Sunday, January 16, 2011

PCAST Report on Health Information Technology Request for Comment

I am preparing to submit comments 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," which provides recommendations for using health IT to facilitate the real-time exchange of patient information.

PCAST is an advisory group of the nation’s leading scientists and engineers who directly advise the President and the Executive Office of the President. PCAST makes policy recommendations in the many areas where understanding of science, technology, and innovation is key to strengthening our economy and forming policy that works for the American people. PCAST is administered by the Office of Science and Technology Policy (OSTP). PCAST’s report and its recommendations have significant implications for the nation’s HIT agenda and the implementation of the HITECH Act. ONC seeks public comment on the PCAST report’s vision and recommendations and how they may be best addressed.

ONC is seeking comments on certain aspects of the PCAST report. The Deadline Has Been Extended: Comments will be accepted through and by mail through January 19, 2011. You can review the Federal Register notice of this Request for Information and submit comments here.

ONC is seeking comment on the questions below. Comments on other aspects of the PCAST report are also welcome.
  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:
    a. That ONC establish minimal standards for the metadata associated with tagged data elements;              
    b. That ONC facilitate the rapid mapping of existing semantic taxonomies into tagged data elements;
    c. That certification of EHR technology and other HIT should focus on interoperability with reference implementations developed by ONC.
  2. What processes and approaches would facilitate the rapid development and use of these standards, implementation specifications, certification criteria and certification processes?
  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?
    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?
    b. Alternatively, what are proposed solutions, or best practices from other industries, that could be leveraged to expedite these transitions?
  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?
  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?
  6. How might ONC best integrate the changes envisioned by the PCAST report into its work in preparation for Stage 2 of Meaningful Use?
  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?
  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?
For additional background you can read the PCAST Press Release released by the Whitehouse on December 8, 2010. You can also watch the video from the announcement of the report.


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