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ONC EHR Reporting Program RFI: A Public Health Perspective

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ONC EHR Reporting Program RFI: A Public Health Perspective

On August 24, 2018, the Office of the National Coordinator for Health Information Technology (ONC) released a Request for Information (RFI) related to the EHR Reporting Program. Th ...

On August 24, 2018, the Office of the National Coordinator for Health Information Technology (ONC) released a Request for Information (RFI) related to the EHR Reporting Program. This RFI is required by the 21st Century Cures Act and its primary purpose is to gather ideas and suggestions related to how ONC might provide better information about Certified EHR Technology (CEHRT).

Apparently, the initial intention was to create a “star rating” like the type used in Consumer Reports to use to rate EHRs, but that seems to have been abandoned in favor of some kind of measurement system. But it is far from clear exactly how this would be done. There may be something to learn from the Immunization Information System (IIS) community: with guidance from the CDC, the American Immunization Registry Association (AIRA) initiated a process to help assess compliance of IIS with national functional standards through a formal measurement and improvement initiative. “Validation,” rather than “certification” or “compliance,” is the carefully-chosen term to signify a system meeting the designated measures through formal testing. The process is interactive, and the results are only made public with the agreement of the IIS program. Perhaps some of the concepts and processes in this initiative can be useful for the EHR Reporting Program.

Frankly, there is not much of interest in here for public health, which is not in the business of worrying about CEHRT. Of course, the quality and functionality of EHR products does impact their effectiveness in supporting interoperability with public health registries. To that end, the RFI does as some questions towards the end (p. 42918) about additional information that might be useful for prospective purchasers of CEHRT, including “Submitting, editing, and retrieving data from registries, such as clinician-led clinical data registries.”

ONC asks for how they might prioritize including information related to this in EHR Reporting as well as data sources for reporting about this. It may be useful for public health to weigh in on these questions; comments are due no later than 5 p.m. on October 17, 2018 at the Federal eRulemaking Portal.

CMS MIPS PI NPRM: A Public Health Perspective

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CMS MIPS PI NPRM: A Public Health Perspective

See my HIMSS blog and our formal comments on this NPRM! Well, here we go again. The Centers for Medicare and Medicaid Services (CMS) has now released a new Notice o ...

See my HIMSS blog and our formal comments on this NPRM!

Well, here we go again.

The Centers for Medicare and Medicaid Services (CMS) has now released a new Notice of Proposed Rulemaking (NPRM), titled Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability ProgramThe purpose of this NPRM is to address proposed changes for Year 3 of MIPS, the provider (as opposed to hospital) side of the Quality Payment Program. The part that is most relevant to public health is the Medicaid Promoting Interoperability (PI) Program for Eligible Professionals (EP)” (the EHR Incentive Programs have been renamed). A major goal of this NPRM is to synchronize as much as possible the EP program with the hospital-based program that was addressed in a previous NPRM  just a few months ago.

HLN Presenting at Upcoming Healthcare Meetings

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HLN Presenting at Upcoming Healthcare Meetings

Over the next several months HLN will be attending a number of important healthcare and public health meetings and events and presenting our work and perspectives. Events and prese ...

Over the next several months HLN will be attending a number of important healthcare and public health meetings and events and presenting our work and perspectives. Events and presentations include:

2018 OSEHRA Open Source Summit (July 18-20): HLN will be joining colleagues on the Immunization Working Group for an update of the groups activities, including an update about HLN’s ICE Open Source Immunization Evaluation and Forecasting System (7/18, Afternoon Session II, 2:30pm ET).


American Immunization Registry Association (AIRA) 2018 National Meeting (August 14-16): As a gold sponsor of the meeting, HLN shows its strong commitment to the Immunization Information System (IIS) community. We will deliver several presentations during this conference, including:

