rule, “Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing (HTI-1),” which included support for interoperability and standardization actions such as updating Health IT Certification with the latest and most inclusive code sets and a requirement for certified health IT to allow for electronic case reporting by 2024 (using the standard code sets).

ASA also commented on the rule’s regulation beyond the scope of interoperability. ASA’s letter commended ONC for implementing new requirements around testing and transparency for the development of decision support intervention applications using artificial intelligence and recommended that further regulatory safeguards be added to include required reviews for health disparities and potential biases. ASA supported the addition of new information blocking exceptions to prevent undue burden on anesthesiologists and other medical professionals.

ASA will continue to advocate for a more complete incorporation of anesthesia records within USCDI, potentially including a dedicated data class for anesthesia care or an anesthesia format guide that reorients USCDI around anesthesia elements. These solutions would guide health IT developers in building out EHR systems to harmonize with anesthesia record formats.

Another near-term priority will be preparing for CMS’ implementation of USCDI+ Quality as a baseline dataset for electronically reported quality measures, including those reported within the CMS’ Quality Payment Program. USCDI+ Quality is a new extension of the base USCDI dataset with additional data elements to account for electronic clinical quality measures. The ONC release of a new USCDI+ Quality dataset this year only confirmed what ASA and our Anesthesia Quality Institute National Anesthesia Clinical Outcomes Registry already knew – that the transition to digital quality measures is moving forward and that ASA and AQI must equip our members with the tools necessary to collect, report, and assess data in a more seamless way.

ASA will carry this advocacy forward with fellow specialty stakeholders and educate members on how they can prepare for the implementation of USCDI+ Quality when reporting quality measures. Regardless of your role in your organization, it may be valuable for you to engage your health IT or informatics department to stay informed on how interoperability regulations will impact your workflows and facility operations.