|See our final comments on the ONC NPRM and the CMS NPRM Patient Matching RFI|
On February 11, 2019 the Office of the National Coordinator for Health Information Technology (ONC) released its latest Notice of Proposed Rulemaking (NPRM) to Improve the Interoperability of Health Information. Referred to by some people as the “Information Blocking NPRM,” since this was the primary topic anticipated, the document actually covers a host of other topics related to interoperability driven primarily by requirements of the 21st Century Cures Act. Besides the initial text of the NPRM, ONC also released a set of summary slides and fact sheets to help explain the document.
Given the relatively minimal mention of core public health reporting certification criteria in this NPRM, there is still a fairly large potential impact on public health. Topics, descriptions, issues, impacts, and potential opportunities discussed in this article and associated documents are based on our careful read of the NPRM and related material. But please note that this information is voluminous and at times confusing. Ongoing discussion and review will attempt to clarify (and if necessary correct) initial ideas presented here.
In order to help focus the reader, I have prepared a detailed table of Public Health Issues, Impacts, and Opportunities (currently at Version 15) which will be updated periodically, as well as a separate detailed response to the ONC Patient Matching RFI and CMS Patient Matching RFI.