Draft 2017 Interoperability Standards Advisory
I-A: Allergies
I-D: Functional Status/Disability
I-G: Immunizations
I-J: Medications
I-M: Patient Clinical “Problems” (i.e., conditions)
I-P: Race and Ethnicity
I-S: Social Determinants
I-V: Vital Signs
I-B: Encounter Diagnosis
I-E: Health Care Provider
I-H: Industry and Occupation
I-K: Numerical References & Values
I-N: Preferred Language
I-Q: Research
I-T: Tobacco Use
I-C: Family Health History
I-F: Imaging (Diagnostics, interventions and procedures)
I-I: Lab Tests
I-L: Nursing
I-O: Procedures
I-R: Sexual Orientation and Gender Identity
I-U: Unique Device Identification
II-A: Admission, Discharge, and Transfer
II-D: Clinical Quality Measurement
II-G: Drug Formulary & Benefits
II-J: Images
II-M: Patient Education Materials
II-P: Representing clinical health information as a “resource”
II-S: Summary care record
II-B: Care Plan
II-E: Clinical Quality Reporting
II-H: Electronic Prescribing
II-K: Laboratory
II-N: Patient Preference/Consent
II-Q: Research
II-C: Clinical Decision Support
II-F: Data Provenance
II-I: Family health history (clinical genomics)
II-L: Medical Device Communication to Other Information Systems/Technologies
II-O: Public Health Reporting
II-R: Segmentation of sensitive information
III-A: “Push” Exchange
III-D: Healthcare Directory, Provider Directory
III-G: Query
III-B: Clinical Decision Support Services
III-E: Public Health Exchange
III-H: Resource Location
Oct. 24, 2016
Philips Wellcentive comment
ONC 2017 Standards Advisory
Philips Wellcentive appreciates the formation of ONC’s annual standards advisory and its public comment period as important elements of advancing this critical aspect of data exchange, born out of the agency’s Interoperability Roadmap.
Overall, given the sometimes contentious perceptions of the state of interoperability within the industry and found within language of the House 21st Century Cures bill, for example, along with examples of arguably arbitrary timelines for “widespread” or “national” interoperability found also in Cures and within the MACRA legislation, we believe the Office of the National Coordinator should utilize the annual standards advisory as a standards requirement vehicle versus that of a list of recommendations.
Historic standards variations coded into proprietary health IT systems even prior to the HITECH Act continue to cause integration lags. In our opinion, “data blocking” is as much a result of legacy development as business practices.
ONC is the agency that can pursue the requirement and enforcement means to effectively advance standardized data exchange, and still do so through collaboration with the private marketplace.
To this end we regret the 2017 advisory’s language around eliminating designations of “best available” standards as a pulling back from the agency’s mission. We are not calling for a mandate but a consensus-driven set of standards that cannot be dismissed as a mere federal exercise. To that end, while excluding best available within the specification categories, we do note the advisory’s introduction language notes that the purpose of the advisory is “to provide the industry with a single, public list of standards and implementation specifications that can best be used to fulfill specific clinical health information interoperability needs.”
As the all-payer movement to value-based care expands and as quality reporting is increasingly addressed and scored at the population level, the health IT industry is moving beyond EHR data exchange to more automated and scalable data aggregation, quality, analysis and reporting platforms.
ONC must understand and keep pace with this movement and address how efficiencies in data exchange standards can become truly standard.
As detailed in a 2016 EHR data integration survey published by Health 2.0 and linked here, health IT vendors found a very mixed landscape of success in terms of integration with legacy EHRs.
This is noteworthy because these integration efforts were conducted through APIs, roundly seen as a solid advancement for interoperability. We don’t disagree with that, and the greater point being if API technology is to fulfill its promise, now is the time for clear and required standards. Likewise a recent KLAS study also discussed interface challenges among disparate legacy EHRs.
