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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.


Ijeoma Adele
Healthcare Consultant
pg 12 - No. 1 - Governance link doesn't work pg 14 - A high level overview of HIPAA in relation to interoperability might be beneficial to enhance understanding and stakeholder engagement The link to the document 'Privacy and Security Protections for Health Information' doesn't work pg 22 - fig 5 - Educational Institutions and Medical/Healthcare Professional Associations should also be engaged as Stakeholders to ensure that newly qualified professionals are coming into the healthcare system with an understanding that this is the normal way of working & the Professional Associations to champion it pg 24- I - I believe currently that vendors are still developing non certified EHR technology, is the assumption that CEHRT systems are the current baseline for interoperability? If so, communication to providers is required to ensure they are aware of this to prevent/reduce barriers to the realization of nationwide interoperability. General - there is mention of Shared profits for payers and providers and at the same time, lower healthcare costs as a benefit to patients. This means there is a reduction in profits which may be viewed negatively. I suggest that it should be made clear that the benefits, be it intangible would outweigh the costs. General - I would suggest outlining the benefits of this for each stakeholder as a supporting document to the incentives General - Comprehensive and interesting document which takes into account a lot of the issues, provides majority of the answers and identifies the challenges and gaps to achieving this huge but required interoperability especially in the face of ever changing and cutting edge technology. This means that the ONC and partners need to be agile to achieve this but also sensitive in approach to the cultural barriers of professionals who may never adopt such technology.
My professional experience includes several years leading the deployment assurance function in a national programme with similar challenges to the Strategic Plan 2015-2020. I was responsible for ensuring that appropriate systems and technology are implemented and used to support patient care and improve service delivery in a wide range of healthcare organizations. I am willing to participate in: Documentation review and feedback Development of relevant documents as required Locally champion ONC Strategic plans relevant to my areas of interest which includes Data/Information sharing and the mechanisms to achieve this as well as the ability to assure it is successfully implemented and SMART measurements to support it.
Thomas Sparkman
Vice President, Government Relations
See Attachment
Tim McMullen
Executive Director
Healthcare Administrative Technology Association (HATA) - The National Practice Management System Association
Peter N. Kaufman, MD
Chief Medical Officer
DrFirst, Inc
Michael (Mick) Talley
Director & Treasurer, Co-Project Manager
Southeast Michigan Health Information Exchange, (SEMHIE)
The Roadmap approach to Governance, Architecture and Infrastructure and security & privacy are very good and shall require work, collaboration, and testing and validation before deployment to be useful. SEMHIE agrees that solutions should be vendor neutral and the architecture should allow for the process of multiple solutions as healthcare is a rather diverse and fragmented industry.
While developing a set of customers for sustainability, SEMHIE is an anchor participant of "Healtheway, Inc", and supports the interoperability pilots and work of "Healtheway". SEMHIE also supports the work of the "Michigan Health Information Network", (MiHIN) and is participating in the Federated Hub Pilot and many of the Work Groups for Security & Privacy/Governance.
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Patrick Johnson
Assistant Director, Dept. of Federal Affairs
American Academy of Pediatrics
Please accept the attached comments on the "Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0" on behalf of the American Academy of Pediatrics. If you have any questions or need additional information, please do not hesitate to contact me. Thank you. Sincerely, Pat Johnson Assistant Director, Dept. of Federal Affairs American Academy of Pediatrics (202) 347-8600 pjohnson@aap.org
Teresa Lee
Executive Director
Alliance for Home Health Quality and Innovation
April 3, 2015 Dr. Karen DeSalvo National Coordinator for Health Information Technologyp Office of the National Coordinator for Health Information Technology Hubert H. Humphrey Building 200 Independence Avenue SW Washington, DC 20201 RE: ONC Shared Nationwide Interoperability Roadmap Draft 1.0 Dear Dr. DeSalvo: I am writing on behalf of the Alliance for Home Health Quality and Innovation (the “Alliance”) with regard to the request for public comment on the Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0. The Alliance appreciates the opportunity to provide comments on the proposed interoperability roadmap. About the Alliance for Home Health Quality and Innovation The Alliance is a non-profit 501(c)(3) organization with the mission to lead and support research and education on the value of home health care to patients and the U.S. health care system. Working with researchers, key experts and thought leaders, and providers across the spectrum of care, we strive to foster solutions that will improve health care in America. We are also a membership based organization comprised of not-for-profit and proprietary home health care providers and other organizations