ONC’s Surprising FACAs
I am often asked what has surprised me most during my tenure as National Coordinator for Health Information Technology. There have been many surprises, but one thing clearly stands out: the extraordinary contributions of our Federal Advisory Committees (FACAs) and their many workgroups.
I have served on, and been advised by, lots of volunteer committees in both the private and public sectors. Some have been helpful, some less so. But nothing prepared me for the magnificent way our Health Information Technology Policy Committee (HITPC) and Health Information Technology Standards Committee (HITSC) have performed, and the role they have played in implementing the HITECH Act. My hat’s off to the wise legislators who created these two statutory bodies under HITECH. And my deep thanks goes to the chairs and co-chairs of the committees, to the dedicated citizens and federal officials who have served on the FACAs and their workgroups over the last two years, as well as to Judy Sparrow, the ONC manager of our Federal Advisory Committees process.
As of the end of March, Judy had organized 368 meetings of the FACAs or their workgroups: the equivalent of a meeting every other day over a two-year period. Assuming three-hour meetings attended by 15 people (and many are longer and bigger), that amounts to more the 16,500 person hours of some of the most talented health information technology (HIT) experts in the country. The sheer volume of this work is extraordinary. But equally impressive have been their specific recommendations. These meetings have directly influenced numerous key policy decisions and regulations by the federal government. For example:
- The basic structure and content of the meaningful use rule: The HITPC and its Meaningful Use Workgroup suggested the five major health goals that provided the organizing framework for meaningful use; many of the specific objectives for meaningful use; and the idea of injecting flexibility into the meaningful use regime by creating a core set of objectives and a menu set from which providers could chose.
- The key standards that the Secretary adopted under the Interim Final Rule – setting forth standards, implementation specifications, and certification criteria for electronic health records (EHRs): The HITSC generated these standards based on previous work performed by the Health IT Standards Panel.
- The structure of the certification process: The HITPC and its Adoption/Certification Workgroup proposed that the certification process be open and competitive, and that we create a streamlined temporary process quickly – to be followed by a more complicated permanent process – so as to get certified records into the market in time for the beginning of meaningful use. The federal government adopted all these recommendations.
Beyond these critical suggestions that have already influenced policy, the committees continue to generate wise, thought-provoking recommendations that ONC will carefully consider in the future. For example:
- The concept that patients should have “meaningful choice” regarding the uses of their personal health information: Bypassing the common controversy over whether patients should be able to “opt-in” or “opt-out” of the electronic exchange of their data, the HITPC and its Privacy and Security Tiger Team focused on the bottom line. Patients should have the information they need to make informed choices over how their data are managed. The Committee also laid out a definition of the term meaningful choice.
- The governance of the Nationwide Health Information Network (NwHIN): The HITPC and its Governance Workgroup recommended that in fulfilling the HITECH requirement to govern the NwHIN, ONC develop conditions of trust and interoperability that any organization must meet to participate in the federally sponsored Nationwide Health Information Network. The decision about whether to meet those conditions, and become a member of NwHIN, would be voluntary. Thus the NwHIN would have to prove its usefulness as a guarantor of the privacy and security of data and of effective interoperability – a very useful market test of the government’s NwHIN service.
ONC’s advisory groups have made and will continue to make many other contributions. All have taken shape in open meetings with opportunities for public comment. Indeed, in some ways, our FACAs have made policy development at ONC wiki-like – a ground up, participatory process in which the federal government has facilitated the work of a vast community of citizen experts.
This experience with the ONC FACAs raises the general question of why some federal advisory committees are more successful than others, but some key factors seem to have played a role. The HITECH legislation and the meaningful use framework gave the committees concrete deliverables and timelines. This made it easier to set priorities and push to consensus on numerous, complex, and potentially divisive issues. A second factor may have been the nature of the HIT community. Its members believe passionately in the value of information to make health and health care better, and they are ready to commit personal time and set aside personal agendas in service of creating a modern, electronic health information system for the United States.
Regardless of the reasons, the ONC FACAs have been a wonderful surprise. We could never have accomplished what we have without them. If HITECH reaches its potential, a lot of the credit will go to the hundreds of dedicated citizens who have contributed thousands of person-hours to make health care better for all Americans through HIT.