The April 2015 HITSC meeting focused on the Certification Rule NPRM and a comprehensive review of the Federal Interoperability Roadmap.
I suggested that a guiding principle for the committee’s work is to emphasize the enablers in the proposals while reducing those aspects that create substantial burden/slow innovation. As a federal advisory committee our job is to temper regulatory ambition with operational reality.
First, Dawn Heisey-Grove provided an overview of Medicaid eligible professionals’ progress towards Meaningful Use.
Next, Steve Posnack and Michael Lipinski provided a detailed review of the Certification Rule NPRM. We congratulated Steve and Michael on a great analysis and look forward to public comments. Th advice from the committee included
*The scope needs to reviewed through the lens of prioritization. Not every stakeholder desire is of equal impact
*Each candidate standard needs to be reviewed for maturity/adoption
*It is better to do a few things well at depth than to pursue breadth superficially
*The burden of the entire regulation, not its component parts, needs to be considered
*Some requirements are best left at a functional level (as was done for APIs) rather at a prescriptive standards level, especially where standards are immature
Steve announced the formation of a Standards Advisory Task Force to review the NPRM comments which we will discuss at the May meeting.
When then turned our attention to the interoperability roadmap.
Jamie Ferguson presented the findings of the Semantic Standards Workgroup. Key points included
* Data standards (e.g., for performance and quality measures, public health) should reflect the
semantics implemented in EHR systems and semantics in EHR should be the same across
* Need attention to challenges of data aggregation , for example for resolving duplicates,
when data is assembled from multiple sources
* It is critically important for data provenance to be workable and practical for semantic
Dixie Baker and Lisa Gallagher presented the findings of the Transport and Security Standards workgroup. They recommended that ONC partner with the NIST, OCR, and other federal agencies, and industry to enable a uniform approach to enforcing cybersecurity in healthcare. ONC together with OCR, other federal partners, and industry stakeholders should continue to support the National Strategy for Trusted Identities in Cyberspace (NSTIC) program and to draw from existing pilots, where applicable. ONC should support NIST’s effort to update SP 800-63 and to help assure its applicability to and utility for healthcare use cases. ONC should also provide guidance that defines computable, discrete data fields needed for negotiating patient consent and access to health information.
Andrew Wiesenthal and Rich Elmore presented the findings of the Content Standards Workgroup.
They recommended improved consistency in the implementation of Consolidated CDA through further guidance or constraints, extension of standards to promote exchange across the care continuum, including new sources of patient generated health data, device/sensor, environmental and other big data. They also noted that APIs by themselves will not open up clinical systems for learning, an ecosystem, culture, and policy are important enablers.
Liz Johnson and Cris Ross presented the findings of the Implementation, Certification, and Testing Workgroup. Key points included:
*Testing tools need to be available with adequate lead time for pre-certification testing and should be
focused in areas that provide value for end users. Where possible, providers should be involved in
development of test tools.
*CCDA Simplification has occurred between Release 1 and Release 2.
* Practical, effective, and industry-run tools are needed for post-certification testing in support of
interoperability, and evolution of vocabularies, technologies and processes between regulatory
Finally David McCallie and Arien Malec presented the findings of the Architecture, Services, and APIs workgroup. They presented a framework for evaluating technology policy surrounding health information technology. I believe their work is foundational to the future thinking about interoperability and could only be proposed now because of the current technologies available to us such as FHIR-based APIs.
All reports were approved by consensus for transmission to ONC. 10 members of the Standards Committee will leave the group when their terms expire in June. I will leave the Standards Committee when my term expires in January 2016. It will be fascinating to watch the transition. Will the consensus change when the membership changes? In June we will celebrate the amazing contributions of those who have served for their 6 year term limit.