EHRA’s Advice to ONC on Information Blocking

In October, we provided comments to ONC on its April 2015 “Report on Health Information Blocking”, in the spirit of collaborating to establish an environment where the right data can flow to the right party at the right time using a set of agreed-upon standards.  While some press coverage characterized our comments as negative (“…Prove It”), we in fact attempted to provide balanced feedback, recognizing that the first challenge is to come up with a definition of “information blocking” that everyone agrees on.

We clarified that charging for interface software and services should not be considered information blocking, as there are real costs incurred by EHR developers and other health IT companies in building and maintaining interfaces.  In the EHRA response, we reiterated our support for a standards-based approach to connectivity which, over time, can reduce these costs.  But we also pointed out that there are a large number of stakeholders – e.g., public health agencies – which are not compelled to use the same standards; until they are, systemic costs will continue to be higher than necessary.

We find, based on review of the report and subsequent policy discussions, that the concept of “information blocking” is still very heterogeneous, mixing perception, descriptive, and normative issues in ways that are not easily untangled.  As a result, this concept and “label” does not provide a good basis yet for policy actions or enforcement, as it could encompass a broad range of actions, few of which are likely to warrant civil or other penalties.

EHRA has seen evidence that provider and patient demand for data exchange is growing, primarily driven by new payment and delivery models, as well as increased patient engagement.  Over time, as these new financial systems gain traction, this will reduce any perverse incentives to block information that may exist, and instead focus provider organizations and software developers more clearly on addressing current interoperability challenges.

Interoperability and data exchange require organizational, policy, legal, and technical infrastructure, with much of the infrastructure for information sharing actually existing outside of EHRs.  This infrastructure, we believe, should be supported by a mix of funding entities similar to other public infrastructure in this country, such as private sector and public/private data sharing and HIE initiatives.

We encourage our member companies to read and share the full EHRA response to ONC on this important report.  And if you have any further feedback, please share it with the Standards and Interoperability (S&I) Workgroup!

Charles Parisot (GE Healthcare IT), Chair, Standards & Interoperability Workgroup

Hans Buitendijk (Cerner), Vice Chair, Standards & Interoperability Workgroup

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