Friday was the deadline for public comments on the Office of the National Coordinator for Health ITs draft nationwide Interoperability Roadmap. Comment from industry groups ran the gamut from outright support to tough criticism.
Also See: How Far To True Interoperability?
Overall, the Healthcare Information and Management Systems Society supports the roadmap, saying it lays out a plan that builds on what HIMSS has already invested in: standards that enable the foundation for interoperability today, and processes to test and certify that health IT systems implement those standards consistently and according to constrained implementation guidance.
However, HIMSS cautioned against creation of a top-down governance process dominated by the federal government. No single network, organization, or process will be able to provide and manage the interoperability life cycle. We, therefore, do not foresee a unitary and monolithic governance process, rather a set of processes that requires some coordination, but largely can operate independently as long as the overall scope, focus, and direction is well understood and shared.
HIMSS urged ONC to work with stakeholders to establish a lean coordination framework with a focused approach to support a small set of high-value, impactful use cases that can substantially benefit from improved interoperability. At the same time, the organization advised that prioritization should in no way hinder private sector and market efforts to develop and implement standards and technologies for other use cases or needs.
The Workgroup for Electronic Data Interchange in its comment letter strongly supports ONCs efforts to establish an Interoperability Roadmap, but urged ONC to better reflect the realities,gaps, challenges, and opportunities across the current landscape. According to a recent national survey conducted by WEDI, there are significant barriers to interoperable electronic data exchange among providers, health plans, and vendors that need to be addressed.
As a result of these barriers and competing industry priorities, WEDI called the proposed timing and scope of the roadmaps critical actions for both public and private stakeholders aggressive and suggested that ONC prioritize these steps. WEDI believes that the healthcare industry is still working onimplementing the basic infrastructure in order to support the exchange of electronic health data. Giventhe nascent state of these efforts, and in light of competing deadlines (e.g. ICD-10, AdministrativeSimplification provisions, etc.), WEDI would encourage ONC to develop a prioritized list of actions andindividual stakeholder assignments that can be achieved with reasonable effort.
WEDI also cautioned that changes required for national interoperability will require more involvement of industry and less direct oversight from the federal government. Over the past several years, ONC has played a key role in driving thedevelopment and adoption of core building blocks and standards for health information technology, according to the organization. As wemove, however, into a more mature phase of building a health IT infrastructure, WEDI would encourageONC to continue its shift away from a government-based governance and oversight program and movetowards coordination and guidance with private industry partners. Given the success of efforts such asHealtheway, the industry would stand much to gain if ONC identifies additional priority areas for public-privatecollaboration.
Comments from the Electronic Healthcare Network Accreditation Commission focused on the accreditation process for organizations and health IT products in the areas of privacy, security and confidentiality. While EHNAC was pleased to see that ONC recognizes that certification and testing to support adoption and optimization of health IT products and services is one of the five building blocks in the draft Interoperability Roadmap, the organization proposed that the document go further than just the certification/accreditation and testing of the interoperability standards.
The range of functions, ease of use, vendor support and product platforms are all key issues for users of IT products, EHNAC argued in its comments. In addition to base certification of standards, we would also recommend that ONC confer and include vendor and user groups to help define best practices for IT products to meet, especially in the realm of interoperability.
At the same time, EHNAC asserts that there is a need to streamline the plethora of certification/accreditation programs that currently exist. It will be important for ONC to recognize and work closely with other certification/accreditation programs to reduce any duplication of effort on the part of stakeholders and to align, as closely as possible, requirements among programs.
EHNAC also recommended that ONC allow entities to choose the certifications/accreditations they wish to achieve and that it should be the decision of the users of products to determine what certifications/accreditations they feel are necessary for a product in determining compliance with privacy, security and confidentiality to minimize exposure and risk of a breach or incident. The organization warned that a one-size-fit-all approach will only lead to complex and over-architected products which may contain features not necessary to a wide range of users.
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