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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.


Piper Su
Vice President, Health Policy
The Advisory Board Company
Angela Gorden
Program Manager, EHR Association
Electronic Health Record Association
We are pleased to submit the attached comments on ONC’s Ten Year Interoperability Roadmap on behalf of our nearly 40 member companies which serve the majority of hospitals and ambulatory care settings using electronic health records (EHRs) to provide safer, more effective care to their patients. We applaud the general collaborative approach that the Office of the National Coordinator for Health IT (ONC) suggests to create and maintain this Roadmap.
Becky Lampkins
Associate Research Analyst
Council of State and Territorial Epidemiologists
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Cynthia Morton
Executive Vice President
The National Association for the Support of Long Term Care (NASL) is a trade association representing both vendors of health information technology (IT) with full clinical and point-of-care IT systems and providers of care for the long term and post-acute care (LTPAC) sector. NASL appreciates the opportunity to offer the attached comments on the Shared Nationwide Interoperability Roadmap (DRAFT Version 1.0).
Andrew Schlafly
General Counsel
Association of American Physicians & Surgeons
The Association of American Physicians & Surgeons (“AAPS”), founded in 1943, is a nonprofit membership organization devoted to protecting the practice of private, ethical medicine for the good of patients. Our motto is “omnia pro aegroto,” which means “all for the patient.” We represent members in virtually every specialty and State. We respectfully submit these comments in opposition to the Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0 (“Interoperability Roadmap”). We urge the government to scale back its proposals and not expand into this field. The free market can work amazingly well when allowed to do so. The market for smart phones is a shining example of how much free enterprise and technology can achieve for the public with little or no regulation by government. Likewise, systems for managing medical data are more likely to develop faster and with more efficient results in the absence of government involvement. The free market can better achieve the goals for patients and the medical community. In addition, States have proper jurisdiction over medical care and it would be an intrusion on state sovereignty for the federal government to expand into this area. Our system of federalism has worked well in many areas of life, including medical care. Federal involvement with respect to medical data would be unwise, would increase the risk of privacy violations while impeding progress that can be made at the state and local level. AAPS urges restraint by the federal government. AAPS objects in particular to federal government interference with stronger privacy laws at the state level. The Interoperability Roadmap complains about the “variations in state law and variation in policies that organizations voluntarily adopt, make the environment complex” (p. 129). There should be variations in state law. That is how our system of federalism works best, and the federal government should not be trying to remove those variations. AAPS also has serious concerns about the impact that the Interoperability Roadmap will ultimately have on medical office expenses. By and large, electronic medical records have increased costs significantly, reduced privacy, and led to some devastating medical errors. Perhaps even worse, electronic medical records repeatedly take time away from physicians’ caring directly for patients. Electronic medical records are often riddled with errors, rendering the goal of interoperability one of dubious value, or even harmful. Repetition and reliance on errors is detrimental to patient care. One study found that less than half of electronic medical records were completely accurate. See Drs. Weiss, Kumata, Galar, and Turkish, American Academy of Ophthalmology 2014 Annual Meeting: Abstract PO081. Presented October 19, 2014. If the federal government proceeds with its Interoperability Roadmap, then there should be greater emphasis on transparency with respect to conflicts of interest in the electronic systems and standards. There should also be greater focus on what is best for patients, not intermediaries or hospitals. The patient should come first, both in medical care and in any federal standards relating to medical care. Finally, AAPS supports and incorporates herein the superb comments previously submitted by the Citizens’ Council for Health Freedom. Andrew L. Schlafly General Counsel Association of American Physicians & Surgeons
Gwen Lohse
Managing Director, CAQH CORE
Brian Scarpelli
Director, Government Affairs, Telecommunications Industry Association
Multistakeholder Coalition
Please see attached consensus comments in response to the draft Interoperability Roadmap, on behalf of the following stakeholders: ACT | The App Association American Association for Respiratory Care American Telemedicine Association Baxter Corporation Biocom Christus Health Intel Panasonic Corporation of North America Personal Connected Health Alliance Qualcomm Telecommunications Industry Association Underwriters Laboratories Please contact us if we can be of any further assistance to ONC in this matter. Sincerely, Brian Scarpelli Director, Government Affairs Telecommunications Industry Association (TIA) d: 703.907.7714 | m: 517.507.1446 BScarpelli@tiaonline.org | tiaonline.org
Please see attached
David Booth
Yosemite Project Steering Committee
Yosemite Project for Healthcare Information Interoperability
See attached
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Nick Nudell
Project Manager
National Association of State EMS Officials
Please see attached.
Please see attached.
Chris Hills
Standards and Engagement Team Lead
This is a good first step in moving the Nation to a Nationwide standard. We look forward to working with ONC to get the next version as detailed and specific as possible.
Continue our daily engagement on all items regarding Health IT and developing further specific technical details and guidance for exchanging DoD & VA HealthIT to improve the Health card standards for our Military.
