On April 17, 2019 the Office of the National Coordinator for Health Information Technology (ONC) released the second draft of its Trusted Exchange Framework and Common Agreement (TEFCA) for comment. The initial version was released more than a year ago in January 2018 (see my original blog). As before, this is in response to a requirement imposed by Congress in the 21st Century Cures Act. After a somewhat lengthy (but well written) introduction, the document contains three parts (compared to just two parts the first time around):
|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.
On January 11, 2019 the Agency for Healthcare Research and Quality (AHRQ) released a draft Addendum to the Third Edition of Registries for Evaluating Patient Outcomes: A User’s Guide called Tool and Technologies for Registry Interoperability. AHRQ has long written about registries – largely from a research standpoint – and I have been following this from afar for some time. This new guide is focused on helping those who both create and use registries understand the issue surrounding leveraging external data to improve registry completeness, accuracy, and usefulness.
This report covers lots of ground and does a good job of summarizing important subtopics. Each chapter is overflowing with footnotes and sources. In Chapter 1, AHRQ reviews the context for registries today within the notion of a learning health system, and then quickly jumps into a useful discussion of interoperability barriers and problems. Many research-oriented registries are narrowly focused on a specific issue or problem; AHRQ envisions a more interoperable set of registries that can create a more integrated “national research infrastructure.”
In early January the Office of the National Coordinator for Health Information Technology (ONC) issued its annual report to Congress for 2018 on the adoption of electronic health records (EHR) and interoperability. This report is required under the HITECH Act and is further informed by requirements of the later 21st Century Cures Act.
There was actually very little to comment about in this report, and it felt more like ONC was “going through the motions.” There were a few (actually, very few) updated statistics about technology use, a short discussion about the importance of open Application Programming Interfaces (APIs), and a useful but not terribly new list of initiatives and reports issued by ONC over the past year or two. I spotted one or two things in there that I had not recalled seeing before but nothing terribly important.
One thing that I think is notable was a short discussion about barriers to interoperability that we have heard before. The report identifies three types: technical barriers, financial barriers, and trust barriers. Within trust barriers the report mentions legal incentives to keep data from moving (I guess that would have better been phrased as legal disincentives to sharing), but this misses the point: It is the patchwork of inconsistent and incompatible State and local laws and regulations – not intentional information blocking – that presents a bigger challenge and barrier. These can be laws prohibiting movement of certain health data across state lines, incompatible consent requirements, or restrictions on “downstream” use of data that is shared. Until these legal barriers are addressed separate from trust issues interoperability will be hampered.
On November 28, 2018 the Office of the National Coordinator for Health Information Technology (ONC) released a draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs for public comment. The strategy aims to reduce the time and effort and improve the functionality of electronic health records (EHRs) for clinicians, hospitals, and other healthcare organizations.
This strategy was developed primarily through the efforts of ONC-convened workgroups in response to requirements laid out by Congress in the 21st Century Cures Act (Section 13103). The report itself does not identify who exactly served on these workgroups and what organizations were represented.