Comments on PCAST Report on Health IT

I submitted the comments below on the President’s Council of Advisors on Science and Technology (PCAST) report, "Realizing the Full Potential of Health Information Technology to Improve Healthcare for Americans: The Path Forward."

1. What standards, implementation specifications, certification criteria, and certification processes for electronic health record (EHR) technology and other HIT would be required to implement the following specific recommendations from the PCAST report:
   

   ONC should view the PCAST report in light of previously considered elements of standardization and interoperability, while maintaining the flexibility to pivot towards the reports recommendations. ONC projects and the EHR Incentive Program may need to be retooled to help incorporate the idea of a Universal Healthcare Data Exchange Language.

   a. That ONC establish minimal standards for the metadata associated with tagged data elements;
   

   Establishing minimal standards for metadata associated with tagged elements is an important first step. Moving frmo minimal standards to a deeper level of comprehensive standards should be done in a measured way, considering the difficulties that healthcare organizations will face in staffing and funding efforts to adopt solutions.

   b. That ONC facilitate the rapid mapping of existing semantic taxonomies into tagged data elements;
   

   The rapid mapping of existing semantic taxonomies into tagged data elements will be key to the evolution of this language. Any new semantic taxonomies necessary should be simple and straightforward to provide vendors and clinicians with a clear path towards adoption. There is no need to reinvent the wheel were existing efforts have produced working code.

   c. That certification of EHR technology and other HIT should focus on interoperability with reference implementations developed by ONC.

I believe the Direct Project has shown a working model for reference implementations that could be used in these efforts.

2. What processes and approaches would facilitate the rapid development and use of these standards, implementation specifications, certification criteria and certification processes?

While still using the SHARP and BEACON projects to provide examples for development, opening up the process to other interested groups will help crowd source good ideas. Creating implementation geographies similar to those being used in the Direct Project would work well.

3. Given currently implemented information technology (IT) architectures and enterprises, what challenges will the industry face with respect to transitioning to the approach discussed in the PCAST report?
   

   Vendors will need very clear signals on any new certification criteria that will allow them the necessary time to implement these capabilities into their EHR systems.

   a. Given currently implemented provider workflows, what are some challenges to populating the metadata that may be necessary to implement the approach discussed in the PCAST report?
   

   Capturing the data that will populate these fields will be a significant challenge for providers. Embedding requirements into later stages of meaningful use will be an important policy lever to help drive clinical workflow transformation.

   b. Alternatively, what are proposed solutions, or best practices from other industries, that could be leveraged to expedite these transitions?

While not a perfect analogy, some of the experience from the financial industry could be applied to transforming healthcare and the way that information is securely addressed, routed and exchanged. The open source community could be a strong example of using a collaborative approach to solving many of these issues.

4. What technological developments and policy actions would be required to assure the privacy and security of health data in a national infrastructure for HIT that embodies the PCAST vision and recommendations?

In order for rapid evolution of taxonomies to take place, I suggest using a phased approach to incorporating the PCAST recommendations into the national architecture.

5. How might a system of Data Element Access Services (DEAS), as described in the report, be established, and what role should the Federal government assume in the oversight and/or governance of such a system?

DEAS governance should be handled through public/private collaboration, much like the development of the Internet itself.

6. How might ONC best integrate the changes envisioned by the PCAST report into its work in preparation for Stage 2 of Meaningful Use?

As rapid development of standards occurs there must be a sharp eye kept for opportunities to include these into certification criteria for stage 2 and stage 3 meaningful use. However, there needs to be sufficient time for vendors to incorporate the standards and clinicans to change clinical workflow.

7. What are the implications of the PCAST report on HIT programs and activities, specifically, health information exchange and Federal agency activities, and how could ONC address those implications?

A system of DEAS should be included in state plans for health information exchange. Like provider directories, these systems will need to be incorporated early into state, regional and national infrastructure planning.

8. Are there lessons learned regarding metadata tagging in other industries that ONC should be aware of?
9. Are there lessons learned from initiatives to establish information sharing languages ("universal languages") in other sectors?

Comment Tracking Number: 80bce1cf