In June 2020 the Office of the National Coordinator for Health Information Technology (ONC) released a Pediatric Health Information Technology: Developer Informational Resource. The primary purpose of the guide is to assist electronic health record (EHR) software developers in improving their products to better support pediatric health requirements. The origin of this initiative is the 21st Century Cures Act which is Section 4001 calls on ONC to, “make recommendations for the voluntary certification of health information technology for use by pediatric health providers to support the health care of children.”
As a framework for complying with this regulatory requirement, ONC drew upon the American Academy of Pediatrics’ (AAP) clinical priorities and the AHRQ Children’s EHR Format. This material had previously been circulated for comment as part of the Notice of Proposed Rulemaking (NPRM) to Improve the Interoperability of Health Information (February 2019). ONC collected comments, acknowledged comments from public health explicitly in the Final Rule (March 2020), but released no other substantive information until the publication of this new resource document. For each of ten recommendations, ONC briefly outlines its purpose, identifies the relevant 2015 Edition Certified Electronic Health Record Technology product Certification Criteria, the standards and resources available to assist with implementation, indicates specific references in the AHRQ Children’s EHR Format, and offers other considerations.
There are two ONC recommendations that seem most relevant to public health: First, Recommendation 5, Synchronize Immunization Histories with Registries. We made some comments about this function during the NPRM review process and ONC seems to have considered these when making the final recommendations. This is a core function enabled by Immunization Information Systems (IIS) operated by public health agencies at the state and local level. Generally the recommendations are sound, but there are just a few nuances worth noting:
- The order of the Implementation Resources is not the most helpful. The HL7 v2.5.1 Implementation Guide is the most important document. FHIR-related documents are just not yet very relevant in current or near-future implementation.
- The AIRA Tool Sets referenced in the Other Technical Resources and Tools section reference both the Aggregate Analysis Reporting Tool (AART) and Message Quality Evaluation Tool (MQE), but the link in the resource name only leads the viewer to AART. Either way, neither of these tools are particularly relevant for EHR software developers; they were designed for IIS managers to help evaluate the functionality of their systems.
- In the Other Considerations section, there is a regulatory note that, “The recommendation requires bidirectional interoperability between EHRs and jurisdictions; however, the jurisdictions do not use a single standard for immunization data.” This seems to be an oversimplification of the current state of affairs. While different IIS may present slightly different interoperability requirements for EHRs, the Centers for Disease Control and Prevention (CDC) and the American Immunization Registry Association (AIRA) have been working hard to align these systems more consistently to standards for message content (HL7 v2.5.1) and transport (web services).
Second, Recommendation 9: Track Incomplete Preventative Care Opportunities is focused on altering the clinician when children require services. While immunizations are mentioned in the introduction, there are no specific standards or implementation tools related to immunization forecasting mentioned. In addition, the implementation strategies are completely focused on FHIR-based tools which, as was said above, are not currently beyond the experimentation phase for immunizations (and many other domain areas). This paints too narrow a picture for EHR developers and may cause them to overlook existing implementation strategies for alerts and reminders that use earlier standards and technologies.
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