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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.


Chantal Worzala
Monday, July 31, 2017 - 13:49
Thank you for the opportunity to comment. Please see the attached letter from the American Hospital Association.

Mari Savickis
Monday, July 31, 2017 - 13:40
Attached, please find CHIME's response to ONC's Standards Measurement Framework.

Elizabeth Martin
Monday, July 31, 2017 - 13:38
This is a challenge, because nationwide the different computer resources that health professionals are or have implemented into their businesses can be as different as every American family's Thanksgiving traditions. I think that the idea of tying in basic minimum computer infratructure to healthcare payer incentives is a good one. As more healthcare professionals adopt and provide patient access to healthcare electronic records via patient portels the navigation signs will increase. From a computer expert working with experience within large multi-office corporations including some with NIH research grants, communication on the front-end among and between depts, divisions and beyond is imperative. My own personal access to my EHR leads me to this comment: "Holy Cow Doctor, Where did you get this software? Now I'd like to see the machines you're trying to cram it into." Please keep me on your review and comment list as I will be exploring in more detail this subject and developing some healthcare staff and patient potal surveys.

Elizsbeth Martin

Gary Dickinson
Monday, July 31, 2017 - 13:32
Thank you for the opportunity to comment on the proposed ONC “Interoperability Standards Measurement Framework”. We believe it is crucial to focus on measurement of interoperability standards in actual use AND the resulting achievement of true and useful interoperability as evident in health data/record integrity and fitness for use.

See uploaded comment document which includes specific responses to the questions posed and references closely-related CentriHealth comments submitted on 30 June 2017 regarding the "National Quality Forum – DRAFT Measurement Framework to Assess Nationwide Progress related to Interoperable Health Information Exchange to support the National Quality Strategy" (also included).

Monday, July 31, 2017 - 13:06
On behalf of the Healthcare Information and Management Systems Society (HIMSS), we are pleased to provide written comments to the Office of the National Coordinator for Health Information Technology (ONC) in response to the ONC Proposed Interoperability Standards Measurement Framework (the Framework). HIMSS appreciates the opportunity to leverage our members’ expertise in commenting on the ONC Framework, and we look forward to continuing our dialogue with ONC on identifying, assessing, and determining the best available tools and resources to measure the state of interoperability within the health IT community. We feel that this effort will provide important information on the status of our healthcare system’s ability to share and use secure electronic information and inform the community on how to continue to advance interoperability to improve care delivery.

Mariann Yeager
Monday, July 31, 2017 - 12:47
We appreciate the opportunity to comment and are pleased to submit the attached letter with our comments.


Monday, July 31, 2017 - 12:46
Please see comments offered by UnitedHealth Group in the attached letter.
Joel White
Monday, July 31, 2017 - 12:12
Attached please find Health IT Now's comments on the Standards Measurement Framework.

Kyle Levin
Monday, July 31, 2017 - 12:10
July 31, 2017

Don Rucker, M.D.
National Coordinator for Health Information Technology
Office of the National Coordinator for Health Information Technology
U.S. Department of Health and Human Services
330 C St SW
Floor 7
Washington, DC 20201

Submitted electronically

RE: Request for Public Comment Concerning ONC’s Proposed Interoperability Standards Measurement Framework

Dear Dr. Rucker,

On behalf of our more than 98,000 member physical therapists, physical therapist assistants, and students of physical therapy, the American Physical Therapy Association (APTA) submits the following comments regarding the Office of the National Coordinator for Health Information Technology’s (ONC) request for public comment concerning its Proposed Interoperability Standards Measurement Framework.

The purpose of the Proposed Interoperability Standards Measurement Framework is to determine the nation’s progress in implementing interoperability standards in health information technology (health IT) and the use of the standards as a way to measure progress towards nationwide interoperability. APTA strongly supports the implementation of interoperability standards in health information technology. Physical Therapists have increasingly come to rely on the use of health information technology in their practice, and we believe that this trend is likely to accelerate in the coming years. Ensuring that IT systems are able to properly exchange information will ultimately lead to a better functioning health care system as a whole. APTA supports any standards that would lead to increased efficiencies.

APTA supports the ONC’s efforts to adopt the widespread exchange of health information through interoperable certified electronic health record (EHR) technology nationwide.
Recognition of the need to capture rehabilitative services in electronic health records (EHRs) has led to substantial growth in the development of EHR systems in the rehabilitation sector.
APTA’s development of clinical practice guidelines and other important criteria has been the basis for the attributes of many existing health information technology systems serving rehabilitative service providers.

Given that only a limited number of EHRs certified through the ONC encompass the necessary components for the documentation and transmission of information regarding physical therapy services, we hope to work with the ONC in the near future to ensure that these products are certified accordingly. To better assist physical therapists and other non-physician providers as they adopt certified EHRs within their clinics and practices, we recommend the ONC develop robust educational materials as well as provide implementation assistance and/or consultant support to such professionals.

Once again, we thank the ONC for the opportunity to comment on the Proposed Interoperability Standards Measurement Framework. We look forward to working with the ONC to develop a well-functioning interoperable health system. If you have any questions regarding our comments, please contact Kara Gainer, Director of Regulatory Affairs, at karagainer@apta.org or 703/706-8547. Thank you for your consideration.


Sharon L. Dunn PT, PhD, OCS

SLD: kg

Sarah Collins
Monday, July 31, 2017 - 11:53