On March 27-28, 2018, Dr. Noam Arzt, President of HLN, participated by invitation in the Stewards of Change National Interoperability Collaborative Symposium on Advancing Information Sharing in California and Beyond on behalf of the Healthcare Information and Management Systems Society (HIMSS). In attendance was a small, but diverse set of stakeholders across the health, human services, education, and criminal justice with an interest in improving data interoperability between systems with these diverse domains, with a special emphasis on efforts in California. Sponsored by the National Interoperability Collaborative (NIC) this symposium represents a continuing expansion of the Stewards of Change focus from human services into the health domain. This expanded conversation will allow public health to participate more fully as the shift to our collective concern about wellness requires a more holistic view of people, their requirements, and their circumstances. We look forward to continuing engagement with this community and an opportunity to bring what we have learned in public health about interoperability into this new forum.
Technical assistance (TA) is provided by expert consultants to public health systems projects in order to improve their performance against functional standards or to help solve recurring or one-time problems or issues. Unlike other forms of training or support, TA is usually focused or tailored to a specific circumstance or situation. Common examples of TA include assistance to a jurisdiction in migrating from one product to another, consultation related to a specific programmatic initiative such as school immunization health compliance, EHR interoperability implementation, or data quality review.
The Office of the National Coordinator for Health Information Technology (ONC) has selected Dr. Noam H. Arzt, President of HLN Consulting (HLN), as a member of the Trusted Exchange Framework Task Force. This group of healthcare and health information technology specialists will advise ONC on various aspects of the Draft Trusted Exchange Framework. This framework outlines a common set of principles for trusted exchange of health information records and minimum terms and conditions for trusted exchange as directed by Congress in the 21st Century Cures Act.
The task force is expected to consider a number of important implementation issues for the framework, including the nature of the coordinating body that ONC envisions for this activity (the Recognized Coordinating Entity, or RCE); the definition, attributes, and functioning of the organizations that will operate within this framework to exchange data (the Qualified Health Information Networks, or QHINs); issues related to privacy and security that must be understood and settled before interoperability can take place; and determination of exactly what activities and uses will be supported by the network.
Dr. Arzt has been a vocal proponent of health data interoperability and health information exchange for many years, with particular emphasis on public health’s needs and activities. Dr. Arzt has written extensively on the challenges and potential solutions to interoperability, including The Interoperability of Things which describes why interoperability in the US seems so hard to achieve. In a recent blog post (HIE: The New Landscape), Dr. Arzt described the state of health information exchange today and the changes that have taken place since Federal funding under the HITECH Act ended. He has also written key articles on important issues in health information technology such as information blocking, the state of patient matching strategy in the US, and cloud computing.
Dr. Arzt recently submitted public comments related to TEFCA on behalf of HLN, and participated in the responses developed and submitted by key organizations including the American Immunization Registry Association (AIRA), American Medical Informatics Associations (AMIA), Healthcare Information and Management Systems Society (HIMSS), and the Joint Public Health Informatics Task Force (JPHIT).
In January 2018 the Office of the National Coordinator for Health Information Technology (ONC) issued a draft Trusted Exchange Framework and Common Agreement (TEFCA), and related supporting documents, in response to a requirement imposed by Congress in the 21st Century Cures Act. The Act says that the TEF may include a common method for authenticating users, a common set of rules, enabling policies, and a process for managing non-compliance. Nowhere does the Act instruct ONC to determine an actual technical architecture in this process, though such a step is not precluded either.
The primary document is in two parts: Part 1 is a set of principles that set the foundation for Part 2 which is a set if minimum terms and conditions for trusted exchange. While the principles seem overall quite reasonable, the terms and conditions have many, many technical specifications and standards embedded within them and lay the groundwork for a very specific nationwide implementation. Though the phrase “network of networks” appears nowhere in these documents, Part 2 seems to describe a technical implementation not too unlike the original NwHIN/eHealth Exchange model that was implemented with limited success a number of years ago. It does not appear that this model fits all that well with any of the major market-based strategies that have emerged in the past several years, notably the Commonwell Health Alliance, Carequality, or the Strategic Health Information Exchange Collaborative (SHIEC).
In September 2017 GAO released a new report, Public Health Information Technology: HHS Has Made Little Progress toward Implementing Enhanced Situational Awareness Network Capabilities. In particular, GAO pointed out lapses in completing Congressionally-mandated requirements for this area including the definition of minimal data elements required and collaboration with state, local, and tribal public health officials on the development of standards and procedures to ensure proper data collection. In addition, the GAO chided HHS for not following its own information technology project management methodology in the planning and execution of this project.
Situational awareness has been a conspicuous topic ever since the 9/11 attacks and the anthrax scare that followed shortly thereafter. But since the initial flurry of public health preparedness funds in the ensuing several years this topic has not had a high priority at CDC nor the funding necessary to implement it successfully. Perhaps this report will serve as a catalyst for the new administration to provide the funding and leadership to fulfill Congress’ intentions in this area.