True to its word, the Office of the National Coordinator for Health IT is moving at full steam to provide governance support to health information organizations (HIOs) to spur the industry to widespread electronic data exchange.
ONC has formed a governance framework with business, trust and other principles to create a "common foundation" for all types of health information exchange governance models. It has awarded grant money to entities to develop governance policies and interoperability requirements. Just last week, it outlined pilot programs to test electronic queries and created a forum so HIEs can come together to swap ideas and share best practices.
These initiatives are in response to ONC's decision to provide voluntary guidance, rather than imposing a particular governance structure on HIEs. This decision was made so that ONC wouldn't hobble existing efforts being made by HIEs. There probably was also some pushback from organizations that resisted yet another heavy handed regulation from the government telling the healthcare industry what to do.
All very good.
Still, I wonder if this decision ultimately may come back to haunt the industry. Is all of this flexibility and variability the best way to achieve interoperability? Internal governance flexibility--profit vs. nonprofit, different provider data use agreements--may be fine, but if the HIEs make different decisions about how to provide data sharing? Will the electronic exchange operate smoothly? Will it operate at all? And is it more complicated--and more expensive--if each HIE is given too much governance leeway?
For example, look at the recently released guidance on key considerations for HIOs supporting the Meaningful Use Stage 2 Transition of Care measure 2, which requires 10 percent of referrals by providers to be sent electronically. The guidance outlines six different options HIOs can choose from to govern how they will satisfy the measure. If HIOs have several options for each measure, the variability among HIOs will be astronomical.
Is this level of variability too much of a good thing?
The scenario reminds me of problems that have arisen from the lack of standardization of EHR products themselves. Sure, EHR systems need to be certified to be part of the Meaningful Use program, which provides a level floor for the systems, but the variability of the products has made them harder to use and hampered interoperability. If there had been less variability allowed then, perhaps data sharing would be easier now.
Arguably, lack of standardization of EHRs occurred in part because EHRs existed before the Meaningful Use program required that they be adopted. Vendors already were headed down different design paths.
But HIE is a new animal. Should the industry allow fewer governance options to ensure that we're all on the same page? Or are ONC's actions good enough? A number of stakeholders have requested more "top down" HIE governance guidance. They may be on to something. Perhaps the government "frame" should be a little less pliant and a little more sturdy. - Marla (@MarlaHirsch)