As an example within the agency’s 2017 standards advisory we see variations allowing the use of LOINC or SNOMED, for example. For Philips Wellcentive, as we currently aggregate data from more than 3,000 established interfaces with more than 150 vendors, we find that a good 50 percent of the data we aggregate is custom in its origins, meaning we need to conduct normalization processes before the data can be uniformly used for quality reporting and other means. We have no issues with utilizing LOINC or SNOMED, and would have less issue with one. In instances of any acceptable combination or options – which we don’t recommend – and in lieu of a “best” available, articulating specifications to use cases to avoid overlap in that regard could be beneficial.
In addition, as standards need to be crystalized, ONC needs to address the growing need for care management and population health management use cases that should be matched, to again not only keep pace with but to anticipate the ubiquitous future of value-based care and then population-based payments, either condition-specific or comprehensive, which appears on health IT framework roadmaps recently submitted to ONC.
This calls for, in part, an expansion of the voices and participating health IT firms within ONC standards and policy committees.
Detailed advisory specification comments
• CPT/HCPCS in combination – We seek clarity on the agency’s reasoning for the use of CPT/HCPCS in combination as a standard. If the advisory here implies there are different or better cases to use different types of HCPCS or different levels of CPT codes, we, and the industry, would welcome such designations. Overall we would refer to our above comment on ONC’s mission to pare down clear and concise standards matched with use cases.
• CPT/CDT – Here we simply believe ONC should internally address whether CPT/CDT should be both federally required – in itself a good thing – but also commercially licensed.
• Tobacco use – We recommend clarity in this designation as tobacco use is not solely concurrent with smoking status, and that an expansion of language is needed here to accommodate smokeless tobacco usage (chewing tobacco) and the growing use of electronic cigarettes and/or vaporized nicotine. We therefore believe that the current coding language ascribed to tobacco use as mature is in fact premature and should be addressed as such.
• BMI and vital signs – Here we recommend that BMI be included or considered as a vital sign to reconcile its inclusion in CCDA transmissions and more so its inclusion in the common clinical data set.
• FHIR – For the FHIR standard, we seek clarity on its designation for only certain listed content and structures. For example, we noted its exclusion as standard for receiving laboratory results. As FHIR is ostensibly a replacement for “older” HL7 standards, is ONC implying that for basic interoperability needs, such as receiving labs, FHIR is not yet ready or mature? We would also refer to our above comments on the need for care management and population health management use cases within the development or maturity of the much-anticipated FHIR standard.
• Behavioral Health – Here we are simply recommending that ONC begin to address standards for behavioral health data points. Behavioral health is to be included, for example, within CMS’ CPC+ incentive program through certification criterions adopted by Jan. 1, 2019, or year three of the CPC+ program, according to current program language.
• “Administrative/payment oriented interoperability purposes…” – We noted introductory language on the agency’s decision not to include “payer” transactions within the advisory, concerning cost/claims related 837/835 transactions, etc. We would note here that payers who are moving to value-based care models are also exchanging quality data using the Quality Reporting Document Architecture specification. Our point is that overall we believe ONC should address cost and claims transmissions, as again the aggregation of this data is part of the creation of a true longitudinal patient record insofar as the data is used for risk stratification and other analytics. We would also note that MACRA’s MIPS scoring track includes cost as a scoring pillar. Increasingly, ONC and CMS should combine its internal collaborations on data transmissions and standards to again anticipate how common or overlapping data is being used by health IT platforms and health system customers complying with increasingly sophisticated payment models. As MACRA, for example, seeks to include Medicaid, Medicare Advantage and commercial ACOs, and bring in more provider types as ECs such as therapists, psychologists, nutritionists, pathologists and nurses, ONC and CMS should increase its collaborations around health IT platforms, and ONC should define and require standards that eliminate legacy variations leading to integration challenges.
Thank you for this review and as we’ve noted in past and related comments to ONC, we are available to assist you in any capacity regarding market/sector advancements, health IT platforms and future rulemaking.
Phillip Burgher
Director of Data Platforms
Greg Fulton
Industry & Public Policy Lead
The Sequoia Project would like to submit the attached .xls file, based on the suggested template provided, for comment. Please contact Didi Davis at 865-671-1624 or ddavis@sequoiaproject.org with any questions.
