AHIMA Issues Comments on ONC’s Proposed Interoperability Framework

In late July, AHIMA submitted comments to the Office of the National Coordinator for Health IT (ONC) in response to the agency’s open comment period for its “Proposed Interoperability Standards Measurement Framework”—a guide that will evaluate the implementation and use of interoperability healthcare standards.

In a blog post outlining ONC’s objectives in releasing the framework and the agency’s solicitation of comments, Steve Posnack, MS, MHS, director of the office of standards and technology at ONC, wrote:

“ONC recognizes the critical role that health IT developers, health information exchange organizations, and health care organizations will need to play to develop an agreed upon set of measures to assess the implementation and use of standards. Accurate measurement will require strong support and participation from multiple health IT stakeholders. Your feedback will help us to engage and coordinate with stakeholders, especially those who may be in the best position to contribute data toward industry-wide measures.”

In its written response to ONC, AHIMA notes that while ONC’s document lists standards relevant to health information exchanges using certified electronic health record (EHR) technology, “providing the list of standards is not sufficient to achieving trusted information sharing.”

AHIMA believes instead that ONC should ask: “Do these standards get the provider ‘the right information, in the right form, in the right time’?”

ONC, AHIMA says, should be trying to identify “use cases”—or a set of specific scenarios to which standards can be applied.

“Because the needs of providers are case-specific, there is a need to reinstate in the US the basic computer science use-case driven approach—the foundational methodology for documenting user needs… We believe that the ONC Framework will benefit greatly from identifying/applying the use cases as specific examples for the measures of interoperability/information sharing via the means of HIT,” AHIMA writes.

One of the questions ONC’s document asks is: “Does the proposed measurement framework include the correct set of objectives, goals, and measurement areas to inform progress on whether the technical requirements are in place to support interoperability?”

In response, AHIMA proposed an alternative approach:

  1. Develop a US Interoperability Framework (see EU Framework as an example)
  2. Define US priority use cases
  3. Identify standards portfolios by use case and by framework components
  4. Develop conformance criteria for interoperability standards testing and implementation
  5. Develop the measures for interoperability based on approach stated in items 1-4 above

Click here to read AHIMA’s full comments.

Mary Butler is the associate editor at The Journal of AHIMA.

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