The Office of the National Coordinator for HIT’s proposed rule for Stage 2 of the electronic health records meaningful use program begins the process of including use of metadata as criteria for compliance.

In December 2010, the President’s Council of Advisors on Science and Technology called for metadata to be part of Stage 2. The ONC rule, in its current non-published version on pages 34-35, pushes limited use of metadata.

The 2010 PCAST report describes metadata as follows:

“The best way to manage and store data for advanced data-analytical techniques is to break them down into the smallest individual pieces that make sense to exchange or aggregate,” according to the 108-page report. "These individual pieces are called ‘tagged data elements’ because each unit of data is accompanied by a mandatory ‘metadata tag’ that describes the attributes, provenance, and required security and privacy protections of the data.”

This means that privacy rules, policies and applicable patient preferences “are innately bound to each separate tagged data element and are enforced both by technology and by law,” the report continues. “For example, a patient with diabetes may decide that her blood sugar information should be available to any of her doctors and to emergency physicians requesting that information should she have a problem while traveling in another state--but that details of her past treatment for cancer should remain private and not be shared.”

In the proposed rule, ONC calls for adoption of the Consolidated CDA standard for summary of care records, which essentially is a revamped Continuity of Care Document. This standard includes several metadata elements, including two that are proposed for use--data provenance and the ConfidentialityCode. Provenance gives information about the history or origin of data, like a date/time stamp. The ConfidentialityCode describes what kind of data is being electronically sent--N for normal, R for restricted and V for Very Restrictive.

An article, published in the February 2012 Journal of the American Health Information Management Association before the Stage 2 rules came out, gives an excellent plain-language explanation of what metadata is, types of metadata, how they are used, and even what they look like. Authors are Allison Viola, director of federal relations at AHIMA, and Shefali Mookencherry, principal health care consultant at Hayes Management Consulting. The article is available here at no cost.

Both proposed Stage 2 rules are scheduled for publication in the Federal Register on March 7, with a 60-day comment period to follow. Federal officials hope to publish final rules during the summer.

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