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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.


Steven Maier
State HIT Coordinator, Health Reform Manager
State of Vermont, Dept. of VT Health Access
Rebecca Snead
National Alliance of State Pharmacy Associations
Ron Fitzwater
Chief Executive Officer
Missouri Pharmacy Association
Lauren Choi
Senior Director, Federal & International Affairs
Premier healthcare alliance
Margaret Weiker
Director, Standards Development
The comments I'm submitting are on behalf of the SCO.
Lisa Simpson
President and CEO
Priority Use Cases AcademyHealth supports the efficient flow of clinical information for authorized reuse by the research community and works to improve the infrastructure and ecosystem needed for the dissemination and uptake of evidence-based findings by the health care system. To that end, we encourage ONC to consider policies that enhance—and do not unnecessarily restrict—the quality, availability, timeliness, and affordability of data and tools used to conduct and disseminate research. Along those same lines, as ONC weighs the prioritization of use cases, AcademyHealth recommends supporting a governance framework that gives researchers appropriate access to identified and de-identified clinical and claims data for the production of robust, meaningful research and focuses on the role of patients in their own care—including facilitating access to their data for self-management and care across systems and settings (i.e., Appendix H use cases 2,19, 21, 56) and exchange of data among providers (i.e.,17), as well as promoting opportunities to participate in research—in addition to those cases that provide continued support for public and population health (i.e., 1, 4, 50, 51), measuring and reporting on care to improve quality and value (i.e., 10, 38), and facilitating discovery (i.e., 15, 16). General: Critical Action for Near-Term Wins AcademyHealth supports enhancing the evidence base and moving knowledge into action. We value ONC’s inclusion of calls to action (Table 4, pp. 53-54) for providers to collaborate more fully with research institutions, public health departments, and other partners to generate new knowledge that helps to fulfill the Triple Aim by recognizing the importance of research to improve health care and care delivery. There are many promising examples of continuously learning health systems that are improving care while contributing new methods and approaches to facilitate meaningful interoperability. AHRQ-funded research networks such as Improve Care Now, CERTAIN, the Indiana Registry, and SAFTInet, in addition to ONC Beacon Communities in Michigan, Minnesota, and New Orleans offer a subset of relevant examples. All offer live demonstrations of systems working towards interoperability that can contribute new knowledge on critical health issues such as Crohn’s disease, surgical outcomes, dementia care, and pediatric asthma, among others. Similarly, AcademyHealth’s peer-reviewed, open access journal, eGEMs, was created with support from AHRQ for the express purpose of highlighting lessons learned from quality improvement and research efforts that promote the interoperability of systems needed to facilitate continuous learning and improvement. Governance The Roadmap rightly views the HIT ecosystem as a learning health system (LHS) and considers rules of engagement and governance as a fundamental building block for LHSs of the future. Of particular concern to the research community is the need for coordinated governance to facilitate data-sharing agreements among different institutions, including the need to agree on legal, policy, and procedural issues. Without these agreements, there are significant delays and many missed opportunities for collaboration. AcademyHealth is excited to see ONC define a need for public-private collaboration around shared governance (Table 1). We encourage ONC to consider adaptation and support for partnership models that facilitate learning, collaboration, and sharing of successful governance models among researchers and other stakeholders to build learning health systems that improve patient care and outcomes. Such forums can broaden awareness and agreement among existing communities with the goal of coordinating governance processes.
AcademyHealth's EDM Forum will continue to support interoperability in the following ways: - Gather, synthesize, and disseminate information on promising interoperability models through issue briefs, white papers, toolkits, and other policy-friendly products; - Publish and curate information through eGEMs, the online journal for innovative approaches to achieve interoperability in a learning health system; and - Continue to support collaborative methods projects that generate new tools to promote best practices in interoperability.
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Anne Myrka
Medication Safety Pharmacist-Healthcare Quality Improvement
Anne Myrka
Medication Safety Pharmacist-Healthcare Quality Improvement
Arrah Slichenmyer
Please!!!! Let's keep confidentiality in the freedom of speech! !!!
Terrence O'Malley, MD
Partners HealthCare System, Inc
General comment: excellent overarching vision, perfect timing, needed Long range goal has to include unimpeded information exchange across all service sectors that might be engaged with individuals having complex medical, behavioral, functional and environmental needs. This requires standards for information exchange, syntax and meaning that are shared by medical service providers, behavioral health service providers, Long Term and Post Acute Care providers (LTPAC) and LTSS/HCBS providers and, finally, the individual and immediate caretakers. Currently, there is limited exchange between these sectors although exchange among medical providers has increased thanks to meaningful use incentives. Robust exchange among all of these sectors is a necessity for the individuals with the most complex needs. There are two essential processes that should be called out specifically: transitions of care from one site or team to another, and longitudinal coordination of care across all sites and teams. These are the fundamental processes in health care and need to be explicitly supported. The capability to exchange a plan with other service providers should be a high priority goal. The data required as part of an exchangable plan includes most of the information needed to assure safe transitions. When this is done electronically, it opens up the possibility of using the act of transferring this information as a quality measure based on timeliness, completeness and format. ONC Rocks.
