Monthly Review: Christmas Wormhole Edition
HTI-2 progresses, HIE swirls, and Epic punches back
I will be the first to admit - a semi-fortnightly cadence is both confusing from a linguistic standpoint and also a level of frequency that does not account for the natural twists and turns of life’s vicissitudes. So, this is my reset to a normal nomenclature and achievable tempo. It’s also a nicer, downright plump set of content for you all to check out.
We’ve all noticed by now, but whoever in the government scheduled the holidays this year did something weird, choosing to slot us not only for the latest possible Thanksgiving but also the maximum blast radius Christmas and New Year’s (on a Wednesday). Regardless of our creed or faith, on the business front, we only just escaped the Thanksgiving lull only to proceed vigorously into the Christmas wormhole. With limited weekday hours to close deals and ship code and even fewer weekend minutes for exceedingly mediocre at-best holiday movies (the revival of a quorum of the cast of Mean Girls via Hot Frosty and Our Little Secret truly a comeback story of the season, disregarding cinematic quality), something feels off this year with this year’s timetable.
Regardless, here is your monthly review. As a reminder, this is a regular round-up of various short(er) form content on the big three of socials (X, LinkedIn, Bluesky) to surface things you may have missed.
Politics and Regulation
The past month feels as though it’s been the NFL Draft sound on repeat as news outlets scrambled over one another to announce our President-Elect drawn-out selections for various Cabinet and executive branch positions, with selections ranging from edgy/controversial (Gaetz, Gabbard, Dr. Oz) to talented (lots of a16z and Paypal mafia). We’re still waiting to see who will lead ASTP, which I care about most.
We sit in the multiverse of possibility, where everyone is dreaming (or nightmaring) about the infinite multitude of things that the new administration and DOGE might do. So there’s obviously been a rush to finish some last items and to prognosticate on what’s to come:
Republican Criticism of ASTP (and follow-up): A few senators wrote a strongly worded letter to Micky Tripathi, current ASTP lead, about the reorganization of the agency and some of their work on AI. It’s a bit of rabble-rousing dependent on squinting at reality, but it is a sign of their perspective on AI and the ASTP that should be considered carefully.
Standards Wars of Eras Past: We’ve seen standards wars before and we’ll see them again. The HTI-2 proposed rule has a variety of interesting comments that highlight how certain standards bodies are grappling for dominance in regards to PDMP and federated trust.
Trump and Antitrust: Despite big Republican wins in the election, antitrust autumn is not over. Many signs point to this version of conservatives continuing the fight against Big Tech and PBMs.
HTI-2: It’s just TEFCA: There was no way the ASTP was finalizing the full HTI-2 rule before the next administration takes over, so they pushed out an abbreviated cut that’s just the TEFCA provisions and some clerical changes.
HTI-3: Protecting Care Access Exception: In a move we haven’t seen before, the ASTP followed up the above with another cut of HTI-2 that just contained the Protecting Care Access Exception. The remainder of HTI-2 will be subject to, at minimum, a freeze as Trump takes over. They could continue to see parts of that through (many of us hope they do so for key features like FHIR Subscriptions and CDS Hooks), or they could mothball it and set an entirely new set of objectives and goals.
Health Information Exchange
December had both the Annual ASTP Meeting in DC and the eHealth Exchange/Sequoia Project/Carequality Annual Meetings in Nashville. As a result, there has been bountiful discussion on health information exchange, the nationwide networks, and TEFCA:
NCPDP Piloting Medication Availability: E-prescribing is a ubiquitous national capability at this point, but that doesn’t mean it’s perfect. One known issue is when a prescriber sends to a patient’s pharmacy who doesn’t have the medication in stock. NCPDP is trying to resolve this with a new transaction type, surfacing availability at the prescription time.
Benefits Determination: A recent article highlighting Epic’s success in expediting Social Security benefits determination (for those with disability) shows a unique workflow that we should scale to all EHRs.
