It’s that time of year again. The Office of the National Coordinator for Health IT has published the latest version of its Interoperability Standards Advisory for public comment.
The advisory is a “key element” of ONC’s national interoperability roadmap and the agency's first deliverable for it. According to ONC’s website, the advisory process “represents the model by which [ONC] will coordinate the identification, assessment and public awareness of interoperability standards and implementation specifications that can be used by industry to fulfill specific clinical health IT interoperability needs.”
The first advisory was published in 2015, and has been updated each year. The biggest changes from the 2016 version to the 2017 draft are largely related to the Advisory’s content and framing. These include:
- The beginning of the transition of the advisory from a standalone document to an interactive,web-based resource
- Discontinued use of the label “best available” in order to be more inclusive
- Links to active projects listed in ONC’s “interoperability proving ground”
- Better representation of pairing of standards for observations (questions) and observation values (answers)
The 2017 draft also revises the language of several of the six informative characteristics of interoperability standards, which were introduced last year (standards process maturity, implementation maturity, adoption level, federal requirement status, cost and test tool availability).
In a related blog post, ONC leaders state that the advisory “directly supports the interoperability commitments that leading health IT developers, providers, and professional associations and stakeholder groups made earlier this year to adopt ‘federally recognized, national interoperability standards, policies, guidance, and practices for electronic health information.’ ... [B]y providing the industry with a single, public list of the standards and implementation specifications that can be consistently used to fulfill specific clinical interoperability needs, we hope to spur more seamless and secure flow of information across the health system.”
The advisory clearly represents a lot of hard work. But it also raises several questions. Notably:
- Why is it hard to locate? While aspects of the advisory and its processes are public, the advisory itself buried in ONC’s website unless you have access to a direct link from ONC’s email announcement or blog post. It’s on the website under “policy researchers & implementers.” Then viewers must go to the interoperability tab, and then search under standards acceleration. The advisory is mentioned at the bottom of that page.
- Does the development process work well? And is updating annually, with a draft issued each summer and a final version at the end of the year, too frequent for stakeholders to digest and implement, or not frequent enough to keep up with new developments?
- Is the advisory itself helpful? At least one organization has complained that it isn’t detailed enough. Is that a common concern? Has that been sufficiently addressed?
- What feedback has ONC received and how is it been incorporated? ONC says that it takes the feedback it receives into consideration, and the 2017 draft Advisory lists in the appendix some general comments and responses to those requiring additional consideration. However, that sounds like a representative sample of the comments, not a full picture. Can one view all of the comments, as one can with comments on a proposed rule? And does ONC respond to all comments, as agencies do in final rules?
- I anyone is using the advisory to further interoperability? If so, who, and in what way? Are entities working on data exchange, such as CareQuality, embracing the guidance in the advisory? Are health information exchanges and EHR developers turning to it? Are the organizations that pledged earlier this year to work on data exchange relying on it? It’s certainly possible, but if so why aren’t we hearing about that? And if they are, which aspects are most useful?
- If people aren’t using the advisory, then what is its utility? Is it a must-have tool or an academic exercise? Should ONC keep at it or turn its resources to other priorities?