We appreciate the opportunity to provide our feedback, which represents the perspective of researchers who are “secondary users” of clinical data. Specifically, we identify as researchers and information professionals who support “pragmatic clinical trials.” Pragmatic clinical trials (PCTs) are research investigations embedded in healthcare settings, with the goal of increasing the efficiency of research and relevance to clinical practice.
These comments represent the individual views of the authors. These comments do not necessarily represent the views of the NIH Health Care Systems Research Collaboratory, the NIH, Duke University, or other organizations and governmental entities collaborating in the development of the NIH Collaboratory and associated studies.
ACLA Comments included in the attached file.
Please see attached comments on the 2017 Interoperability Standards Advisory on behalf of the College of American Pathologists.
The Minnesota e-Health Initiative (the Initiative) is pleased to submit comments on the 2017 Interoperability Standards Advisory. The Initiative’s Advisory Committee is a 25-member legislatively-authorized committee appointed by the Commissioner of Health to build consensus on important e-health issues and advise on policy and common action needed to advance the Minnesota e-Health vision. The Advisory Committee is comprised of a diverse set of key Minnesota stakeholders, including consumers, providers, payers, public health professionals, vendors, informaticians, and researchers. The Initiative’s comments are informed by the experiences of the Advisory Committee, its workgroups and participants, the findings from the SIM-Minnesota work, and the Minnesota Department of Health, Office of Health Information Technology staff. More information on the Minnesota e-Health Initiative is at http://www.health.state.mn.us/e-health.
The Initiative recognizes the need to continually update the community on the most current standards and implementation specifications necessary to achieve interoperability. The Initiative supports community-developed standards through the Standards Developing Organizations that are responsive to the needs of providers across the care continuum.
We ask that the attached comments be considered for the current and future Interoperability Standards Advisory.
The Pharmacy HIT Collaborative has been working with several pharmacy organizations and other groups regarding the use of a structured coding system – SNOMED-CT – particularly for medication therapy management (MTM) services clinical documentation by pharmacists including Pharmacist eCare Plan Version 1.0: Guidance on the Use of the HL7 CDA Consolidated Templates for Clinical Notes R2.1 Care Plan http://www.ncpdp.org/NCPDP/media/pdf/Pharmacist-eCare-Plan.pdf.
According to National Council for Prescription Drug Programs (NCPDP) September 21, 2016 news release "WG10 Professional Pharmacy Services has developed the Pharmacist eCare Plan Version 1.0: Guidance on the Use of the HL7 CDA Consolidated Templates for Clinical Notes R2.1 Care Plan (as the topic Recommendations for Pharmacists on the Use of HL7 Consolidated CDA Templates) to enable pharmacists to capture their assessments of patient health status and health concerns, mutually defined patient care goals, recommendations, interventions and outcomes and to share them with other care providers, payers and the patient.
This NCPDP/HL7 harmonized standard is to support the CMS Innovation Center Medicare Part D Enhanced Medicare Therapy Management (MTM) program that starts on January 1, 2017. The development of the NCPDP Pharmacist eCare Plan C-CDA guidance document provides a roadmap to assist vendors in programming a mechanism to capture pharmacist-provided patient care services and share the data with providers and payers.
The eCare Plan is a standard the government and health plans are moving toward as a solution to collect electronic clinical data to validate provider services in transition of care, chronic care management and other value-based payment models. According to ONC, "to further validate the continued interoperability of certified health IT and the ability to exchange electronic health information with health IT certified to the 2014 Edition, 2015 Edition and potentially future editions, a new “transitions of care” certification criterion will rigorously assess a product's ability to create and receive an interoperable C-CDA".
Having a medication-related plan of care shared and incorporated with care plans developed by other care team members is critical to the overall success of patient’s reaching their proposed goals of care. The Pharmacist eCare Plan will provide for identification of resources for, and obstacles to, the patient’s compliance with the recommended treatment." http://ncpdp.org/NCPDP/media/pdf/UploadLinks/Pharmacist-eCare-Plan-Versi....
On behalf of the membership of the Pharmacy Health Information Technology Collaborative (Collaborative), we are pleased to submit comments regarding the proposed final 2017 Interoperability Standards Advisory.
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. The Collaborative is supportive of the proposed standards for clinical health IT interoperability purposes.
