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Proposed Interoperability Standards Measurement Framework Public Comments

Proposed Interoperability Standards Measurement Framework Public Comments

The comment period for this document ended on 5 p.m. ET on Monday, July 31, 2017. Comments for this document will be posted shortly.

The document solicits feedback on a proposed industry-wide measurement framework for assessing the implementation and use of health care interoperability standards. Currently, stakeholders’ capabilities to measure and report on the use of standards vary significantly across the health IT ecosystem. This framework aims to help health IT developers, health information exchange organizations, and health care providers move towards a set of uniform measures to assess interoperability progress.

Please note that comments and recommendations submitted as part of this process will be made public by ONC.


Jesse James
Tuesday, August 1, 2017 - 04:42
Please accept the attached Feedback about the Standards Measurement Framework.
Julie Maas
Monday, July 31, 2017 - 20:02
In the simplest case, collection of the Direct Address and other activated FHIR or XD endpoints for an organization would be helpful in determining that such capabilities have been enabled for an organization and through which trust community. This could be a path toward building a nationwide directory of all electronic addresses and for evaluating the capabilities of those endpoints by performing automated tests (or at least pinging them). A breakdown of how IRA requests are managed would also be helpful--expecting this to be heavily fax-dependent today and moving toward more automation. Give an opportunity to list a provider organization or EMR vendor with which there are interoperability issues that should be explored, so that solutions can be sought. Next in priority would be assessing the % of pulled or received documents that were successfully incorporated into new or existing medical records, with a categorization of the remaining % that couldn't be incorporated (patient not accepted, CCDA incompatibilities, or for which effort was not made to do so). Of the % unsuccessfully digested documents, list 3 different product/vendor senders or sources whose documents you were unable to digest and what transport method was used. Nice to have: it would be useful to explore failures/missed connections--perhaps a narrative set of questions to ask providers regarding why sent messages seem to fail (percentage breakdown of trust issues, attachment related issues, or that messages were not sent in the first place due to not knowing the recipient's address). Also, what data would help their work but is not available to them presently? Your question of how to collect metrics on increased efficiently and improved care might be similarly addressed by allowing providers to respond in the form of a narrative that allows them to describe successes relevant to their specialty. It would be helpful to note which b.1 certified EMRs do not work with which h.2 certified HISPs, to evaluate "interoperability at the edge". Metrics to consider: 1) Number of query or Direct messaging resources available to a practice (count of distinct provider organizations participating in network and for which the destination endpoint or address is known or discoverable); 2) Percent of patient documents received from a foreign system which can be referenced within the EMR as if they were locally generated (denominator is total # of Direct messages received or queries performed).

Leigh Burchell
Monday, July 31, 2017 - 18:39
Allscripts, with a platform of clinical and business solutions for ambulatory, acute and post-acute care settings, is relied upon by the largest network of providers. It is through our three decades of experience partnering with and deploying software to this vast network of providers that we can submit informed comments today on the Office of the National Coordinator’s Proposed Interoperability Standards Measurement Framework. We appreciate an opportunity to contribute to this important discussion of how to best measure interoperability standards adoption and use, and we welcome any questions or discussion that would be helpful. Please see attached...

Chris Hills
Monday, July 31, 2017 - 18:23
Thank you for providing us an opportunity to comment on this document. We are submitting these comments on behalf of Veteran's Health Administration, Defense Health Agency, Program Executive Office Defense Healthcare Management Systems and DoD / VA Interagency Program Office. Let me know if there are any questions. Chris Hills (843) 218.6627

Sally Connally
Monday, July 31, 2017 - 17:48
Please see the attached file. Thank you for to opportunity to share our comments and recommendations.

Allyson Perleoni
Monday, July 31, 2017 - 17:28
Please find attached comments from the American Academy of Pediatrics.
Sally Connally
Monday, July 31, 2017 - 17:01
On behalf of Change Healthcare, I am pleased to submit comments on the proposed Interoperability Standards Measurement Framework.

