Industry groups basically support a measurement framework for healthcareinteroperability standards proposed by the Office of the National Coordinator for Health Information Technology or ONC plan, although they differ on whether a voluntary industry-based measure reporting system is the best path forward.
Release in April, ONC’s draft framework is meant to help developers, health information exchange organizations and providers move toward a set of industry-wide measures to assess the implementation and use of interoperability standards. The agency’s public comment period on the framework ended on Monday.
Both the American Medical Informatics Association and Health IT Now submitted comments to ONC plan supporting the development of a framework for reaching consensus on such measures, which they see as critical for measuring progress being made on achieving nationwide interoperability.
“We consider that several significant policy queries would be informed by data collected as part of such a measurement framework, as well as provide a window into our progress toward nationwide interoperability,” states AMIA CEO Doug Fridsma in his organization’s letter to the agency. “For example, as the industry moves from local coding for laboratory results to LOINC, away from a legacy set of standards based on the Consolidated Clinical Document Architecture (CCDA) towards a Fast Health Interoperability Resources (FHIR)-based ecosystem, it will be important to understand the details of this transition.”
Likewise, in its letter to ONC, Health IT Now points out that the Medicare Access and CHIP Reauthorization Act (MACRA) requires widespread interoperability by the day of Dec. 31, 2018.
“Measuring interoperability is essential to comprehend how much progress is being made against this goal,” writes HITN Executive Director Joel White. “Measurement can thus be a tool to help advance interoperable systems, information exchange, and the use of data in improving care.”
Presently, quantifiable data regarding the implementation and utilization of standards is often not readily available or regularly tracked. In its proposed framework, ONC identifies two key measurement areas: tracking whether interoperability standards are contained in health IT products and services, and the use of standards—including customization of the standards—by end users such as providers.
While AMIA explains the agency’s draft framework as “thoughtful” and rightly recognizing current gaps, challenges and opportunities, Fridsma in his letter underscores the need to have the “benefits of measurement outweigh the costs,” particularly with measure reporting becoming more automated.
“As the work moves forward, we emphasize ONC to be very mindful of the potential burdens associated with additional measurement and to carefully balance the burdens of measurement with expected benefits,” contends Fridsma. “As the field moves from surveys to more automated reporting, we urge ONC plan to focus on guidance to industry on what may be used in voluntary and optional automated data collection before there is any definitive shift from surveys to automated collection. It is essential that measurement not become an end in-and-of-itself and that we recognize the charges to clinicians, developers and others in developing and implementing automated solutions.”
At the same time, on the query of whether a voluntary, industry-based measure reporting system is the best means to implement ONC’s framework, Fridsma says that AMIA does not anticipate that widespread industry participation will occur based on a strictly volunteer basis.
“Ideally, the reporting system creates a high ratio of value/burden,” in accordance with the Fridsma. “Moreover, if reporting is convenient, then we expect higher rates of participation with a decreased need for strong incentives. However, if the accumulation of value is not shared among those being measured, or reporting is not easy, we anticipate that incentives will be necessary to encourage participation in the reporting system and we suggest a focus on positive incentives.”
Although, HITN’s White makes the case that a voluntary, industry-based measure reporting system is the best way to implement the framework, as opposed to a mandated reporting system, adding that the “barriers to interoperability can best be solved by private-market developed standards and initiatives” given that “government involvement in the quest to reach interoperability has mostly fallen flat and, in some cases, impeded progress.”
White also highlights the fact that—like ONC—the National Quality Forum has proposed its own interoperability measurement framework.
“ONC plan has been working to establish the Proposed Interoperability Standards Measurement Framework and the NQF’s Interoperability Committee (with funding from HHS) has been working independently to establish interoperability measurement frameworks,” he concludes. “NQF and ONC plan should clarify their roles in this process to avoid confusion about the several frameworks and their interaction moving forward.”