Proposed Interoperability Standards Measurement Framework Public Comments

Attached are HL7's comments on the Office of the National CoordinatorÕs (ONC) Request for Information regarding a proposed Interoperability Standards Measurement Framework.

Please see the Comments from the DirectTrust Clinicians Steering Group attached.

Please see attached.

To the Office of the National Coordinator,
The New York City Department of Health and Mental Hygiene (DOHMH) appreciates the opportunity to comment on ONCÕs Proposed Interoperability
Standards Measurement Framework. Our commentary is attached.

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 frameworkÕs goal of measuring nationwide interoperability progress.

As we noted in previously submitted comments regarding the ONCÕs 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 pharmacistsÕ access to proposed interoperability elements not be limited; a current barrier needs to be resolved, particularly with regard to the ONCÕs 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 ONCÕs 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 CollaborativeÕs vision and mission are to assure the nationÕs 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 CollaborativeÕs founding organizations represent pharmacists in all patient care settings and other facets of pharmacy, including pharmacy education and pharmacy education accreditation. The CollaborativeÕs 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 pharmacistsÕ services. For additional information, visit www.pharmacyhit.org

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 clinicianÕs 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.

Please see the attached letter from ANI and ANA

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 ONCÕs 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 TechnologyÕs (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 nationÕs 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 ONCÕs 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.
APTAÕs 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.

Sincerely,

Sharon L. Dunn PT, PhD, OCS
President

SLD: kg

Attached please find Health IT Now's comments on the Standards Measurement Framework.

Please see comments offered by UnitedHealth Group in the attached letter.