In an October 23rd letter to Dr. Vindell Washington, the National Coordinator for Health Information Technology at the Office of the National Coordinator (ONC), HIMSS submitted its comments in response to the 2017 Draft Interoperability Standards Advisory.
In leveraging our members’ expertise, HIMSS offers responses based on eight major themes in the comment cover letter. HIMSS applauds ONC on the focus on standards for electronic health information in the context of treatment, but recommends expanding standards to include secondary uses of clinical data, such as research. HIMSS proposes that ONC consider including stronger language in the ISA’s scope to direct users on the importance of implementing the standards outlined while still encouraging consideration of emerging standards that will lead to innovation. HIMSS highlights the importance of Data Provenance as an Interoperability Need, and asks ONC to conduct more research on how to appropriately capture and preserve details on the data source and systems that data passes through. As the volume and sources of data grow, HIMSS suggests that ONC identify standards for patient-generated health data and data originating from outside the clinical setting. HIMSS commends the use of LOINC and SNOMED-CT code system pairs within the Question and Answer paradigm but recognizes that challenges may arise when trying to implement LOINC for many questions as many EHR systems do not consistently use LOINC standards to encode questions within their data elements and fields. Throughout the ISA, many Interoperability Needs outlined more than one standard or specification. HIMSS suggests further clarification for implementers on the preferences for use of these multiple standards. Finally, HIMSS recommends aligning standards included in the ISA with those listed in the 2015 ONC Certification rule since those standards are federally required.
HIMSS’ final comments are available here.