Pharmacists provide patient-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 HL7, SNOMED CT, LOINC, RxNorm, and NCPDP SCRIPT, and NCPDP Real Time Formulary and Benefits (currently under development). The Collaborative supports use of these particular standards which are important to pharmacists for allergy reactions, immunization historical and administered, immunization registry reporting, medications, medication allergies, patient problems, smoking status, reporting to public health agencies, clinical decision support services/knowledge artifacts, drug formulary checking, and electronic prescribing (including new versions).
As noted in our submitted comments on the Interoperability Standards Advisory tables, it is vitally important that pharmacists’ access to the proposed interoperability elements not be limited. Pharmacists, as health care providers, need the ability to query documents within/outside a specific health information exchange domain and clinical health information, as well as medication and immunization sharing. Pharmacists need to know the indications on medications relating to ICD-10 and SNOMED-CT.
Since the draft interoperability standards advisory was published, a change was made to one of the standards proposed for the vocabulary/codeset/ terminology. The federal Medical Terminology Group has changed NDF-RT to MED-RT. This change should be made throughout the standards advisory. Additionally, we recommend that the ONC keep abreast of the work being done by the National Library of Medicine in DailyMed regarding FDA structured product labeling (SPL) and UNI regarding food substances and environmental substances.
The following are our comments regarding one of the additional requests for feedback posed for the proposed final 2017 Interoperability Standards Advisory.
Section IV: Questions and Requests for Stakeholder Feedback
7. For subsection I-D: Functional Status/Disability, the Health Information Technology Standards Committee recommends using SNOMED®/LOINC® observation paring for this interoperability need. Do you support this approach?
The Collaborative supports the value sets of SNOMED-CT and LOINC. Additional information regarding value sets for these may be found at https://www.nlm.nih.gov/healthit/meaningful_use.html.
SNOMED-CT has been recognized as the leading clinical terminology standard used to document clinical care for many years. This terminology permits the capturing of clinical information and permits the codifying of patient care encounters in the EHR. Coupled with classification systems, such as ICD-10, incorporation of SNOMED-CT leads to interoperability of health information systems.
The Collaborative has been working with several pharmacy organizations and other groups regarding the use of a structured coding system – SNOMED-CT – particularly for medication therapy management (MTM) services clinical documentation by pharmacistsincluding Pharmacist eCare Plan Version 1.0: Guidance on the Use of the HL7 CDA Consolidated Templates for Clinical Notes R2.1 Care Plan http://www.ncpdp.org/NCPDP/media/pdf/Pharmacist-eCare-Plan.pdf. Included among the organizations with whom the Collaborative has been actively working in this regard are the Pharmacy Quality Alliance (PQA), National Library of Medicine, and our members including the Academy of Managed Care Pharmacy (AMCP), the National Council for Prescription Drug Programs (NCPDP).
We believe that the consistent use of structured universal codes is critical to the expansion of documentation of services, especially MTM, and support the use and implementation of SNOMED- CT codes for these services.
Overall, SNOMED-CT has the potential to create benefit for the patient and the greater health care environment, and again, the reason we encourage the use of SNOMED-CT codes.
*****
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
*****
On behalf of the Pharmacy HIT Collaborative, thank you again for the opportunity to comment on the final 2017 Interoperability Standards Advisory.
For more information, contact Shelly Spiro, Executive Director, Pharmacy HIT Collaborative, at shelly@pharmacyhit.org.
Respectfully submitted,
Shelly Spiro
Executive Director, Pharmacy HIT Collaborative
Shelly Spiro, RPh, FASCP
Executive Director
Pharmacy HIT Collaborative
shelly@pharmacyhit.org
Susan A. Cantrell, RPh, CAE
Chief Executive Officer
Academy of Managed Care Pharmacy
scantrell@amcp.org
Peter H. Vlasses, PharmD, DSc (Hon), BCPS, FCCP
Executive Director
Accreditation Council for Pharmacy
Education (ACPE)
pvlasses@acpe-accredit.org
Rylan Hanks, PharmD
Regulatory Intelligence
Global Regulatory and R&D Policy – Biosimilars
Amgen, Inc.
