ONC in August issued an advanced notice of proposed rulemaking, laying out its initial thoughts about metadata and seeking public comment. Adoption of EHR metadata standards, which the President's Council of Advisors on Science and Technology has advocated, could help improve data exchange and would enable patients to segregate parts of their medical records, such as self-paid treatment for sensitive conditions.
Metadata tagging does have the potential to increase the reliability, dependability and trustworthiness of health information exchanges by better describing the data being exchanged, NCVHS acknowledges in a recent comment letter to ONC.
However, "this approach is not in current use and there are no accepted standards for metadata tags," advisory board members contend. "Consequently, we believe that it is premature to start the rulemaking process for metadata standards without having a better understanding of the current level of maturity of those standards, assessment of the degree to which they have been tested or even used in the industry, a careful analysis of possible unintended consequences, and, more importantly, a policy framework that defines their use."
NCVHS also reminded the ONC that industry stakeholders already have plenty of I.T. initiatives on their plate, including meaningful use Stages 1 and 2, HIPAA 5010 transaction sets, ICD-10, new operating rules for HIPAA transactions, and changes to health care delivery and financing under accountable care organizations. "Introducing yet to be tested standards in the midst of these initiatives would pose significant challenges and risks to the health care industry."
The full comment letter is available here.
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