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Interoperability

Interoperability Roadmap Public Comments

ONC accepted public comments on Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0. The comment period ended on April 3, 2015.

The draft Roadmap proposes critical actions that need to be taken by both private and public stakeholders to advance the nation towards a more connected, interoperable health IT infrastructure and was drafted by ONC based on input from private and public stakeholders. The draft Roadmap outlines the critical actions for different stakeholder groups necessary to help achieve an interoperable health IT ecosystem.

Comments

Kiersten Stewart
Director of Public Policy and Advocacy
Futures Without Violence
Futures Without Violence's comments are attached. We thank the ONC for the opportunity to comment.
Lydia Romero
To whom it may concern, I am against Interoperability Roadmap. I have many issues with EHRs and interoperability, privacy is one of them. Privacy is a person's right and this seems to be taken away with EHR interoperability. It allows nationwide access by innumerable people, which is unacceptable. 1. Proposes to repeal federal law that allows state legislatures to enact true medical privacy laws for citizens. The Roadmap proposes to undo state’s rights under HIPAA to enact state laws and conform all state laws to federal HIPAA “no privacy” rule. (p. 67) 2. Views patient data as public property rather than personal property: “Data holders … should ensure standards are prioritized, developed and implemented to support the public interest, national priorities and the rights of individuals.” (p. 33) 3. Links data without consent for government and research use: “As a learning health system evolves, more than individual/patient-specific information from health records will be matched and linked, including provider identities, system identities, and device identities and others to support public health and clinical research.” (p. 24) The data sharing EHRs are a concern for all involved, practitioners and patients alike. Signed, Lydia Romero
Michael Jackson
General Manager, Consumer Health Care, Health and Life Sciences
Intel Corporation
Attached please find the comments of Intel Corporation.
Ronna Hauser
VP Pharmacy Affairs
NCPA
Wayne Johnson
Senior Project Manager
Retired
I strongly urge you to vote against the proposed implementation of a National Medical Records System, an intrusive, non-secure storage and retrieval system designed to store and track the private medical data of US citizens, citizens who rightfully expect their personal information and effects to be secure from government inspection. I hold a Masters of Science in software engineering, and I guarantee that the database system you intend to build, regardless of your intentions for security, will be compromised. Unlawful access to the private medical information stored in the system will be achieved. There is no such thing as an absolutely secure networked system. Sufficiently motivated individuals, organizations, or governments -- including domestic political operatives -- will gain access to any or all information stored in the system. All of its data is vulnerable to being stolen or manipulated. It’s that simple. Not only is the medical data of millions of individuals not secure, but the federal government has no constitutional right to collect that data in the first place. Citizens have a right to privacy. Whatever medical data can lawfully be collected should be controlled and managed by the states where citizens are better able to hold legislators accountable, and where local values are far more likely to hold sway when it comes to managing the system. As currently written, the National Medical Records System repeals current federal law which upholds states’ rights to enact their own medical privacy laws under HIPAA. Again, we citizens have a right to privacy, especially when it comes to our own private medical information. Increasingly, the federal government and its bloated bureaucracies exercise a paternal view of US citizens, treating us as children instead of adults capable of self-governance. This National Medical Records System is a case in point, treating private patient data as public property to be used for whatever ends the government sees fit. We citizens are promised that this data will be used for the common good, but we citizens have been lied to too many times. Millions of us have lost our healthcare because of misguided federal legislators. We were not permitted to keep our own doctors. We are well aware that our electronically documented doctor-patient conversations, our medical tests and their results, and our current medical expenses are all available to anonymous bureaucrats whose intentions may or may not be harmless. Besides, the intentions of today’s bureaucrats will most certainly be different from the intentions of future bureaucrats. In this new, Orwellian age of American government, it is necessary to remind federal representatives and senators that the purpose of a just government is to protect the individual rights of citizens. We are not a collective society; we are a democratic republic whose representation is being usurped by an increasingly administrative state whose functionaries are neither elected nor accountable to US citizens. The federal government has no business eavesdropping inside my doctor’s office or being at my hospital bedside. You can make all the promises you want about the built-in security to safeguard access and other protocols regarding my private medical data, but you are not being honest. Wayne Johnson
Allen Namath
MD
Palo Alto Medical Foundation
I strongly support the stated goals
Matthew Rafalski
MD
Dasypring Family Health Center
Feel like C1 and C4 are out of sync D2.2 - Unclear - what does this mean? D2.5-8 – Assumes provider have any sway at all with vendors Biggest consumer issue is that more than poor infrastructure and lack of electronic education, we need a culture change in order to even see the importance of electronic access and exchange of information in the public realm.
Continue to Advance Direct Communication when we are able to find other partners to exchange with.
C.Krinkie
I am very opposed to this. It proposes to repeal federal law that allows state legislatures to enact true medical privacy laws for citizens. It views patient data as public property rather than personal property. It has uses of data that many patients will not accept.
Meg Marshall
Director, Health Policy
Cerner Corporation
Please find attached Cerner's comments. We appreciate the opportunity to provide feedback.
Andrea Pitkus, PhD, MLS(ASCP)CM
Product Manager, Laboratory IT
Intelligent Medical Objects
Christopher Carr
Secretary, IHE International Board
Integrating the Healthcare Enterprise
