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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.


Sylvanus Zimmerman
Privacy & Security Officer
Jersey Health Connect
Please see attached.
American College of Emergency Physicians (ACEP)
Michael Gallup
Fred Trotter
Data Journalist
The DocGraph Journal
Please find my comments attached.
I create data sets that can be used to help you sort out if interoperability is actually working.
Kate Horle
State and Federal Initatives Director
Colorado Regional Health Information Organization
Mariann Yeager
Healtheway, Inc.
Richard Morrison
Vice President, Government & Public Policy
Adventist Health System
Please find Adventist Health System's comments in the attached file.
Carolyn Mullen
Director of Government Affairs
American Association for Dental Research
Janis Bartlett
Policy Director
Arkansas OHIT
The guiding technology principles laid out in the road map do not seem to be in line with the scope, since the scope states that the systems need to be “learning systems”. This concept is not in line with the principle regarding leveraging existing HIT infrastructure as traditional technology may not support “learning systems” universally. In addition, Direct Trust - Requirements have been developed as a security protocol requirement by ONC but this concept requirement must be implemented by each funded HIE and requires investment in a product made available by specific entities or vendors. This creates a market without pricing restrictions that has become cost prohibitive to the HIEs and their customers. Requiring HIEs to provide a certified product to their customers but not requiring vendors to utilize a defined pricing model results in HISP services that are priced in various methods depending upon the vendor. Furthermore, EMR/EHR vendors’ pricing models offered to their EMR/EHR customers and HIEs for building interfaces between the EMR/EHR and the HIE are extremely expensive to both parties. The Vendors charge the HIEs to build the interfaces and the providers. HIEs are required to connect to every EMR/EHR system and the costs to the HIE remains the same if there is one customer using the EMR/EHR or 1,000. This is cost prohibitive to the HIEs and the providers. OHIT urges ONC to consider these pricing constraints on interoperability and take steps to improve market pressures. In addition, as a statewide Health a Information Exchange, OHIT also believes that: • Interoperability governance must reflect the full continuum of a broad national information supply chain; and • The information supply chain must include the rich and abundant data from across the health, healthcare, human services, health research, and personal health & wellness ecosystem. We urge ONC to consider a broad definition of the interoperability ecosystem, reflecting the goal of a Learning Health System. As a nation, we must collaborate across domains to address the scope and significance of this effort and its essential national importance to health, wellness, and cost. This process of coordination and governance must be durable, repeatable, and extensible, not through any one particular organization or institution, yet the process must persist over time. To ensure the equity and integrity of this critical national infrastructure, it must be organized: • through a process that is vendor-, payer-, and institution-agnostic; and • reflects all of the domains of HIT’s diverse constituencies. Those domains include but are not necessarily limited to: • Data generators and users, including o patients and families, o providers: individuals, institutions, and organizations across the care, services, health & wellness continuum; o Federal providers of healthcare services and federal senders/receivers of data (DoD, VHA, IHS, CDC, CMS... the members of the Federal Health Architecture); • State, county, local, territorial, and tribal governments and agencies; • Health IT and IT system vendors and integrators, their trade groups and associations; • Health Information Exchange and data aggregation and analytics organizations and services; • Clinical research and the pure and applied sciences communities; • Champions of transparency, value, and quality of healthcare systems and financing; and • Cross-cutting individuals and organizations that support those both within and working across these domains. We believe the best approach is an iterative, agile series of steps designed to: • engage and convene cross-domain constituencies of collaborators; • define common shared values by articulating clusters of use cases that reflect common patterns across domains; and • produce a set of recommendations in early fall 2015 for specific actions steps that can be taken within each domain, including government, to inform ONC about the next steps we as states/organizations/individuals can take together through self-organizing collaboration. We recognize this is no small task, but the alternative is to continue the unacceptable chaos that characterizes the status quo of interoperability. Paradoxically, while we must begin to comprehensively coordinate the mission-critical infrastructure of HIT, its coordination must be focused on those activities that people and organizations agree that they want to coordinate. In other words, this must be a self-organizing, collaborative process, reflecting the particular interests and focus of diverse communities of interest across the ecosystem. Its outcomes cannot be pre-ordained: the governance structures will emerge “in the rearview mirror,” based on the outcomes of subsets of collaborative activities. It is critically important not to let construction of an ideal governance solution impede immediate progress. It will take a long time to fully instantiate a durable, persistent governance and coordination process. Even very recent history is littered with multiple, failed efforts to define “the right governance” and roadmap for HIT. These failures are the result of approaching the problem from too narrow a perspective. We should look to the wisdom of General and President Dwight D. Eisenhower, who said "Whenever I run into a problem I can't solve, I always make it bigger. I can never solve it by trying to make it smaller, but if I make it big enough, I can begin to see the outlines of a solution."
OHIT continues to work toward interoperability as it expands the scope of SHARE, the statewide HIE, to private and public health participants using a vendor agnostic platform and leveraging policy levers to expand the utilities SHARE provides.
zack gill
private citizen
I am opposed to the medical records tracking system. It threatens the privacy of every person. Subjects our medical records to the risk of hacking. Interferes with the rights of states to make their own laws and regulations regarding medical records.
Jeff Coughlin
Senior Director, Federal & State Affairs
Thanks for the opportunity to submit our comments.
Anne Myrka
Medication Safety Pharmacist-Healthcare Quality Improvement
Carol Heitzman
2. Views patient data as public property rather than personal property. Our medical information is personal, should be kept private. 4. Turns medical system into a research endeavor at the bedside. Who will be able to trust medical professionals if one is concerned about being in an experiment. 9. Proposes to turn EHR companies into public utilities to create a national medical records system.
Sean Turner
Sr. Director, HIE / Community Care
Dignity Health
On behalf of Dignity Health, I respectfully submit the attached comments.
jeri Kubicki
Vice, President, Head of Legislative Policy
UnitedHealth Group