rhanks@amgen.com
William Lang, MPH
Senior Policy Advisor
American Association of Colleges of Pharmacy
wlang@aacp.org
C. Edwin Webb, Pharm.D., MPH
Associate Executive Director
American College of Clinical Pharmacy
ewebb@accp.com
Stacie S. Maass, BS Pharm, JD
Senior Vice President, Pharmacy Practice
and Government Affairs
American Pharmacists Association (APhA)
smaass@aphanet.org
Arnold E. Clayman, PD, FASCP
Vice President of Pharmacy Practice & Government Affairs
American Society of Consultant Pharmacists
Aclayman@ascp.com
Jillanne M. Schulte, JD
Director, Federal Regulatory Affairs
American Society of Health-System Pharmacists
jschulte@ashp.org
Tony Matessa
Cardinal Health - Commercial Technologies
Director, Product Marketing Lead
www.cardinalhealth.com/fuse
Rebecca Snead
Executive Vice President and CEO
National Alliance of State Pharmacy Associations
rsnead@naspa.us
Ronna B. Hauser, PharmD
Vice President, Pharmacy Affairs
National Community Pharmacists Association (NCPA)
ronna.hauser@ncpanet.org
Stephen Mullenix, RPh
Senior Vice President, Communications & Industry Relations
National Council for Prescription Drug Programs (NCPDP)
smullenix@ncpdp.org
Cynthia Kesteloot
Vice President of Operations
OutcomesMTM
ckesteloot@outcomesmtm.com
David Searle, RPh
Director, Pharmacy Development
Pfizer US Trade Group
David.w.searle@pfizer.com
Rita Russell, RPh
Senior Director, Relationship Management
RelayHealth Pharmacy Solutions
Rita.Russell@relayhealth.com
Ken Whittemore, Jr., RPh, MBA
Vice President, Professional & Regulatory Affairs
Surescripts
ken.whittemore@surescripts.com
On behalf of the membership of the Pharmacy Health Information Technology Collaborative (Collaborative), we are pleased to submit comments regarding the proposed final 2017 Interoperability Standards Advisory.
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. The Collaborative is supportive of the proposed standards for clinical health IT interoperability purposes.
Pharmacists provide patient-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 HL7, SNOMED CT, LOINC, RxNorm, and NCPDP SCRIPT, and NCPDP Real Time Formulary and Benefits (currently under development). The Collaborative supports use of these particular standards which are important to pharmacists for allergy reactions, immunization historical and administered, immunization registry reporting, medications, medication allergies, patient problems, smoking status, reporting to public health agencies, clinical decision support services/knowledge artifacts, drug formulary checking, and electronic prescribing (including new versions).
As noted in our submitted comments on the Interoperability Standards Advisory tables, it is vitally important that pharmacists’ access to the proposed interoperability elements not be limited. Pharmacists, as health care providers, need the ability to query documents within/outside a specific health information exchange domain and clinical health information, as well as medication and immunization sharing. Pharmacists need to know the indications on medications relating to ICD-10 and SNOMED-CT.
Since the draft interoperability standards advisory was published, a change was made to one of the standards proposed for the vocabulary/codeset/ terminology. The federal Medical Terminology Group has changed NDF-RT to MED-RT. This change should be made throughout the standards advisory. Additionally, we recommend that the ONC keep abreast of the work being done by the National Library of Medicine in DailyMed regarding FDA structured product labeling (SPL) and UNI regarding food substances and environmental substances.
The following are our comments regarding one of the additional requests for feedback posed for the proposed final 2017 Interoperability Standards Advisory.
Section IV: Questions and Requests for Stakeholder Feedback
7. For subsection I-D: Functional Status/Disability, the Health Information Technology Standards Committee recommends using SNOMED®/LOINC® observation paring for this interoperability need. Do you support this approach?
The Collaborative supports the value sets of SNOMED-CT and LOINC. Additional information regarding value sets for these may be found at https://www.nlm.nih.gov/healthit/meaningful_use.html.