  • Strategies for Evaluating and Integrating SmartyStreets (Session 1B, 8/14, 1pm MT)
  • IIS Platform or Module Migration – Is Your Program Prepared? [with CDC, AIRA & PHII] (Session 2B, 8/14, 2:30pm MT)
  • CAIR2 Patient Matching: Solving the 25 Million Piece Puzzle [with CA and DXC] Session 3A, 8/15, 9:15am MT)
  • IIS Past, Present, and Future: A Conversation and a Discussion [with PHII] (Session 4E, 8/15, 11am MT)
  • Comparative Analysis of AFIX-IIS Tools [with CA] (Session 5D, 8/15, 1pm MT)
  • Cloud-Based Solutions: A Good Option for Hosting CDS for Immunizations (Session 5D, 8/15, 1pm MT)
  • Vaccines For Children (VFC)-IIS Integration Strategy [with CA] (Session 6E, 8/15, 2pm MT)
  • ICE: An Open Source Option for Immunization Forecasting (Session 7D, 8/16, 11am MT)
  • Hearing from Everyone: Diverse Perspectives to Improve Oregon School Immunization Reporting [with OR] (Session 8C, 8/16, 9:45am MT)

HLN will also have an exhibitor booth at the meeting.


2018 Public Health Informatics (PHI) Conference (August 19-23): HLN will have an even greater presence at this bi-annual CDC-sponsored conference including delivery of the following presentations:

  • Case Study for Cloud Computing Solutions in Public Health: Clinical Decision Support (Session E03, 8/21, 4:15pm ET)
  • Reportable Conditions Knowledge Management System (RCKMS): Developing Quality Decision Support in the Data Supply Chain for Public Health Surveillance [with CSTE] Session B01, 8/21, 10:30am ET)
  • A Collaborative Approach to Supporting Information System Migration Projects [with CDC, AIRA, & PHII] (Session G01, 8/22, 1:30pm ET)
  • Clinical Decision Support for Immunizations as a Community-drive, Standards-based Activity [with CDC & NYC] (Session H04, 8/22, 3pm ET)
  • Developing a Data Integration and Management System: Improving New York City’s Population Health Research and Surveillance [with NYC] (Session H07, 8/22, 3pm ET)
  • The Changing Face of Interoperability and its Impact on Public Health (Session K11, 8/23, 9:15am ET)

In addition to being an exhibitor at the conference, HLN will demonstrate some of its Open Source software as part of a HIMSS Interoperability Showcase that accompanies this event:

  • Immunization Use Case – ICE Immunization Evaluation and Forecasting System
  • Electronic Case Reporting Use Case – Reportable Conditions Knowledge Management System (RCKMS)


Health Level 7 (HL7) 32nd Annual Plenary and Working Group Meeting (9/29-10/5): HLN will attend this important gathering, including demonstrating our Open Source products at the FHIR Connectathon that takes place in conjunction with the meeting.

HLN releases Version 1.13.1 of its Award Winning Open Source Immunization Forecaster

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HLN releases Version 1.13.1 of its Award Winning Open Source Immunization Forecaster

A new release (v 1.13.1) of the Immunization Calculation Engine (ICE) is now available (download ICE version 1.13.1). ICE is a state-of-the-art open-source software system that pro ...

A new release (v 1.13.1) of the Immunization Calculation Engine (ICE) is now available (download ICE version 1.13.1). ICE is a state-of-the-art open-source software system that provides clinical decision support (CDS) for immunizations for use in Immunization Information Systems (IIS), Electronic Health Record (EHR) and Personal Health Record (PHR) Systems.

The release includes support Earliest Date and Overdue Date for additional vaccines: Pneumococcal and Hib. If enabled, ICE will output two additional forecast dates along with the Recommendation Date: the Earliest Date and Overdue Date. The Earliest Date is the soonest date that the vaccine can be given and still be considered valid. The Overdue Date is the date after which an immunization administered would be considered late. With this release, ICE returns the earliest and overdue dates for nine vaccine groups, and the remaining three vaccine groups will be completely supported in a future release of ICE this summer.

In addition, this release includes an adjustment to the Pneumococcal catch-up schedule (see Exception 1B in the Pneumococcal Vaccine Group documentation for details). All changes are documented in the release notes. There were no changes to the ICE Implementation Guide (v2r20) which describes how implementers should update their installation and software to properly read the Earliest, Recommended, and Overdue dates.

Feel free to e-mail us at ice@hln.com if you have any questions.

HLN Submits Comments to CMS on IPPS NPRM

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HLN Submits Comments to CMS on IPPS NPRM

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemakin ...

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program based on our earlier comments:


HLN Consulting, LLC is pleased to submit the following comments on the recently-released CMS IPPS NPRM, CMS–1694–P. HLN is a leading public health informatics consulting company. With that in mind, we read documents like the NPRM through a public health lens, and confine our comments to that important context.