ONC – HLN Consulting, LLC

ONC Releases New NPRM on Interoperability: How Might it Affect Public Health? [Updated]

by Noam Arzton February 27, 2019

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 8) which will be updated periodically.

AHRQ Releases Draft Guide for Registry Interoperability: Does Public Health Have a Role?

by Noam Arzton January 29, 2019

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.”

ONC Releases 2018 HITECH Report

by Noam Arzton January 16, 2019

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.

A Public Health Perspective ONC’s Strategy to Reduce Burden on Physicians

by Noam Arzton December 19, 2018

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.

ONC EHR Reporting Program RFI: A Public Health Perspective

by Noam Arzton September 12, 2018

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.