SNOMED-CT has been recognized as the leading clinical terminology standard used to document clinical care for many years. This terminology permits the capturing of clinical information and permits the codifying of patient care encounters in the EHR. Coupled with classification systems, such as ICD-10, incorporation of SNOMED-CT leads to interoperability of health information systems.
The Collaborative has been working with several pharmacy organizations and other groups regarding the use of a structured coding system – SNOMED-CT – particularly for medication therapy management (MTM) services clinical documentation by pharmacists. Included among the organizations with whom the Collaborative has been actively working in this regard are the Pharmacy Quality Alliance (PQA), National Library of Medicine, and our members including the Academy of Managed Care Pharmacy (AMCP), the National Council for Prescription Drug Programs (NCPDP).
We believe that the consistent use of structured universal codes is critical to the expansion of documentation of services, especially MTM, and support the use and implementation of SNOMED- CT codes for these services.
Overall, SNOMED-CT has the potential to create benefit for the patient and the greater health care environment, and again, the reason we encourage the use of SNOMED-CT codes.
*****
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
*****
On behalf of the Pharmacy HIT Collaborative, thank you again for the opportunity to comment on the final 2017 Interoperability Standards Advisory.
For more information, contact Shelly Spiro, Executive Director, Pharmacy HIT Collaborative, at shelly@pharmacyhit.org.
Respectfully submitted,
Shelly Spiro
Executive Director, Pharmacy HIT Collaborative
Shelly Spiro, RPh, FASCP
Executive Director
Pharmacy HIT Collaborative
shelly@pharmacyhit.org
Susan A. Cantrell, RPh, CAE
Chief Executive Officer
Academy of Managed Care Pharmacy
scantrell@amcp.org
Peter H. Vlasses, PharmD, DSc (Hon), BCPS, FCCP
Executive Director
Accreditation Council for Pharmacy
Education (ACPE)
pvlasses@acpe-accredit.org
Rylan Hanks, PharmD
Regulatory Intelligence
Global Regulatory and R&D Policy – Biosimilars
Amgen, Inc.
rhanks@amgen.com
William Lang, MPH
Senior Policy Advisor
American Association of Colleges of Pharmacy
wlang@aacp.org
C. Edwin Webb, Pharm.D., MPH
Associate Executive Director
American College of Clinical Pharmacy
ewebb@accp.com
Stacie S. Maass, BS Pharm, JD
Senior Vice President, Pharmacy Practice
and Government Affairs
American Pharmacists Association (APhA)
smaass@aphanet.org
Arnold E. Clayman, PD, FASCP
Vice President of Pharmacy Practice & Government Affairs
American Society of Consultant Pharmacists
Aclayman@ascp.com
Jillanne M. Schulte, JD
Director, Federal Regulatory Affairs
American Society of Health-System Pharmacists
jschulte@ashp.org
Tony Matessa
Cardinal Health - Commercial Technologies
Director, Product Marketing Lead
www.cardinalhealth.com/fuse
Rebecca Snead
Executive Vice President and CEO
National Alliance of State Pharmacy Associations
rsnead@naspa.us
Ronna B. Hauser, PharmD
Vice President, Pharmacy Affairs
National Community Pharmacists Association (NCPA)
ronna.hauser@ncpanet.org
Stephen Mullenix, RPh
Senior Vice President, Communications & Industry Relations
National Council for Prescription Drug Programs (NCPDP)
smullenix@ncpdp.org
Cynthia Kesteloot
Vice President of Operations
OutcomesMTM
ckesteloot@outcomesmtm.com
David Searle, RPh
Director, Pharmacy Development
Pfizer US Trade Group
David.w.searle@pfizer.com
Rita Russell, RPh
Senior Director, Relationship Management
RelayHealth Pharmacy Solutions
Rita.Russell@relayhealth.com
Ken Whittemore, Jr., RPh, MBA
Vice President, Professional & Regulatory Affairs
Surescripts
ken.whittemore@surescripts.com
Please see the attached PDF for Epic's comments on the Draft 2017 Interoperability Standards Advisory.
Comments submitted on behalf of the Sequoia Project for standards used within the eHealth Exchange, Carequality and the RSNA Image Share Validation Program Initiative.