The organizations voiced their concerns and praise in comments to the ONC on the agency’s draft Trusted Exchange Framework, released earlier this year in accordance with the 21st Century Cures Act.
The framework outlines principles for promoting nationwide interoperability and data sharing, including using federally recognized standards and transparently exchanging information. The ONC also plans to tap a private-sector organization—a “recognized coordinating entity”—to drive greater interoperability among health information networks.
Some organizations praised the ONC for the draft documents, saying they set the industry on a path toward greater interoperability. Specifically, they appreciated the notion of a “single on-ramp” for data exchange through which a single network opens up broader data exchange from other networks.
“The overall direction is appropriate and consistent with the objectives of the 21st Century Cures Act,” wrote Tom Nickels, the American Hospital Association’s executive vice president for government relations and public policy.
But there’s still room for improvement. The AHA wondered how health information networks would manage patient consent documents, which they’re required to keep.
Patient consent for data sharing was a point of contention for many organizations. The ONC needs to clarify the details of how such content would work, since it’s not clear whether patients would know which health information networks include their data, wrote Wylecia Wiggs Harris, CEO of the American Health Information Management Association. What’s more, the ONC should clarify what happens across these networks when consent is revoked from just one, Harris wrote.
One solution to managing patient consent could be third-party applications, according to the CARIN Alliance. “The ONC should support common, open standard approaches for how consumers and their authorized caregivers can digitally request access to their health information via an application or third-party data store of their own choosing,” wrote Ryan Howells, a convener of the alliance and principal at Leavitt Partners.
Consent is just one of many processes that need to be worked out. Matching patients to their data is another. The ONC should get expert input about patient identification and data matching and then edit the framework’s data-matching provisions accordingly, wrote Russell Branzell, CEO of the College of Healthcare Information Management Executives, and Cletis Earle, who chairs the organization’s board of trustees and is chief information officer at Kaleida Health.
“It is important to emphasize that integrity goes beyond just patient matching and making sure that the patient data is up to date prior to exchange,” wrote Healthcare Information and Management Systems Society CEO Harold Wolf and Denise Hines, a HIMSS board member. “From an information assurance perspective, integrity means that the data are not tampered with, nor modified, without authorization.”
Achieving all that the framework calls for may be more work than the industry can handle in such a short time, according to CHIME. The organizations is concerned that the framework is too far-reaching and that it may therefore be “too much for the industry to digest, especially in such a short time frame.” As such, CHIME representatives asked the ONC to lengthen the timeline, as did Stephanie Zaremba, director of government affairs for Athenahealth.
The EHR vendor criticized the ONC for drafting too prescriptive a framework and warned the ONC against too much regulation.
In addition to limiting regulation, Zaremba also suggested that the ONC ease its limitations on what kind of organization can be considered a qualified health information network. EHR vendors, for instance, should be able to be considered those kinds of networks, she argued.
Sasha TerMaat, a director at Epic Systems Corp., agreed. Letting vendors be qualified health information networks would help their users join the framework, she wrote.
But that’s not the only problem those at Epic had with the framework. As is, the framework “will slow current progress and will add significant cost to interoperability,” TerMaat wrote.
Because of how many changes are necessary, she and others asked the ONC to have another comment period on the framework before it’s finalized.
That won’t happen, exactly, said the ONC’s Genevieve Morris during the second meeting of the Health Information Technology Advisory Committee Wednesday. But the ONC does plan to get comments on the draft common agreement, which complements the framework, after it chooses a recognized coordinating entity and creates the agreement.