Release of the Federal Health IT Strategic Plan 2011 – 2015
Jodi G. Daniel, J.D., M.P.H. and Seth Pazinski | September 12, 2011
Today, the Office of the National Coordinator for Health Information Technology (ONC) published the Federal Health IT Strategic Plan 2011 – 2015 (the Plan). The Plan, and our strategy, benefited from the valuable input we received on the draft Plan that was out for public comment from March 25 – May 6, 2011. The 240 responses to our blog post requesting public feedback on the draft helped us to refine and solidify the final Plan.
This by no means marks the end of our strategic planning. The Plan is meant to be a living document that will be updated based on experience with stage one of the meaningful use electronic health record (EHR) incentive programs and the results of our evaluation program. We will continue to track national progress toward achieving the goals laid out in this Plan, particularly the high-priority goal for providers to adopt and become meaningful users of certified EHR technology. Based on this new knowledge, we’ll begin another open process to revisit and update our strategy and this Plan. As always, our planning efforts will be done in coordination with our Federal partners and with insights from private stakeholders and the general public.
We’d like to thank everyone who provided feedback on the draft Plan. Below are highlights of the themes that emerged from the comments and some ways in which feedback has been incorporated into the Plan itself.
Privacy Comments, Particularly Around Consent Management
The privacy and security of identifiable health information should be protected wherever it is electronically transmitted, maintained, or received. While the HIPAA Privacy and Security Rules are key safeguards, they are not the only means available for affording this protection.
HHS has commenced the process of exploring broader privacy and security policies that may be necessary to ensure trust in electronic health information exchange. This process is being guided by the Nationwide Privacy and Security Framework for Electronic Exchange of Individually Identifiable Health Information, a set of privacy and security principles grounded in the fair information practices released in 2008. HHS has commissioned a principal-level, inter-division workgroup to develop an updated approach to privacy and security policies. The efforts of this workgroup are informed by the recommendations of ONC’s federal advisory committees – the HIT Policy Committee and HIT Standards Committee – on privacy and security issues. Broader Federal participation in developing privacy and security policies is obtained through the Federal Health IT Taskforce. One of the major areas being addressed through this process is pursuing policy changes that would afford individuals more meaningful choice as to whether their information may be exchanged electronically. ONC is also assessing technical solutions that could support more granular patient choice and data segmentation that could support a patient’s choice to share only certain parts of their record during information exchange.
Comments about the Pace of Change and Timing for Stage 2 Meaningful Use
We fully acknowledge the Plan is ambitious, but wholeheartedly believe that meaningful use of certified EHR technology provides the electronic infrastructure that is essential to support implementation of key delivery system transformations, like Accountable Care Organizations and Patient-Centered Medical Homes, and the priorities in the National Quality Strategy.
As was mentioned at the July 6, 2011 HIT Policy Committee meeting, we appreciate the dedicated members of the HIT Policy Committee who gathered expert testimony and considerable stakeholder input from both providers and vendors, and put in long hours reviewing and analyzing the pros, cons, and consequences of changing the timing for the start of stage 2 of the Medicare and Medicaid EHR Incentive Programs. In the end, the HIT Policy Committee recommended Stage 1 be extended by a year just for those attesting in 2011 in order to incentivize early adoption and meaning use of EHRs. This approach would allow extra time to help providers and vendors develop more comprehensive EHR functionality, avoid disincentivizing early adoption, and it would mean that all providers first attesting to meaningful use in 2011 or 2012 would have until 2014 to move up the escalator to stage 2. Moreover, at this meeting, we expressed support for this recommendation and indicated that we have passed this along to our colleagues at the Centers for Medicare & Medicaid Services (CMS) to consider as they develop the notice of proposed rulemaking for meaningful use Stage 2.
Comments about the Usability of EHR Products
Improved usability of EHR products is an important goal that can lead to increased adoption and effective use of EHRs to deliver safer and better quality care. In order to improve the usability of EHRs, we will support National Institute of Standards and Technology (NIST) and research to refine EHR usability testing and use protocols targeted at improving safety and efficiency. This work will occur in a transparent process, engaging EHR developers, researchers, and other stakeholders. We will also work on greater transparency and better guidance for EHR users and purchasers with regard to EHR usability.
ONC intends to explore ways to improve the ability of providers to change EHR products to better support their needs by improving data portability. Reducing the cost associated with switching EHR products while increasing data fluidity and choice can help drive market competition to improve the usability of EHR products.
Request for More Information on Outreach and Education to Providers and Consumers
In order to achieve the highest participation possible in the Medicare and Medicaid EHR Incentive Programs, ONC and CMS are working together on a coordinated outreach and education campaign directed at providers and hospitals. Our approach is two-pronged and involves distributing critical information and materials nationally, while focusing on local communities to engage audiences where they live and work. We’ve already started collaborating with stakeholders and the media to distribute materials and established a strong online presence through social media.
In addition, ONC and the Office for Civil Rights are gearing up to launch a national campaign this month, designed to increase consumers’ awareness about:
- The transition to health IT;
- How to access their health information;
- The benefits of leveraging health IT tools to better manage their health; and
- Privacy rights to access and protect their health information.
The campaign slogan, Putting the I in Health ITSM, provides a platform for patients and providers to share their personal stories using health IT to improve care. As part of the campaign, ONC launched a new website for patients and providers, HealthIT.gov. An integral part of the campaign is a continuous feedback loop where we will learn from experience and make necessary adjustments along the way. Some campaign materials will be available in multiple languages.
The themes highlighted above are only a subset of the comments we received, which, like the Plan, cover a wide range of topics. Some additional areas that we heard a lot of feedback on, and led to revisions in the Plan, include:
- Barriers to adoption and health information exchange
- Support for further harmonization of standards
- Support for the inclusion of providers not eligible for incentive payments under the Medicare and Medicaid EHR Incentive Programs in information exchange for purposes of care coordination
- Need to address accessibility
- Concern that the private sector was not engaged in learning about efforts of the health care system
Thank you again for your insights. We appreciate your support and candor, and we welcome your challenge to create a Plan that will achieve the ambitious goal of modernizing the health care system and ushering in a new era of electronic health information. The revised Plan is available on our website at: http://healthit.hhs.gov/strategicplan.