It looks like the Office of the National Coordinator for Health IT's interoperability roadmap has already hit its first speed bump.
The Health IT Standards Committee's Interoperability Standards Advisory task force reported this week on the public comments received on ONC's 2015 Interoperability Standards Advisory, the first deliverable in support of the agency's national interoperability roadmap. The results do not appear promising.
According to ONC's website:
"The advisory is meant to provide the industry with a single, public list of the standards and implementation specifications that can best be used to achieve a specific clinical health information interoperability purpose and also to prompt dialogue, debate and consensus among industry stakeholders when more than one standard or implementation specification could be listed as the best available."
If the public comments are any indication, it looks like the advisory will certainly succeed on prompting dialogue and debate, but may fail on creating consensus and a single, specific set of standards and implementation specifications.
According to the task force, of the 59 comments received regarding the advisory, the only item that stakeholders agreed to was the need for strong privacy and security standards. Nothing else was consistent.
There were no consistent suggestions for characteristics of the standards and specifications. Seventeen commenters provided suggestions on what standards and specifications should be included, but they were not consistent with each other. Twenty-three commenters suggested new purposes in the advisory, but again none of them were consistent. There also was little consistency regarding which standards should be removed, what the advisory update process should be or criteria for what would be "best available." The commenters were even split about the advisory itself, with only 32 voicing support.
In addition, some of the comments were rather strongly worded, which creates even more dispute and dissent. For example, Gary Dickinson, Director of healthcare standards at CentriHealth, said in his comments:
"Another day, another instance where ONC's proposed rules/guidance seem(s) to offer no consideration--much less concern--for truth [authenticity] and trust [assurance] as baselines/foundations for what is proposed. This is particularly evident when health data/records must maintain fidelity to source data/record content and thus qualify to support primary use [clinical care, interventions and decision making]. We believe clinical integrity and most importantly, patient safety, are placed at risk by recommendations of this advisory."
Usually commenters have differing views on a proposed rule or other document. But this near total lack of agreement seems extreme.
And to make matters worse, the Centers for Medicare & Medicaid Services just released its latest proposed payment rule for 2016, for end stage renal disease facilities, which "encourages" them to adopt interoperable EHRs.
The rule puts such facilities on notice that they, like other providers, soon will need to use electronic health records and must share data electronically. This rule specifically references both the interoperability roadmap and the advisory, which the rule says "provides a list of the best available standards and implementation specifications to enable priority health information exchange functions.
"Providers, payers, and vendors are encouraged to take these 'best available standards' into account as they implement interoperable health information exchange across the continuum of care," the rule adds.
Interoperability is a priority item these days. But if there's no consistency regarding what the interoperability standards should be, how will anyone know what's the best available?
And when does "debate" move to "consensus?"
ONC will review the task force's recommendations and update the advisory later this year.
But if the advisory is meant to "provide clarity, consistency and predictability regarding the best standards and specifications for interoperability" as ONC says on its website, the agency has some work ahead. - Marla (@MarlaHirsch and @FierceHealthIT)