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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.


Ksenija Kapetanovic
Monday, July 31, 2017 - 11:44
The American Society for Radiation Oncology (ASTRO) appreciates the opportunity to comment on the Proposed Interoperability Standards Measurement Framework. Generally, ASTRO agrees that Health IT developers and exchange networks are best positioned to provide data on the use of standards meant to improve interoperability. However, there should be an opportunity for end users to comment or provide feedback on the true success of interoperability within the clinic. For example, a specific standard may be available in health IT products (Objective 1) and even utilized by end users (Objective 2), but this does automatically equate to progress towards the Triple Aim. For example, poor design may result in inefficiency for the provider and consequently, the healthcare system. On paper, 30 clicks or four systems with separate logins may be considered a "success" to developers, but from the clinician’s point of view, they cost a lot of time and money, both of which provide significant impediments to getting and using the information in the data domains. Health IT should allow providers to spend more time with their patients, not their computers. Therefore, it is important that end users help determine if the interoperability standards and implementation results in a system that offers providers information needed to deliver high quality healthcare.

Shelly Spiro
Monday, July 31, 2017 - 11:29
On behalf of the membership of the Pharmacy Health Information Technology Collaborative (the Collaborative), we appreciate the opportunity to submit comments regarding the proposed Interoperability Standards Measurement Framework. The attached document outlines our comments. The Collaborative has been involved with the federal agencies, including the Office of the National Coordinator (ONC), developing the national health information technology (HIT) framework since 2010.

Pharmacists provide person-centered care and services, maintain various secure patient care records, and as part of the integrated health care team, they are directly involved with other health care providers and patients in various practice settings. Pharmacists are users of health IT and are especially supportive of interoperability standards incorporating Health Level Seven (HL7), SNOMED CT, RxNorm (National Library of Medicine), NCPDP SCRIPT (National Council of Prescription Drug Programs), and NCPDP Real Time Formulary and Benefits (currently under development). The Collaborative supports the use of these particular standards which are not only important to pharmacists for use in providing specific person-centered care and services to patients, but these particular standards would help in reaching the proposed framework’s goal of measuring nationwide interoperability progress.

As we noted in previously submitted comments regarding the ONC’s proposed interoperability standards and its 2015 released Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap (the Roadmap), it is vitally important that pharmacists’ access to proposed interoperability elements not be limited; a current barrier needs to be resolved, particularly with regard to the ONC’s current proposed framework for measuring implementation progress.

Pharmacists, as health care providers, were not included in the CMS Electronic Health Records (EHR) Incentive Program, which is now being merged into the new Merit-based Incentive Program (MIPS), as eligible providers who use health IT. These programs are a rich resource for measuring implementation progress and knowing what standards are being used. However, as parts of the Roadmap and the proposed measurement framework are based on the interoperability standards incorporated into these incentive programs, groups not included in these incentive programs may be slow to implement these standards, if at all, within the ONC’s timeframe, thus limiting the progress of nationwide interoperability adoption. Given the interconnectivity of federal agencies to the Roadmap, the ONC could play a role in helping to resolve this particular barrier.

The Pharmacy HIT Collaborative’s vision and mission are to assure the nation’s health care system is supported by meaningful use of HIT, the integration of pharmacists for the provision of quality patient care, and to advocate and educate key stakeholders regarding the meaningful use of HIT and the inclusion of pharmacists within a technology-enabled integrated health care system. The Collaborative was formed in the fall of 2010 by nine pharmacy professional associations, representing 250,000 members, and also includes associate members from other pharmacy-related organizations. The Pharmacy HIT Collaborative’s founding organizations represent pharmacists in all patient care settings and other facets of pharmacy, including pharmacy education and pharmacy education accreditation. The Collaborative’s Associate Members represent e-prescribing and health information networks, a standards development organization, transaction processing networks, pharmacy companies, system vendors and other organizations that support pharmacists’ services. For additional information, visit www.pharmacyhit.org

Sarah Shih
Monday, July 31, 2017 - 10:29
To the Office of the National Coordinator,
The New York City Department of Health and Mental Hygiene (DOHMH) appreciates the opportunity to comment on ONC’s Proposed Interoperability
Standards Measurement Framework. Our commentary is attached.

Terrence O'Malley
Monday, July 31, 2017 - 09:14
David Kibbe
Monday, July 31, 2017 - 08:03
Please see the Comments from the DirectTrust Clinicians Steering Group attached.

Ticia Gerber
Saturday, July 29, 2017 - 07:11
Attached are HL7's comments on the Office of the National Coordinator’s (ONC) Request for Information regarding a proposed Interoperability Standards Measurement Framework.

Jamie Ferguson
Friday, July 28, 2017 - 19:43
pam matthews
Friday, July 28, 2017 - 15:48
thank you for allowing public comment on this important piece of work. The Strategic Health Information Exchange Collaborative (SHIEC) has submitted comments via the PDF attachment. Please let me know if there are any questions

Anna Orlova
Friday, July 28, 2017 - 11:54
Please see attached the Comments from the American Health Information Management Association (AHIMA)

Aafaque Akhter
Tuesday, July 25, 2017 - 16:03
Trusted bundles should be cheaper. measures should be there so that big businesses don't control access and people with less means can't develop operations. There should be some dummy data for testing.