HHS Plans to Issue Rule on EHR Metadata Standards

The Department of Health and Human Services expects soon to issue an "advance notice of proposed rulemaking," on adoption of metadata standards to support the electronic exchange of health information.

The notice is a first step toward implementing certain recommendations from the President's Council of Advisors on Science and Technology, particularly focused on including some degree of metadata in Stages 2 and 3 of electronic health records meaningful use criteria.

An advance notice lays out an agency's initial thoughts about a policy issue and seeks public comment that will influence development of a proposed rule. HHS has sent the advance notice to the Office of Management and Budget for review before publication in the Federal Register.

The President's Council, known as PCAST, recommends use of a "universal exchange language" to facilitate the exchange of health information while protecting privacy by giving patients more control over the dissemination and use of their medical information in an automated fashion.

Universal exchange languages for metadata descriptions, known as "extensible markup languages" or "XML," are widely used, the council noted in its December 2010 report, "Realizing the Full Potential of Health Information Technology to Improve Healthcare for Americans: The Path Forward."

"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 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."

In April 2011, a workgroup of the advisory HIT Policy and Standards Committees concluded that the PCAST vision was not feasible, but it is possible "to implement the new exchange architecture in an incremental fashion."


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