The Office of the National Coordinator for Health IT has received a large number of comments on its draft interoperability road map. Some commenters have praised it; others have offered criticisms.
Yet, we can't ignore that ONC is not alone at the interoperability drawing board. Both the CommonWell Health Alliance and Carequality, Healtheway's interoperability initiative, are forging ahead with their own initiatives. There also are the health information exchanges, with their different rules, operating models and governance structures.
Micky Tripathi, CEO of the Massachusetts eHealth Collaborative, remarked during this week's Health IT Policy Committee meeting that the different data sharing arrangements--including CommonWell and Healtheway--have been resolving issues in different ways. These different approaches could be a challenge to interoperability if they don't mesh together.
But the biggest barrier to interoperability may be the inability to match a patient's records. And that takes us to the great Congressional interoperability disconnect.
Congress has blasted ONC about the lack of interoperability between provider EHRs on several occasions; one legislator called it a "fraud" on taxpayers. The Omnibus bill, passed in December, requires ONC to submit a report regarding interoperability challenges and on those who engage in "information blocking."
But Congress, for years, has engaged in its own form of information blocking, placing roadblocks in the path of the U.S. Department of Health and Human Services to explore the use of a unique patient identifier to match patient records to the correct patient.
It's like Congress is talking from both sides of its mouth.
Let's take a deeper dive into the unique patient identifier. A number of commenters on ONC's interoperability roadmap recommend that unique patient identifiers be used to match patient records. It's not the first time that identifiers have been recommended.
In fact, we were supposed to have unique patient identifiers. When HIPAA was enacted 19 years ago, it required a unique patient identifier, as well as a unique provider number, unique employer number and unique health plan number. We have the other numbers, but 15 years ago, then-Rep. Ron Paul nixed the patient identifier, prohibiting not only the identifier itself, but the use of HHS funds to even test one. The current Omnibus bill--the same one ordering ONC to address information blockers--prohibits HHS from using funds to provide unique patient identifiers "until legislation is enacted specifically approving the standard."
This is in the same section of the Omnibus bill that prohibits use of HHS funds for creation of human embryos for research or for disseminating information that is deliberately false or misleading.
Wow. That unique patient identifier must be really bad.
Jodi Daniel, ONC's director of policy and planning, also speaking at this week's Health IT Policy Committee meeting, revealed her position on the identifier, saying that if Congress changes its position against patient identifiers, that HHS would move forward, saying "we stand by the ready."
I understand the patient identifier wouldn't solve some of the other issues surrounding interoperability, such as infrastructure or consent. I also understand opposition to the unique patient identifier stems in large part from privacy and security worries.
But it's pretty obvious that patient records aren't safe now without one. I'm not sure that a unique patient identifier would be worse than the social security number, and we all have that.
If it's at least an option on the table, it could be considered.