ONC Report Card

Now that their work is done for 2009 I thought it would be fun to grade the Office of the National Coordinator. It has been a very exciting year in health IT, with a cliff hanger right down to the wire on meeting the statutory requirement for publishing a proposed rule to define Meaningful Use criteria and and an interim final rule on Standards, Implementation Specifications, and Certification Criteria. For getting these rules out for comment before the years end, I give the ONC a solid B- overall (I consider myself a reasonably hard grader). I have some categories below, but would be very interested in any feedback you might have.

• Privacy and Security -
  
  The HIT Standard Committee made some excellent recommendations in September on privacy and security. Also in December the ONC announced the creation of a new Chief Privacy Office and the Office of Economic Modeling and Analysis (among three others including the Office of Chief Scientist, Deputy National Coordinator for Programs & Policy, and Deputy National Coordinator for Operations). This reorganization and good recommendations give a strong B in this area. This is only a a start and they have been at it for less than a year, so I am being generous.

• Meaningful Use -
  
  Since the rule has been posted before the end of the year, and considering all the hard work this has taken this is definitely an A for effort. Unfortunately, the 60 day comment period begins January 13, 2010 (after Federal Register publication) and there still appears to be a long way to go. However, I would give an overall B+ for the work so far, with a big question mark as to what will happen in the our years with a phased approach to defining the criteria.

• Transparency -
  
  This is an area that I am keenly interested in. I am very pleased that the ONC has made a strong commitment to transparency for 2010, but I will need to see results before giving a much higher grade. For now: a D!

• Standards and Certification -
  
  The HIT Standards Committee has done outstanding work in 2009! Reading this transmittal letter of their recommendations will give an inkling of the incredible work this body has accomplished. There is still a lot do in the coming year, but I would give an A- in this area...

• National Health Information Network (Health Internet) -
  
  This is an area that has not had much in the way of tangible results yet, and will be critical to succeed if we are to see the goals of health IT come to fruition. The NHIN Work Group of the HIT Policy Committee has made some progress charting a way forward, and the Federal Health Architecture e-government line of business initiative has been working for years towards an interoperable future, I can not grade on hopes for future success. So far, based on the framework being developed I feel comfortable giving a C.

Taking all of these in consideration, and weighting them based on my feelings at the moment (plus the feeling that grades C-level or below are unacceptable), I feel that a B- is really the best I can give right now. Being the eternal optimist I am hoping that things will improve significantly in 2010.