By Stephanie Jamison (Greenway Health), Chair, and William Hayes, M.D. (Trubridge), Vice Chair, EHR Association

With its Draft 2024-2030 Federal Health IT Strategic Plan, ONC seeks to enhance individual and community health through improved healthcare experiences, advanced research and innovation, and integrated health data systems – important goals the EHR Association finds commendable provided the path taken to achieve them is paved with realistic expectations and timelines for regulations targeting them.

In many ways, the mission and vision laid out by ONC in its strategic plan echoes the objectives of our member companies; namely, advancing the quality and efficiency of care through innovative, interoperable health IT adoption and use. However, our enthusiastic support is tempered by concerns over the potential for too-aggressive compliance timelines and expectations that are beyond the reach of EHR and other health IT developers and the provider organizations utilizing these tools – concerns we shared in our response to ONC’s call for feedback on the Draft Federal Health IT Strategic Plan. 

Standards and Interoperability

A nationwide health data exchange ecosystem requires policymakers and industry leaders to focus on the continuous development and adoption of robust standards, implementation guides, and testing tools., Future innovation requires establishing and advancing baseline standards that ensure broad data access and support the development of additional data exchange mechanisms. As such, we:

• Support the Strategic Plan’s goal to enhance care delivery through improved interoperability and adoption of national standards such as HL7 FHIR. 
• Remain committed to collaborating with the ONC as it further defines and expands TEFCA, including a focus on aligning other data-sharing networks with it.

Privacy and Security

EHR technology is pivotal in safeguarding the privacy and security of patient health data, particularly within an increasingly connected health IT ecosystem. Our members are dedicated to developing and implementing software, services, and business practices to maintain patient privacy through secure data handling. We also advocate for stringent controls on using, disclosing, and selling identifiable patient data. 

Advancing technologies to protect and secure EHR requires a collaborative approach between industry and government. It should include establishing guidelines that balance innovation with risk management while emphasizing transparency and non-discrimination.

Advancing technologies to protect and secure EHR requires a collaborative approach between industry and government. It should include establishing guidelines that balance innovation with risk management while emphasizing transparency and non-discrimination. To that end, we:

• Support the Plan’s strategy to provide guidance and resources to help healthcare organizations integrate high-impact cybersecurity practices, such as the NIST Cybersecurity Framework.
• Suggest it’s critical to modernize data protection laws to extend HIPAA-like protections to all entities holding identifiable health data, regardless of their current regulation under HIPAA. 
• Support simplifying consent processes and aligning local privacy rules to reduce the complexity and inconsistency currently challenging data stewards and patients, including creating clear criteria for informed consent and setting boundaries for the permissible use of health information. 

Patient Safety and Quality of Care

The EHR Association supports the active involvement of all stakeholders in patient safety initiatives as each contributes a unique and valuable perspective. It’s why we remain committed to enhancing patient safety through:

• Standards-based product design
• Collaborative health IT-related patient safety event analysis
• Sharing best practices for the deployment and maintenance of health IT. 

We also seek to facilitate client and patient reporting of safety issues and to promptly address software problems that could impact patient safety while promoting a culture of safety within health IT organizations.

Health Equity and Access

As the primary systems of record and the agents of interoperability, EHRs are well-positioned to introduce front-line tools to combat disparities in care. However, those tools must work in conjunction with a larger socio-technical environment that reduces stigma and mistrust around data collection; adequately funds healthcare systems and community-based organizations that must partner to address disparities; and prioritizes safe, effective, and standards-based sharing of this information. 

As the primary systems of record and the agents of interoperability, EHRs are well-positioned to introduce front-line tools to combat disparities in care.

As such, the EHR Association:

• Supports the Plan’s emphasis on increasing health equity across all populations by advancing the use of data to represent social needs and the conditions in which people live, learn, work, and play.
• Recommends an approach to capturing social determinants that standardizes high-level domains and allows flexibility in how individual organizations assess risk.

We also support policies to expand access to quality care and reduce or eliminate health disparities. This includes funding for technologies that enable the digital delivery of healthcare in underserved areas, the standardization of electronic referrals to community-based organizations, and permanent Medicare telehealth reimbursement free from artificial barriers such as in-person visit requirements and geographic restrictions.

The EHR Association remains committed to collaborating with ONC and other stakeholders to strengthen the ethical and equitable design, implementation, and use of health IT that serves all populations. Together, we can achieve our vision of a healthcare ecosystem that leverages the capabilities of EHRs and other health IT to efficiently deliver higher-quality care to patients in a productive and sustainable manner.

Read our full comment letter to ONC here.