Repetitive Questionnaires and HIE: If health information exchange is becoming widespread and nearly ubiquitous, why do patients have to fill in the same form each time they have an appointment? This post explains the why by giving some context on how EHRs have implemented this workflow
The First TEFCA IAS Exchange: Individual Access Services is the next step in our long journey to give patients easy access to their data, so seeing this announcement of the first successful exchange (between b.well and Epic) is cool. If we scale this up and remove the patient portal log-in piece, we will transform how patients can interact with their providers and direct their data.
Rent-Seeking, Price Controls, and HIE Incentives: The arbitrage opportunity that is selling data from health information networks to life sciences, law firms, and other non-Treatment entities via secondary use is a function of the incentives we’ve created via the price controls we’ve implemented.
Visa, Department Stores, and Defining Treatment: The disputes and legal battles of this year have strong parallels in the history of Visa, where the organization almost tore itself apart over the addition of new participants (department stores)
State HIEs in an Era of Nationwide Exchange: States health information exchanges are not irrelevant in the era of ubiquitous nationwide clinical exchange (TEFCA or otherwise), but they are forced to innovate and provide the next level of infrastructural services as the floor is raised.
Artificial Intelligence
Flexpa’s LLM FHIR Eval: Flexpa (my old employer) released a handy toolset for those playing with AI and FHIR data.
Data Exchange in an AI World: There’s a lot of debate going back and forth on whether AI makes data standards obsolete. The reality is that it makes dumb/analog pipes significantly more helpful and also makes dumb/analog payloads more discrete and valuable.
EHR News
MEDITECH Showing and Not Telling: I’m getting more and more impressed by MEDITECH on the interoperability front, who continues to ship instead of talking shit. Oracle would benefit from following their lead.
Epic’s Motion to Dismiss: In a buzzer beater just before the deadline, Epic filed their motion to dismiss the antitrust lawsuit against them. Dismissal of antitrust is rare, but it’s a strong and convincing argument based on the one reason you typically do (incorrect market definition).
Info Blocking and Privacy
Interoperability Court Cases: As we head into the winter break, this summary outlines the current state of the Big 3 of interoperability court cases (Particle v. Epic, RTMS v. PointClickCare, and Intus Care v. RTZ) and where they’ll go next
HIPAA is a Bad Law: HIPAA was supposed to bring us privacy and security in healthcare, but we have neither. It’s time to re-evaluate and improve this pre-Internet law by shifting the scales toward the patient.
Other News
GTM and Sales Leader: A good friend of mine is looking for her next position:
Nadine Peever Joining HTD: My old colleague and friend Nadine Peever has joined HTD, bringing deep interoperability expertise and expert partnerships skills. We and our customers are excited she’s here to extend our ability to offer top-level interoperability strategic advice and execution to clients.
External Media
John Lynn is the OG health tech marketing king, so it was fun to spend a few hours diving through Epic, interoperability, and more, broken up into three sections:
Epic Culture and Interoperability with John Lynn: Focusing on what it was like to work at Epic, including the intense work culture and CEO Judy Faulkner's leadership style. We also covered the evolution of healthcare interoperability and Epic's success factors, including their commitment to integrated systems and strong customer focus.
EHR API Deep Dive: Moving a bit broader and chatting about the evolution and current state of healthcare interoperability, focusing on the shift from basic treatment-focused data sharing to more complex use cases through TEFCA, while also exploring the challenges of asymmetric relationships in data sharing and the importance of transparency in building trust across healthcare networks.
Jonathan Bush, Patient Access to Health Data, and Is Epic a Monopoly?: Shared my perspectives on Epic's market dominance, potential antitrust concerns, and improving patient access to healthcare data through better interoperability and administrative workflows.
Events
Washington State of Reform (Seattle, Jan 9): Speaking on a panel about Washington’s Health Data Exchange Infrastructure
ViVE (Nashville, Feb 16-19): Not speaking but certainly participating. My personal goal is to find whoever runs these conferences and convince them not to schedule them over holiday weekends.
HIMSS (Vegas, March 3-6): Keynoting the HIE Forum and attending my first HIMSS. The lineup for the HIE forum is killer, and I guarantee that whoever gets up early for the keynote will be rewarded.
quality stuff, Brendan!