How Federal Rules Can Help Public Health Agencies Get The Data They Need

The United States’ response to the COVID-19 outbreak suffered various stumbles, but one of the biggest came when state and local public health agencies initially tried to understand how widespread the virus was in their communities so they could target appropriate interventions.

Nationwide, test results and reported cases often came to public health authorities via methods such as fax machines, which meant officials had to spend time and resources entering data into their electronic systems before they could identify hot spots and launch case investigations or contact tracing. To make matters worse, many reports lacked fundamental information, such as the person’s race or ethnicity, address, or phone number. Without those details, it would be nearly impossible to track down others who may have been infected, determine how the disease was affecting different communities, or track the progress of vaccination drives and other interventions.

Such  problems pre-date the pandemic, and continue to hamper responses to other health challenges, including local meningitis outbreaks, upticks in Type 2 diabetes, or environmentally-triggered diseases like asthma. Fortunately, the technology to get public health agencies the data they need exists; most electronic health record (EHR) systems already can share this data electronically. Many health care providers, however, don’t use those capabilities, citing reasons that include costly connections between EHRs and public health systems, limited staff capacity, and a lack of familiarity with where to send the data. Now, the Centers for Medicare & Medicaid Services (CMS) has an opportunity to address some of these issues.

Broadly speaking, public health work relies on four types of data: Case, lab, and immunization reports that can provide patient-level information; and syndromic surveillance that uses data from emergency departments to paint a broader picture of potential population-level health threats. All four help health departments identify risks and determine what actions to take.

For example, lab results that contain individuals’ demographic information are vital for contact tracing and identifying outbreak “hot spots.” Syndromic surveillance, on the other hand, provides information on symptoms and behaviors that can help identify potential outbreaks before they become widespread. For example, if emergency departments note a sudden increase in visits with vomiting and other gastrointestinal issues, this could be a sign of foodborne illness that would need to be reported to public health agencies.

However, simply collecting this data isn’t enough. For it to be useful, agencies need to receive it quickly, and it must contain all the information needed to contact individuals and understand how different groups or communities are being affected. That makes electronic submission essential, with data ideally coming from EHRs in hospitals or doctors’ offices or the laboratories that conduct the tests. This way, authorities can get timely and complete information and quickly decide on interventions.

Although the technology to share this data electronically exists, and previous federal incentives have led to more hospitals doing so, uptake remains lower than it should be. CMS is already taking steps to fix that, but there is more the agency can be doing.

The agency recently released a final rule for payment systems in inpatient hospitals that would require those facilities to electronically send all four data types—lab results, case reports, immunizations, and syndromic surveillance—to public health agencies. In addition, CMS already requires electronic reporting through its Promoting Interoperability Program, which offers incentives for hospitals to use EHRs in certain ways in order to get reimbursed by Medicare.

However, CMS’ physician fee schedule–the rules for how doctors are compensated for providing care to Medicare patients–only require sharing case reports and immunization data electronically. That means public health agencies may not have all the data they need to make informed decisions. Although some physicians covered by this rule won’t have data that could support syndromic surveillance, those who practice at urgent care centers do. And that information could be vital for public health officials to understand the risks of potential outbreaks. CMS can and should require that urgent care clinicians send such data to relevant public health agencies.

These changes wouldn’t be enough on their own. States and localities also need to ensure their public health agencies can accept this data and require that it be sent to them electronically.  Even so, the recent moves by CMS represent a major step toward giving those agencies timely, electronic data, which can help save lives, but the agency still has more it can do to support that goal.

Molly Murray manages The Pew Charitable Trusts’ public health data improvement project.