About Change Healthcare:
Change Healthcare is inspiring a better healthcare system. The Change Healthcare Extended Care Solutions group works alongside our customers and partners. We leverage our software and analytics, network solutions and technology-enabled services to enable better patient care, choice, and outcomes at scale. As a key catalyst of a value-based healthcare system, we are accelerating the journey toward improved lives, and healthier communities. Simply put, we impact 1 in every 5 US patient records, 12 billion healthcare transactions and $2 trillion in healthcare claims costs annually. Our solutions touch 800,000 physicians, 5,500 hospitals, and 2,100 payer connections. With our customers and partners, we are creating a stronger, better coordinated, increasingly collaborative and more efficient healthcare system that enables better patient care, choice and outcomes at scale.

Comments and Recommendations
Change Healthcare is pleased to offer comments and recommendations on the proposed framework:

We strongly support a measurement framework and the objective as outlined in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), to achieve widespread exchange of health information through interoperable certified electronic health record (EHR) technology nationwide by December 31, 2018.

We support the attainment of this objective through joint public private collaboration as we continue to advance the digitization of healthcare. True person centered interoperability may begin with the basic exchange of a file containing patient data but our vision must evolve to orchestrated interoperability were the information flows seamlessly across heterogenous environments and can be incorporated within workflow to inform decisions in real time. The following comments and recommendations are provided to help guide the development of a measurement framework that will evolve with our expanding capabilities.

As currently proposed, the measurement areas could count transactions, detect point use, or capture within-vendor transactions—which may misrepresent the state of interoperability across the US. The measurement areas miss identifying whether the crucial interoperability use cases and cross-vendor transactions are met, which are ultimately the driving force behind meeting the nation’s objectives for robust health information exchange. Furthermore, a voluntary program has the chance to create highly-skewed reporting and not have enough statistical rigor to narrow-in on priority areas.

ONC’s efforts to continue refining an adequate measurement framework are admirable and could be furthered with several considerations:
- The measures should align with outcomes and use-case driven focus on the interoperability needs which have been identified through ONC’s convening activities and listed within the ISA. To that end, we encourage ONC to continue in its role as a convener and bring together workgroups with all actors & systems identified to meet specific interoperability needs, and then work through the types of measures which would identify whether varying levels of interoperability are met. Those workgroups should propose how a pilot could then appropriately measure interoperability, based on the outcomes and not simply volume, end-user adoption, or development plans.
o ONC’s proposed measurement areas are going to be a heavier lift end-to-end than any one exchange partner (identified as “data holders”) could adequately cover and provide comprehensive data to answer the strategic objectives. Therefore, the measurement stakeholders need to be broadened beyond the current definition and could include providers, payors, patients, and more, beyond simply software providers.
o Based off the efforts of the workgroup recommendations, ONC should then identify exchange partners to pilot the measurement criteria identified by the working groups. Targeted pilots will generate improvements for the approach, and better codify the merits for industry actors to participate in a voluntary program.

- Understanding that the scope of measurement stakeholders is broader than defined in ONC’s proposal. We recommend that ONC seek to align the voluntary program with desired outcomes from other national interoperability priorities such as Advancing Care Information under MACRA’s Quality Payment Program, and further detailing the understanding of “information blocking” for clinical research use cases contained within the 21st Century Cures Act. Both of those pieces of legislation provide guidestars for value-based payments supporting public health & clinical research which can be leveraged as meaningful use cases for vetting an interoperability measurement framework.
- We encourage ONC to specify the reporting and analysis framework into which the measures would be populated and made available, including level of disclosure.
- Finally, we encourage the ONC to re-visit the term “data holder,” and consider "Measurement Audience," "Measurement Participants," or even "Target Measurement Volunteers," as none of the entities listed truly hold data—be it clinical data, or metadata about interoperability transactions that hasn’t already been configured within the system to-date.

Dresden Maxwell
Monday, July 31, 2017 - 16:51
Nicole Harmon
Monday, July 31, 2017 - 16:50
Karen Boruff
Monday, July 31, 2017 - 16:42
Please refer to attached document for combined comments. Thank you!