ISA Structure

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Comment

Greater Emphasis on Testing Tools

HIMSS encourages ONC to determine how best to incorporate information on the testing of standards into ISA.  When the community looks at any standard, no matter how well the standard is written, it is the actual implementation of that standard where there is interpretation variability.  Overall, the community spends a significant amount of time talking about standards and implementation guides, but if those standards and guides are not tested once embedded into products and systems, there are questions about whether stakeholders are making the progress needed to propel broader interoperability efforts forward.       HIMSS would like ISA to include more quantitative data to support the assessment of standards adoption/maturity.  For example, one helpful approach would be to include more information about testing, test tools, testing events, as well as how and where particular standards can be tested and advanced.  We encourage ONC to work with Integrating the Healthcare Enterprise (IHE) and Health Level Seven International (HL7) to investigate whether the upcoming connectathon events that each organization sponsors would be the appropriate setting to provide additional quantitative data in support of this effort.  HIMSS would be interested in working with ONC to ascertain whether this idea is best suited for more references within ISA or to build out more robust testing standards as part of the Interoperability Proving Ground.    It is also important to note ONC’s reference to testing in the preamble to ISA, and how the agency encourages further pilot testing and industry experience to be sought with respect to standards and implementation specifications identified as “emerging” in ISA.  HIMSS would like to be helpful resource to ONC on this type of project.