Travis Gathright
Chief Information, Infrastructure, and Compliance Officer
Magee Rehabilitation Hospital
April 3, 2015 Dr. Karen DeSalvo Office of the National Coordinator for Health Information Technology U.S. Department of Health and Human Services 200 Independence Avenue S.W. Suite 729-D Washington, D.C. 20201 Dear Dr. DeSalvo, Please accept this letter on behalf of Magee Rehabilitation Hospital (Magee) in response to your request for public comments to the Office of the National Coordinator (ONC) for Health Information Technology’s publication of the first draft of “Connecting Health and Care for the Nation – A Shared Nationwide Interoperability Roadmap” (Version 1.0). Thank you for the opportunity to comment. Magee looks forward to future versions of this document and appreciates the opportunity to provide feedback. Our hospital is an independent, 96-bed, post-acute nonprofit inpatient rehabilitation facility that provides physical and cognitive rehabilitation services to the Greater Philadelphia community. We employ over 600 staff, and Magee is nationally recognized for outstanding programs in physical and cognitive rehabilitation. Our organization has comprehensive services for spinal cord injury, brain injury, stroke, orthopedic replacement, and amputation. Magee, in conjunction with Thomas Jefferson University Hospital, serves as the federally designated Regional Spinal Cord Injury Center of the Delaware Valley. Only 14 such centers exist in the country. Magee is also a founding member of The Christopher and Dana Reeve Foundation NeuroRecovery Network, which provides state of the art rehabilitation therapy. We commend ONC’s continued dedication to the expansion of, and improvements to, our nation’s health IT ecosystem. Generally, we are in agreement with the actions identified by ONC in order to ensure a majority of individuals and providers across the care continuum are able to utilize common and compatible sets of electronic information. We are also appreciative of ONC’s ambitious goals and timelines. That being said, we would like to offer a few suggested changes to the report, emanating from challenges and experiences we have had in our attempts, as an independently owned, post-acute rehabilitation facility, to participate in an increasingly interoperable health IT ecosystem. Firstly, on page 21 of the report, under the section “Who is this Roadmap For?,” the report includes a breakdown of stakeholders in order to denote “which stakeholder groups are best positioned to take on critical action.” Under “people and organizations that deliver care and services” subsection, we believe that post-acute facilities should be listed. Post-acute inpatient rehabilitation facilities, such as Magee, are not currently eligible to participate in the Electronic Health Records (HER) meaningful use program; nonetheless, we remain key stakeholders in the continuum of healthcare and national attempts to improve health IT interoperability. We understand that this report is unable to focus on technology adoption. However, its broader goals will only be met if segments of the health care industry that have been presently excluded by policymakers from government financed EHR incentive programs are explicitly recognized as important participants in EHR expansion and interoperability. Secondly, on page 39 for the report under the section titled “Supportive Business, Clinical, Cultural and Regulatory Environments,” ONC also correctly identifies the need for a shift towards “value-based and person-centered health systems” that reward positive patient health outcomes. Magee, as a post-acute facility, strongly favors interoperable systems that span the entire continuum of healthcare so that we can easily and effectively communicate with acute care facilities and primary care physicians to improve care and reduce costs. Achieving this goal is another area where expansion of EHR incentives would have great benefit. In the present environment, post-acute health organizations are not required or encouraged to adopt certified EHR systems and therefore fall outside the regulatory oversight and guidance created to produce a truly interoperable ecosystem. We believe that financial ability of all providers to acquire the necessary technology is essential in discussions of the “Support Business, Clinical, Cultural and Regulatory Environments” section and that including post-acute facilities will strengthen the goal to achieve interoperability. In addition, we believe there remains a significant risk of creating marked inefficiencies if post-acute providers are not included in early stages of discussions related to mapping the road ahead for interoperability. Since post-acute will, necessarily, be part of interoperability, better planning will be achieved if post-acute perspectives are brought into the discussions at early stages so that post-acute EHR needs can be identified, planned for and anticipated. Overall, Magee Rehabilitation is very appreciative of the work being done by ONC to improve interoperability. Magee also encourages ONC to broaden its discussion in this report to highlight post-acute organizations and their inability to benefit from government incentives to adopt EHR systems. The exclusion of post-acute facilities from EHR incentive programs will have serious long-term repercussions in achieving the goal of an interoperable health IT ecosystem. We thank ONC for its extensive interoperability roadmap and its ambitious goals. We also thank ONC for the opportunity afforded to us to comment on the report. Should you have any questions or require further clarifications, please do not hesitate to contact Magee Rehabilitation’s Chief Information and Infrastructure Officer and Corporate Compliance Officer, Travis Gathright by email at TGathright@mageerehab.org or by phone at 215-587-3463. Respectfully Submitted, Travis Gathright, MHA
Linda VanHorn
President / CEo
iShare Medical
Kristin Majeska
Senior Director
Center for Healthcare Transparency
Lindsey Hoggle
Director, Nutrition Informatics
Academy of Nutrition and Dietetics
Please see attached comments.
The Academy of Nutrition and Dietetics continues to create, test and use health information technology standards, terminologies and best practices. We are aligning the Interoperability Roadmap across areas of care: quality management, nutrition services coverage and nutriton care processes.
Shelley Rusincovitch
Project Leader in Applied Informatics
Duke Translational Medicine Institute