dedicated to improving patient care and the nation’s healthcare system. For more information about our organization, please visit: http://ahhqi.org/. The Alliance supports the direction of, and sentiment behind, the roadmap, and commends the Office of the National Coordinator for Health IT’s (ONC’s) efforts in focusing attention on the need for national interoperability in health information technology. With the roadmap, ONC is demonstrating an interest in moving forward the discussion of interoperability as a central component of a more efficient and cost-effective health care delivery system. As noted previously, the idea of a shared Nationwide Interoperability Roadmap is critical to providing high quality care to patients regardless of where they are treated in the continuum. Additionally, the Alliance appreciates the mention of home health care and long-term and post-acute care (LTPAC) in the specific discussion of future care delivery and the move to community-based models of care delivery. The Alliance supports the work being done in the context of the S&I Framework’s electronic Long-Term Services and Support (eLTSS) initiative, and looks forward to engaging with the initiative. The eLTSS initiative will be useful in developing significant use cases for community-based care and possible standardized data elements. Finally, the Alliance supports the expanded discussion of the Health Insurance Portability and Accountability Act (HIPAA) as it relates to what data can be exchanged, how, and by whom. Such clarification, as referenced within the Executive Summary of the proposed roadmap, will allow for more efficient and safe transfer of health information. Although the Alliance supports the overall direction of the roadmap, the following are key considerations for ONC moving forward: (I) need for greater clarity on the roles of stakeholders; (II) expanded discussion of standards; (III) consideration of further incentives for adoption of interoperable systems; and (IV) inclusion of priority use cases that involve LTPAC. I. In order to better achieve interoperability across all care settings, further clarity is needed on the roles of various stakeholders Setting a national roadmap is a crucial first step in creating a truly interoperable learning health care system. As such, the Alliance applauds ONC’s efforts to set the course for the future. However, further clarity is still needed on the roles of individual stakeholders in advancing interoperability. Within the currently proposed roadmap, the roles of stakeholders are not clearly defined in the evolving learning health care system. Given that ONC refers to stakeholders as the true owners of the roadmap, it is crucial to flesh out their roles in seeing the ten-year timeline through. II. Additionally, while the Alliance appreciates this first step, expanded discussion of standards is still needed to facilitate interoperability across stakeholder groups. The inclusion of LTPAC, and discussion of the eLTSS initiative, within the roadmap are promising signs of the importance of community-based care and long-term supports and services in the health care system. Further discussion of standards is required to enable implementation of the roadmap across the continuum. While the findings from the eLTSS initiative will be critical in the further development of standards, the Alliance recommends ONC consider further exploration of standards, consistent with the Alliance’s comments submitted last year on voluntary electronic health record (EHR) certification. Within these comments, the Alliance noted that interoperability should be the key behind the development of software certification standards as it is the best way to promote care integration across settings. This is further supported by the S&I Framework’s own Transitions of Care Initiative from 2011, which asserts standards are a critical enabler of care transitions. Therefore, to fully reach a nationwide interoperable health system, standards must remain a critical focus across all care settings, including LTPAC, community services, and behavioral health. III. Despite a shared interest in achieving interoperability, further consideration should be given to incentives for creation and adoption of interoperable health information technology systems While the Alliance understands the need for individual providers to play a critical role in the development of interoperable systems and networks, the Alliance urges ONC to consider additional policy levers and supports for the success of interoperability long-term. One possible means of incentivizing interoperability is through new models of care delivery. For example, the incorporation of health IT requirements in to the Medicare Shared Savings Program (“ACO proposed rule”) would be one way of promoting interoperability. Such incentives are appropriate as long as they do not pose an undue burden. Additionally, within the context of the meaningful use program, the Alliance recommends that meaningful use providers increasingly be required to exchange health information with LTPAC providers. By utilizing the existing meaningful use program to further health information exchange across settings, the goal of interoperability is furthered without great financial strain on the system. Without greater incentives for creation of these systems, there is no assurance that even those interested will invest in interoperability. This is referenced on page 37 of the proposed roadmap, “Despite strong agreement on the need for interoperability to enable higher quality, more efficient, person-centered care, the demand among