Halamka's Report on the May 2015 HIT Standards Committee Meeting

The May 2015 HIT Standards Committee focused on an in depth review of the ONC Notice of Proposed Rulemaking, with the goal of providing guidance to ONC by June as to which standards should be included in final rule, which should not be included, and which should be identified as directionally appropriate for inclusion in future regulation.

The meeting began with the ONC announcement that the HITSC workgroups would be disbanded in June and replaced by focused task forces.

We agreed that focused task forces have been successful in the past, but a better process for organizational change would be for ONC to provide a set of goals/requirements and then engage the members of the committee in a discussion of the structure that optimally supports the strategy.

We recently redesigned the workgroups and at present, committee members are not sure what problem is solved by changing the way we work. As Petronius Arbiter said in 27 A.D., we have to avoid change purely for the sake of change as this creates frustration

“We trained hard—but it seemed that every time we were beginning to form up into teams we were reorganized. I was to learn later in life that we tend to meet any new situation by reorganizing, and what a wonderful method it can be for creating the illusion of progress while actually producing confusion, inefficiency, and demoralization.”

As a next step, I hope ONC follows the guidance of John Kotter in the management of change - build a vision, create a guiding coalition, convey an urgency to change, empower people to initiate the change, and sustain the change. We will await word from ONC on the focus areas that will receive more agile guidance with a change in the HITSC structure.

For example, if the barriers to interoperability are lack of a consistent patient identifier, the need for enabling infrastructure such as a national provider directory with Direct addresses, the absence of economic alignment for data sharing, variations in privacy policy among the states, and restrictions on data sharing such as 42 CFR Part 2, then we should launch task forces to focus the NPRMs on these issues, propose a voluntary national patient identifier,  architect enabling infrastructure for national directory services, encourage value-based purchasing models, and simplify heterogeneous privacy policy. At the same time we’ll still need workgroups for security (which is an ongoing process not a project) and implementation/adoption (which serves as a check and balance for overly ambitious regulation).

We began the meeting with an overview of the 2015 Certification NPRM Comments from the Architecture, Services, and APIs workgroup by David McCallie and Arien Malec .   The take home message from their presentation is that many historical standards efforts can be accomplished more efficiently through the use of application program interfaces.

Next, we heard the 2015 Certification NPRM Comments from the Content Standards workgroup by Andrew Wiesenthal and Rich Elmore.   They proposed a list of content standards which are unlikely to be useful for the final rule (and maybe will never be ready for implementation).

Next, we heard the 2015 Certification NPRM Comments from the Transport and Security Standards workgroup from Dixie Baker and Lisa Gallagher.  They enumerated the standards which are considered mature by objective criteria and those which are not.

Next we heard the 2015 Certification NPRM Comments from the Implementation, Certification, and Testing workgroup by Cris Ross.  They made many observations about overly burdensome requirements and their most welcome recommendation was no requirement for automated numerator recording of any measure where to do so would require additional clinical documentation that is not necessary for patient care. This has been the biggest factor in creating inefficiencies in EHR use.

Finally, we heard the 2015 Certification NPRM Comments from the Semantic Standards workgroup by Jamie Ferguson, Becky Kush, Mitra Rocca, workgroup and Eric Rose.  Their key point was that actual code values should not appear regulation - instead the regulation should point to vocabulary authorities for the details.

At the moment, there are multiple events creating anxiety in US  healthcare IT policy making - the 21st Century Cures Act (described in this article), the Burgess Bill, and even the  Notices of Proposed Rulemaking (ONC and CMS) themselves. It’s a time that requires intense focus and strong leadership. The role of the Standards Committee is not to criticize the work being done by any group, but to suggest a path forward that minimizes burden while maximizing improved outcomes. At our next meeting, 10 members of the committee will reach their term limit and be replaced with new members, a great loss of institutional memory.  I look forward to guiding the standards effort for 6 more months until my own term limit is reached.