C3 Privacy and Security. The linchpin for interoperable exchange among all sectors, particularly for behavioral health but not limited to it. Unless there is a robust yet flexible means for the individual to control the flow of information it will be difficult (more difficult?) to meet this standard. In addition to policy and regs, there needs to be a technological solution that prevents data from moving from one site to another without the required permissions. This is a very significant issue for behavioral health due to the loss of control over data once it has been exchanged (with permission) to another setting. The individual has little control over what the second setting does with that information. D. Needs to be more than a new culture of interoperability, there have to be business cases that support the adoption and maintenance of this capability. Unless adoption meets a business requirement, has an ROI or is supported externally, adoption won't occur in LTSS and LTPAC given a lack of resources. There needs to be a "lift" to assure adoption. G4. Standards. Given the investment in the CDA through Meaningful Use, it seems logical to establish this standard for information exchange across the entire care spectrum including LTPAC and LTSS. If this is the shared standard then then next steps would be: establish shared vocabulary and meaning across all sectors (a huge job centered in the Date Element Library requiring an unprecedented degree of harmonization*), develop the low cost exchange mechanism that LTPAC, LTSS, and the individual and caretaker will need to participate (EHRs have limited reach and none of the functionality that the far end of the care spectrum want or need). Establish functional requirements for the electronic systems that enable these exchanges to include at a minimum the ability to create, store, retrieve, send and receive CDA documents. Insure that low cost mechanisms exist everywhere so that everyone can connect with everyone else. *Harmonization of data elements: need process to identify the highest priority elements by looking at high value exchanges between and among the sectors, recognize that the process must include different levels of specificity in order to be useful for clinically sophisticated users as well as for non clinically sophisticated users who will be adding observations to the health record at their own level of understanding. Recommend: a comprehensive and explicit process to establish the data needs for all high value information exchanges between and within the medical care sector, behavioral health care sector, LTPAC, LTSS, and with the individual and care taker. Harmonize these different sets and establish functional requirements for sectors that don't have certification standards of electronic exchange, follow with certification standards.
Kymi Kieffer
We do not want to pass The Doc Fix. We need to vote NO on the HR2. We already have a shortage of health care professionals, especially physicians. This shortage is only going to grow worse. So why would we want to do anything that is going to, first, discourage young people to seek the medical profession and second, why would we do this to only short change ourselves in the future of healthcare professionals. Vote No on HR2. Keep our patient data private. Why would we want the patient data public property? Vote NO on HR2.
Ken Sprague
Government Affairs Manager
American Society of Consultant Pharmacists
Matt Reid
Sr. Health IT Consultant
American Medical Association
Audrey Busch
Director of Policy and Advocacy
Consortium for Citizens with Disabilities Technology and Telecommunications Task Force
April 3, 2015 The Consortium for Citizens with Disabilities Technology and Telecommunications Task Force would like to submit the following comments regarding “Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0.” The Consortium for Citizens with Disabilities is a coalition of more than 100 national disability organizations working together to advocate for national public policy that ensures the self-determination, independence, empowerment, integration, and inclusion of children and adults with disabilities in all aspects of society. The Telecommunications and Technology Task Force focuses on ensuring national policy on matters of telecommunications and technology, including assistive technology, helps move society toward our ultimate goal of full inclusion of all people with a disability. The Task Force commends the Office of the National Coordinator for Health Information Technology’s (HIT) work to develop this draft report. Specifically, however, the Task Force recommends the report include language that ensures HIT is fully accessible for people with disabilities. It is important that all different types of information and communications technologies (ICT) are fully accessible, including HIT, by conforming to a set of nationally accepted ICT access standards. As you continue to finalize the Roadmap that outlines the interoperability across the HIT landscape, it is essential that the development of the health IT system be designed to ensure compatibility with an array of assistive technologies. The importance of ensuring an accessible infrastructure up front during the early development stages is easily overlooked, and therefore, we are asking for language ensuring ICT accessibility included in the final version of this report. The CCD Technology and Telecommunications Task Force would like to meet in person to explain this issue in further detail. It is essential that accessibility issues be considered during the development of this Roadmap and incorporated during the development of a healthy HIT ecosystem. Thank you for your consideration of these views. If you have any questions, please feel free to contact one of the CCD Technology and Telecommunications Task Force Co-Chairs: Eric Buehlmann, eric.buehlmann@ndrn.org; Mark Richert, 4justice@concentric.net; Audrey Busch, audrey.busch@ataporg.org; Sara Rosta,sara.rosta@ppsv.com; or Michael Brogioli, mbrogioli@resna.org. Sincerely, Mark Richert, American Foundation for the Blind Audrey Busch, Association for Assistive Technology Act Programs Sara Rosta, Perkins Michael Brogioli, Rehabilitation Engineering and Assistive Technology Society of North America Eric Buehlmann, National Disability Rights Network
Dave Cassel
Please see Carequality's comments in the attached file.