A Consumer Driven Perspective to CMS 9115 Compliance: A Win-Win

2020 was a chaotic year for all of us trying to deal with COVID. CMS, most impressively, continued to press through that chaos to pass three important rules around Interoperability, Patient Data Access, Prior Authorization & Coverage Transparency (9115F, 9123F and 9915F) that will change US Healthcare for ever. Over thousands of payers and millions of providers serving Medicare & Medicaid will need to comply with one or more of these rules starting 2021.

Each one of these rules is momentous from the standpoint of value to consumers. In an industry where most consumers still do not know the real cost or quality of the health care they seek, these rules are much needed. They will undoubtedly open up a plethora of solutions that give consumers the information needed to make the right healthcare decisions for themselves and their families.

However, these rules also place a compliance burden on plans, hospitals and other providers. The burden is not just limited to the cost of deploying & maintaining compliance solutions, but also the continued exposure to risk of being sole stewards of “pieces” of the consumer’s health record that they happen to have. This burden can be debilitating – especially for smaller organizations that may not have the resources to implement such solutions.

It will not be surprising therefore to see partial solutions & workarounds emerge as deadlines approach. Partial solutions & workarounds will not meet the consumer’s needs despite best intentions on behalf of the organizations offering them.

I strongly believe in a win-win – i.e consumers cannot win if the organizations lose. So, we are going that extra step and will make our compliance solution available at no cost to ALL payer & provider organizations with fewer than 5000 members/ patients.

Why are we doing this? We know that the smaller the organization, the more severe their resource constraints are likely to be. But a level playing field benefits everyone. It is our way of helping smaller payers & providers close that investment gap and better serve their consumers.

We are also taking a unique approach by solving not only for compliance, but also for convenience & risk mitigation for all stakeholders – payers, providers & consumers.  Our solution will not only help health plans and providers meet 9115F requirements, but these organizations can mitigate risk of liability of managing a consumer’s PHI by giving consumers control of their information inside their own app. Consumers can then manage their own records without having to come back to the organization for subsequent data access or share requests. Payers and provider comply with rules and mitigate risk, Consumers get more convenience. A win-win.

Mpowered Health will over the course of next few weeks share more detailed insights on our solution. Preliminary discussions with industry executives & ROI analyses show that Mpowered Health’s CMS compliance offering will be significantly cost-effective for plans and providers of all sizes not just the organizations serving 5000 people or less.

What personally gratifies me is that, with our solution we are solving for multiple problems for multiple stakeholders – payers, providers & consumers. Although I dislike hitting birds with stones, I feel good about “hitting two birds with one stone….or many with one”.