The USCDI Curation Process: Why Stratify?

By John Travis and members of the EHRA Information Blocking Task Force 

In our last blog on the United States Core Data for Interoperability (USCDI), the focus was on USCDI as the policy ground for advancing federal interests for promoting high impact needs for health data, and USCDI’s import as a certification specification impacting developers of Certified Health Information Technology (CHIT). In this blog, we focus on how the evolution and curation of USCDI impacts the efforts of health IT developers and implementers to “stay current.” 

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The Balance Challenge for Policy in Progressing the U.S. Core Data for Interoperability (USCDI)

By John Travis and members of the EHRA Information Blocking Task Force

 

With publication of the 21st Century Cures Act: Interoperability, Information Blocking , and ONC’s Certified Health IT program final rule (Cures Act Final Rule), the Office of the National Coordinator for Health IT (ONC) worked to implement important provisions of the 21st Century Cures Act (Cures Act) for nationwide interoperability. The initial proposal from ONC addressing the Trusted Exchange Framework and Cooperative Agreement (TEFCA), which was also required by the Cures Act, created a central role for the U.S. Core Data for Interoperability (USCDI) in federal health IT policy, and it is important to consider what that role will be in the national policy framework. Will the USCDI push the industry beyond where it would go on its own by being progressive in its version expansion? Will it affirm and codify an extension of the current state, adhering to a principle of expansion based on supporting pre-requisites of already established interoperability standards? Or something in between?

In recent deliberations of the USCDI Task Force of the Health Information Technology Advisory Committee (HITAC), the Federal Advisory Committee established under the Cures Act, this tension point has come to light. The members of the task force seem to have two perspectives on the matter. 

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Securing API-based Access to Patient Data

By EHRA Standards & Interoperability Workgroup

One of the goals of the 21st Century Cures Act’s health IT provisions was to enable patients to have secure access to their electronic health information using Application Programming Interfaces (APIs). The Office of the National Coordinator for Health IT (ONC) advanced that objective when it published its May 2020 Final Rule, which specifies HL7(R) FHIR(R)-based standards that health IT developers (as well as provider organizations developing their own solutions) will be expected to implement so that patient can access their health data using apps of their choice, connected to APIs. But how can patients be assured that their health information is secure once it leaves the EHR? 

Health data are among an individual’s most sensitive information, obligating all members of the healthcare community to protect patient privacy by ensuring secure data exchange. This blog post will review how the ONC standards for patient access can enable best practices to securely share patient health data.

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A Focus on Standards 

Screen Shot 2019-07-04 at 6.19.08 PMOn June 3, EHRA submitted feedback to ONC on its proposed rule, the  21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program. In this feedback, EHRA members drew on both their expertise as software developers and as contributors to standards work across the health IT industry. 

One theme of EHRA and other stakeholders’ feedback is that a focus on standards is critical. A particular standard proposed recently by ONC is the United States Core Data for Interoperability, or USCDI. USCDI “is a standardized set of health data classes and constituent data elements for nationwide, interoperable health information exchange” and includes important health data classes. 

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EHR Developers are Aligned with Goals of Cures NPRM, Hope ONC will Remove Ambiguity and Reassess Timeline

Screen Shot 2019-05-26 at 9.15.33 PMWe had been waiting for the Office of the National Coordinator for Health IT to release the proposed rule fulfilling its Cures Act obligation for quite a while. Encompassing important issues like expanded interoperability, defining what is and isn’t information blocking, as well as proposing updated certification requirements, this is an important rule to get right.

Since the release, there have been lots of discussions—public and private, online and off—about intended and potentially unintended impacts of the language in the proposal. With so much to consider and analyze, we appreciate that the request from EHRA and other groups to give us a full three months to draft our comments on the rule was approved.

The tremendously broad reach of the proposed rule goes far beyond Congressional intent.

The EHR Association’s comments are now going through final rounds of review by our executive committee (and the seven workgroups and task forces that contributed their expertise). We worked throughout the drafting of the 21st Century Cures Act with Congress and are supportive of its goal to remove obstacles to information exchange, but we have found that the tremendously broad reach of the proposed rule goes far beyond Congressional intent. In particular, we have significant concerns regarding timelines, ambiguous language, disincentives for innovation, and definitions related to information blocking.

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IPPS: Ambiguous Measures Won’t Reduce Burden

By Sasha TerMaat
Co-Chair, EHRA Executive Committee

man holding three white medication pills

The final 2019 IPPS rule included changes to the Promoting Interoperability/ Meaningful Use program beginning January 1, 2019. Disappointingly, with only six weeks between the close of the public comment period for the proposed rule in late June and the publication of the final rule in early August, CMS’ rushed process and failure to fully consider stakeholder comments (including EHRA’s) led to a rule filled with measures that will be unworkable, inefficient, and onerous.

In a previous blog we delved into PDMP query as just one of the measures where EHR developers anticipate challenges. In that case it’s due to differing levels of PDMP integration with CEHRT and inconsistent references within the rule about whether the query needs to be made via CEHRT, along with other areas in which the measure is ambiguous.  

In this blog post, let’s look at the reasons we’re concerned about a different measure, this one related to opioid treatment agreements.

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