Is Clinical Quality Language (CQL) the next Black Swan of the HIT industry?

Apr 29, 2016

Is Clinical Quality Language (CQL) the next Black Swan of the HIT industry?

Healthcare IT, Healthcare Newsletter , 0 Comments

This is the first issue of our HIT Newsletter produced jointly by Marlin & Associates and XEN Partners. We hope that you enjoy it. Read the full review HERE.

In the dynamic world of healthcare, the sheer magnitude of innovations and the capital behind actualizing the vision of our entrepreneurs is enough to keep us fully occupied. We continue to see significant activity in the areas of value based reimbursement, consumerism, mobility and informatics. These technologies aim for the double play of increasing quality while reducing costs. At the same time, we see a Black Swan lurking in the background which is not getting the attention it deserves. Clinical Quality Language (CQL) will spur the creation of a whole new set of players and may propel our industry to a new level of automation and efficiency.

CQL is a government mandated file format standard that aims to unify the expression of logic for Electronic Clinical Quality Measures (eCQM) and Clinical Decision Support (CDS). Essentially, eCQM measures impact/care quality outcomes, while CDS recommends clinical actions. They are closely related. The government has come to realize that the ONC’s mandated alternative payment models have placed an undue burden on many providers and payers. At the end of the day these models may have created more problems than solving the cost issue. 


CQL aims to harmonize the rules of the providers and payers so that both will speak the same language and work off of the same “excel sheet”. Our industry today spends billions of dollars bridging the language that providers and payers use to communicate with one another. Once CQL is in place, we can only imagine what could happen to the tens of thousands of administrative functions that facilitate that process today. For example, under CQL, the need for pre authorization which is one of the costliest processes for payers, may gradually go away because the industry will be able to agree on and exchange treatment protocols in advance.

The government says that it will start giving providers machine executed files (CQL) starting in 2017 with gradual on boarding of the full set of rules by 2019. They are known for being late. Like ICD-10, the pain of adoption will be enormous but the cost savings at the end will be unlike any other industry standard set to date.

If the government lives up to its promise, by 2020, our industry will start witnessing one of its most radical changes. There will be a new breed of companies that will be ahead of the curve commanding healthy valuations. Some have already started dedicating considerable resources for implementing this change; many are still in stealth mode.

The most immediate opportunities are for companies that can play the role of “translation/enabling” engines helping EMR vendors visualize and curate the government rules. The addressable market for these companies will be massive. Furthermore, since the combination of SMART on FHIR (a set of open specifications for integrating apps with EMRs) and CQL essentially creates an iTunes type platform, we foresee a robust and growing healthcare application market. Much like iTunes, the app companies will build solutions ranging from light to industrial strength applications. These apps in turn can be seamlessly plugged into different EMR systems. Some claim that If CQL was in place today, conversion to ICD-10 could have been done with a plug in app. We may or may not agree with that statement but we know that the government is fully committed to a level playing field for data harmonization. We have no other choice but to save the system.

Perhaps we should take a step back from our busy day and see what is lurking beyond the immediate horizon. History has taught us that Black Swans’ arrivals are often sudden, they are usually rationalized after the fact, and they leave many soldiers defeated at their feet. But the few that survive get to reap the spoils!

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