providers, consumers and purchasers of health care has not yet translated into seamless interoperability across the health care system.” Thus, the Alliance urges ONC and HHS to consider further appropriate policy levers to advance the health care system towards interoperability. IV. The Priority Use Cases listed in Appendix H should include those related to LTPAC and care transitions. The Alliance urges ONC to look to the use cases developed by the S&I Framework’s Longitudinal Coordination of Care (LCC) Workgroup for additional use cases that include LTPAC. As discussed in both the draft roadmap and above, the shift to community-based services will put a greater emphasis on long-term services and supports. As such, identifying use cases that include LTPAC services is critical to creating an interoperable health care system. Therefore, the Alliance recommends the inclusion of the following use cases developed by the LCC WG, (1) a home health plan of care, (2) transitional care between home health and skilled nursing facilities (SNF), and (3) care transitions between SNFs and emergency departments. Building upon these use cases will support the growth of interoperability as care shifts into the community, with a home as a critical locus of care. * * * The Alliance is appreciative of the efforts made by ONC to focus on goals for health IT in the midst of a changing health care landscape. By focusing on the expansion of HIT adoption and interoperability, patient well-being and safety will be furthered, and health care delivery will be improved overall. In conclusion, the focus on the achievement of a nationwide interoperable learning health care system is one that the Alliance supports strongly. In order to maximize efficiency and achieve interoperability in the timelines discussed, greater discussion and clarification is needed on the role of individual stakeholders, appropriate standards, and incentives for adoption. Additionally, LTPAC and community-based services should remain a focus of discussion, with greater inclusion of the existing use cases. Thank you again for the opportunity to comment. Should you have any questions about the Alliance’s comments, please contact me at (202) 239-3671 or tlee@ahhqi.org or Jennifer Schiller at (202) 239-3206 or jschiller@ahhqi.org. Sincerely, Teresa L. Lee, JD, MPH Executive Director
Nandan Kenkeremath
Leading Edge Policy & Strategy
I have provided detailed comments which are attached on the following topics A. ONC should proceed with the focus on addressing interoperability in significant use cases without further delay or distraction B. Common technical standards or formats should be a desired capability for certain health information system software under some use cases but there should not reflect efforts to restrict additional, alternative formats when coupled with common format capability C. Modularity, like exchange and common format capability, is important, but stakeholders must also assess the value and approaches to modularity under competing objectives and practical considerations D. The Roadmap should try to articulate where there are separate transitional burdens from generally competing policy factors which include the value of innovation, competition, and tailoring products E. Some type of National survey or other approach to measuring the current and future level and means of interoperability would be useful F. Federal Agencies should commit to follow interoperability guidelines G. ONC has not yet demonstrated a feasible model for requiring or managing the use of interoperable IT tools through Medicare payment programs or Conditions of Participation H. The draft discussion on consent issues, including those on basic and granular choice, poses many problems and should be withdrawn except that consideration of developing comment consent mechanisms to facilitate consent where required under existing laws or other arrangement would be useful I.I. Harmonization of privacy and security law is important and cannot per se preserve the most stringent aspects of existing laws
I am in a health care policy consultant and can only commit to supporting the public policy discussion. I have worked on the Hill and afterwards on interoperability policy issues and would be happy to provide policy support.
Loveleen Singh
Assistant Director, Economic and Regulatory Affairs
College of American Pathologists
Tim McMullen
Executive Director
Cooperative Exchange - The National Clearinghouse Assn.
Joseph M. Ganley
Vice President, Federal Government Affairs
McKesson Corporation
Attached are McKesson Corporation's comments on the Nationwide Interoperability Roadmap.
Attached are McKesson Corporation's comments on the Nationwide Interoperability Roadmap.
William Yasnoff
Health Record Banking Alliance
John Dubiansky
Attorney Advisor - Intellectual Property
Federal Trade Commission
Attached is a comment submitted on behalf of the staff of the Federal Trade Commission’s Office of Policy Planning, Bureau of Competition, Bureau of Consumer Protection, and Bureau of Economics. We appreciate this opportunity to provide our views on ONC’s draft Interoperability Roadmap. We would be happy to address any questions you may have regarding competition and consumer protection policy in the health IT marketplace. John Dubiansky Attorney Advisor – Intellectual Property Office of Policy Planning Federal Trade Commission 202.326.2182 jdubiansky@ftc.gov
Nick Valeriani
Chief Executive Officer
West Health Institute
Greg Fulton
Industry & Government Affairs
Greenway Health
Please accept the attached as updated version dated 4-3. Thank you.