Recent comments from the HIMSS Electronic Health Record Association on a proposed national health information technology Interoperability Roadmap urge that parts of the project move swiftly while other initiatives should slow down.

In a letter to National Coordinator for HIT Karen DeSalvo, M.D., the association urges recognizing and leveraging the work of existing operational health information exchange initiatives, particularly eHealth Exchange, CommonWell Health Alliance and the Care Connectivity Consortium. Though the projects have different governance models, they all share the same technical approaches for patient identification and document queries.

Also See: Senators Blast ONC Interoperability Roadmap for Lack of Details

But when it comes to the “emerging and very promising” HL7 FHIR interoperability standard, EHRA wants a more cautious approach. “The roadmap needs to account for several critical facts, not the least of which is that the FHIR standard is not yet final or complete,” according to the comment letter. “Some components are more likely to become stable and robust first, and those need to be favored to support the use cases most essential to address high-priority gaps.”

The association also suggests a first-level pilot of FHIR using C-CDA document push (Direct messaging) and pull (XDS/XCA) standards, with the pilot sites officially recognized as meeting applicable Stage 2 meaningful use measures.

EHRA cautions the Interoperability Roadmap does not adequately acknowledge the role that workflow plays. “We are concerned with the specified scope definition of this first Interoperability Roadmap iteration. Interoperability is very much about workflow support and requires core demographic data of the patient to ensure data is associated with the right patient. The Roadmap appears to exclude workflow support and administrative data in general, yet includes various actions specifically focused on workflow and administrative data.”

The roadmap further should clearly promote unambiguous patient identification methods, “whether private or public, to enhance our collective ability to associate the right information with the right person without manual intervention in over 99 percent of the transactions,” states EHRA.

Finally, the industry needs clarity on the scope of privacy and security protections intended in the road, according to EHRA. “The reference to ‘learning health system’ and introducing RESTful application programming interface (API) services imply a significant increase in the scope of the interoperability model to include a very broad spectrum of healthcare information systems, including consumer devices. We suggest that privacy and security protections should apply to all system components involved in the interoperability use case, not only to the EHRs. Thus, the Roadmap should clarify that the scope includes non-EHR system components.”

The complete 30-page comment letter is available here.

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