Response by Integrating the Healthcare Enterprise (IHE) to Comment Question: What actions are your organization planning to take and willing to commit to that will support interoperability? IHE’s mission is to improve healthcare by providing specifications, tools and services for interoperability. IHE engages clinicians, health authorities, industry, and users to develop, test, and implement standards-based solutions to vital health information needs. IHE International convenes domain experts from across the spectrum of healthcare and health IT to develop technical specifications and implementation guides (called IHE profiles) that address specific clinical use cases. These are published and made freely available in a set of documents called the IHE Technical Frameworks. This resource is made available for the global health IT community, and IHE profiles have been implemented in numerous health IT products, care sites and regional and national health information exchange projects. ONC and other federal agencies have made use of many profiles in the IHE Technical Frameworks to support interoperability and information exchange projects such as HITSP, Direct, the Nationwide Health Information Network, the Data Access Framework and Structured Data Capture. Many have also been identified in the ONC’s recently published Interoperability Standards Advisory as “best available standards and implementation specifications.” IHE values greatly the contribution of ONC to its work, the recognition of its work by ONC and, most importantly, the use of its standards and implementation guides in projects of ONC and other federal agencies. Some of these profiles were developed with direct input by ONC and other federal agencies (including CDC, CMS, VA and DoD). We invite and welcome continued collaboration with and direct participation by ONC and other federal representatives on IHE committees to perform work that may be needed to support the goals of the Roadmap and related federal initiatives. IHE USA’s mission is to improve our nation’s health care by promoting the adoption and use of standards, tools, and services for interoperability. IHE USA engages all levels of public and private sector participants to test, implement, and use standards-based solutions for all health information needs. IHE USA conducts a regular program of interoperability and conformance testing for health IT products, including the annual IHE Connectathon and IHE USA certification. These testing services focus on the adoption of IHE profiles and related standards-based interoperability features. They expedite the availability of interoperability features in the marketplace and their implementation at care sites and health information exchanges. We would be pleased to work collaboratively with ONC and other federal agencies to leverage these resources to meet the interoperability requirements of the Roadmap and of specific federal health information initiatives. IHE International and IHE USA also conduct programs to educate developers, implementers and users regarding the benefits of health IT interoperability and how to achieve them. This includes regularly publishing education materials, conducting workshops and Webinars, and participating in public demonstrations, including the HIMSS Interoperability Showcase and demonstrations at other healthcare meetings around the World. We would be happy to collaborate with ONC to ensure that messages supporting the goals of the Roadmap are communicated to the broader health and health IT community. Finally, IHE has participated actively as a stakeholder in ONC sponsored activities and committees. Joyce Sensmeier, the President of IHE USA, regularly participates on the ONC FACA HITSC Content Standards Workgroup. Drs. David Mendelson and Elliot Sloane, co-chairs of the IHE International Board and other IHE participants have provided testimony and participated in meetings of ONC committees on behalf of IHE. IHE also regularly participates in the Standards Charter Organization (SCO), which convenes regularly to coordinate the work of standards development organizations. IHE looks forward to continued opportunities to participate as a stakeholder in ONC committees and activities, including those outlined in the Roadmap, and to comment on and contribute to the work of ONC in achieving the goals the Roadmap puts forth.
Rebecca Kush
Attached Comments
Christopher Carr
Director of Informatics
Radiological Society of North America
Response by the Radiological Society of North America (RSNA) to Comment Question: What actions are your organization planning to take and willing to commit to that will support interoperability? The Radiological Society of North America (RSNA®) is an international society of radiologists, medical physicists and other medical professionals with more than 54,000 members from 136 countries across the globe. RSNA hosts the world’s premier radiology forum, drawing approximately 55,000 attendees annually to McCormick Place in Chicago, and publishes two top peer-reviewed journals: Radiology, the highest-impact scientific journal in the field, and RadioGraphics, the only journal dedicated to continuing education in radiology. RSNA oversees a set of informatics-related projects that support the goals of ONC and the Roadmap. We are a sponsor of the IHE initiative and convene the Radiology committees of that organization. We also convene DICOM Working Group 8, which defines standards for structured reporting in radiology. We publish the RadLex terminology and RadLex Playbook, resources to enable more uniform expression of radiology concepts in diagnostic reports and other information. We have developed a set of more than 200 reporting templates, the RadReport template library, that enable consistent and comprehensive structured reporting of specific radiology procedures. Finally, we are the prime contractor on the NIH-funded Image Share Network, a nationwide, patient-focused image exchange network. Through its journals, annual meeting and other offerings, RSNA regularly conducts programs to educate radiologists and other clinicians, as well as developers, implementers and users of imaging systems regarding the benefits of health IT interoperability and how to achieve them. This includes regularly publishing education materials, conducting workshops and Webinars, and presenting public demonstrations at its annual meeting and other healthcare meetings around the World. We would be happy to collaborate with ONC to ensure that messages supporting the goals of the Roadmap are communicated to the broader health and health IT community. RSNA representatives have participated actively in ONC sponsored activities and committees. Drs. David Mendelson and Curtis Langlotz, members of the RSNA Radiology Informatics Committee, have provided testimony and participated in meetings of ONC committees on behalf of IHE. RSNA also regularly participates in the Physicians EHR Coalition (PEHRC), which convenes regularly to coordinate the work of medical organizations to advance the use of health IT. RSNA looks forward to continued opportunities to participate as a stakeholder in ONC committees and activities, including those outlined in the Roadmap, and to comment on and contribute to the work of ONC in achieving the goals the Roadmap puts forth.
Marybeth McCaffrey
Principal
Center for Health Law and Economics
Attached.
Our organization will help identify essential information important for improving care transitions and measuring LTSS quality outcomes.Using the Policy Lab as our Data Warehouse. We will help create a standardized data element sets for communication among all service providers through a set of iterative processes that enables the creation and updating of shared, interoperable data sets, common standards for information exchange, and performance metrics. This will provide the foundation for improved communication among providers and coordination of services across a continuously evolving service system.
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Joel White
Executive Director
Health IT Now
Attached, please find Health IT Now's comments on the Roadmap.

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