By David Bucciferro, Chair, EHR Association

In other installments of this five-part blog series on the EHR Association’s issues with ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), we discussed our overarching concerns, as well as concerns with the Insights Condition program, transition to USCDI v3, and Patient Requested Restrictions. In this installment, we examine the considerable issues we have identified with provisions related to Decision Support Interventions (DSI) and Predictive Models.

According to ONC, the existing scope and structure of the Health IT Certification Program are to enhance transparency around predictive decision support, with requirements to make transparent information regarding the authorship, bibliographic, and other kinds of “source attribute” information for evidence-based decision support and linked referential interventions. Noting that AI/ML in healthcare “is often best considered a form of decision support or ‘augmented intelligence’,” ONC says its goal with the proposed rule related to DSI and predictive models is to update the existing decision support criterion to directly include predictive decision support, inclusive of ML technologies.