About the Draft Federal FHIR® Action Plan

Comment

OCHIN Comments Draft Federal FHIR Action Plan

Please see OCHIN's comments attached.

This Plan contains a list of…

This Plan contains a list of FHIR specifications with traction and a list of "early-stage" capabilities. It can provide ground for consensus prioritization: given a new requirement, the design solutions listed here are to be preferred to those not listed here. This is a useful approach, but it would be helpful if these decisions were annotated with reasons for selecting one solution over others. In many cases there is only one, so no rationale is necessary, but the Plan is of less value in these cases. In others, diverse designs exist, so it would be good to know why, e.g., CDex is not included.

The phrase "When these specifications reach a degree of common implementation such that they become the de facto standard" suggests a relatively passive role for the government. For capabilities for which the value can be realized by private concerns without adverse effects on citizens, this passivity makes sense. 

But that there are capabilities that the government is in a unique position to foster, including

              Support for sharing of profiles and terminologies in the US Realm

              Advancing FAST capabilities for finding information (patient data, endpoints)

              Facilitating leverage of other standards (V2, NCPDP, CDA, X12) data in FHIR ecosystem

              Demonstrating operational data quality monitoring

TEFCA and VSAC are good examples of programs that foster a common infrastructure and encourage mutual intelligibility by making it easier to do things right than to do them locally.

In addition, it might be useful to identify cross-agency interactions that can be used for socializing design decisions. 

I’d like to see a plan that specifies activities to promote design consensus, whether via advocacy, policy, or incentive.

Comments About the Draft Federal FHIR Action Plan

In response to the Federal Health IT FHIR Roadmap Action Plan request, we are pleased to submit our collective feedback as a collaboration among CDISC, Catalysis Research, and Piosoft. The full overview of the feedback is attached. The comments are further applied on the specific page. 

We applaud the efforts to leverage and harmonize the standards to benefit health and human services. The Action Plan states the FHIR standard will be essential, and we agree this is a good start. However, leveraging other available and applicable standards, particularly in the case of terminology, will move us all forward faster and perhaps better. Specifically, in the case of research standards, benefits and efficiencies have been proven over the past 25 years in a global research community, including NIH centers and FDA. These terminologies to support core data elements and data elements for over 50 therapeutic areas are mature and are maintained by NCI Enterprise Vocabulary Services. It is inefficient and will not enable interoperability to allow users a choice of terminologies.   To truly reach the goal in a reasonable timeframe, it will be important to leverage this past consensus-based work that is relevant to billions of patients worldwide. Otherwise, it could very well take another 20 years to redo work that has already been done.

Thank you for the opportunity to comment.

  • Catalysis (Rebecca D. Kush, PhD)
  • CDISC (Rebecca Baker, MS, MHA, BSN, RN)
  • Piosoft (Filippo Napoli, PMP)

CDISC_Catalysis Research_Piosoft_RE - About the Draft Federal FHIR Action Plan_FINAL_2024-11-18.pdf

On Behalf of the Vulcan Accelerator - Comments & Recommendations

This comment is done on behalf of the Vulcan Accelerator, which has prepared a detailed document, attached for your review. Below is a summary of the key recommendations for the Draft Federal FHIR® Action Plan:  

  • Increased emphasis on existing and future Clinical Research FHIR IGs with cross-interoperability applications
  • Broadening use cases for digital health and clinical research
  • Aligning OMOP and EHR data models for seamless integration
  • Extending mCODE applications to oncology and other disease areas
  • Expanding support for Real-World Evidence (RWE) generation
  • Create FHIR®-ready, analysis-ready datasets to enhance efficiency in generating insights and decisive actions
  • Enabling additional standards and terminologies for pre-market submissions to the U.S. FDA
  • Leveraging FHIR® to enhance efficiency and simplify data exchange for research purposes, ultimately driving a positive impact on patients' lives

The Vulcan Accelerator would like to thank the ASTP for the opportunity to provide comments. Additional details regarding the Vulcan Accelerator can be found here https://www.hl7vulcan.org/

Vulcan Accelerator Comments on Draft 2024 Federal FHIR Action Plan_0.pdf

Identifying Information Silos

It states “The FHIR standard’s coordinated use across government will help break down the silos separating patients, providers, payers, public health, and research.”  Are these silos/barriers noted anywhere?  I believe understanding the perceived barriers is necessary to comment on the plan.  It appears to be pretty high-level and leaves a lot of room for interpretation.

Medication Information Management

Medication information management requires standards, avenues for exchanging, documenting, storing med and allergy info before, during and after car with patients, caregivers and their healthcare teams for successful ad safe medication care.