Interoperability Roadmap Public Comments

I am opposed to the medical records tracking system. It threatens the privacy of every person. Subjects our medical records to the risk of hacking. Interferes with the rights of states to make their own laws and regulations regarding medical records.

The guiding technology principles laid out in the road map do not seem to be in line with the scope, since the scope states that the systems need to be “learning systems”. This concept is not in line with the principle regarding leveraging existing HIT infrastructure as traditional technology may not support “learning systems” universally.

In addition, Direct Trust - Requirements have been developed as a security protocol requirement by ONC but this concept requirement must be implemented by each funded HIE and requires investment in a product made available by specific entities or vendors. This creates a market without pricing restrictions that has become cost prohibitive to the HIEs and their customers. Requiring HIEs to provide a certified product to their customers but not requiring vendors to utilize a defined pricing model results in HISP services that are priced in various methods depending upon the vendor.

Furthermore, EMR/EHR vendors’ pricing models offered to their EMR/EHR customers and HIEs for building interfaces between the EMR/EHR and the HIE are extremely expensive to both parties. The Vendors charge the HIEs to build the interfaces and the providers. HIEs are required to connect to every EMR/EHR system and the costs to the HIE remains the same if there is one customer using the EMR/EHR or 1,000. This is cost prohibitive to the HIEs and the providers. OHIT urges ONC to consider these pricing constraints on interoperability and take steps to improve market pressures.

In addition, as a statewide Health a Information Exchange, OHIT also believes that:
• Interoperability governance must reflect the full continuum of a broad national information supply chain; and
• The information supply chain must include the rich and abundant data from across the health, healthcare, human services, health research, and personal health & wellness ecosystem.
We urge ONC to consider a broad definition of the interoperability ecosystem, reflecting the goal of a Learning Health System. As a nation, we must collaborate across domains to address the scope and significance of this effort and its essential national importance to health, wellness, and cost.

This process of coordination and governance must be durable, repeatable, and extensible, not through any one particular organization or institution, yet the process must persist over time. To ensure the equity and integrity of this critical national infrastructure, it must be organized:
• through a process that is vendor-, payer-, and institution-agnostic; and
• reflects all of the domains of HIT’s diverse constituencies.
Those domains include but are not necessarily limited to:
• Data generators and users, including
o patients and families,
o providers: individuals, institutions, and organizations across the care, services, health & wellness continuum;
o Federal providers of healthcare services and federal senders/receivers of data (DoD, VHA, IHS, CDC, CMS... the members of the Federal Health Architecture);
• State, county, local, territorial, and tribal governments and agencies;
• Health IT and IT system vendors and integrators, their trade groups and associations;
• Health Information Exchange and data aggregation and analytics organizations and services;
• Clinical research and the pure and applied sciences communities;
• Champions of transparency, value, and quality of healthcare systems and financing; and
• Cross-cutting individuals and organizations that support those both within and working across these domains.

We believe the best approach is an iterative, agile series of steps designed to:
• engage and convene cross-domain constituencies of collaborators;
• define common shared values by articulating clusters of use cases that reflect common patterns across domains; and
• produce a set of recommendations in early fall 2015 for specific actions steps that can be taken within each domain, including government, to inform ONC about the next steps we as states/organizations/individuals can take together through self-organizing collaboration.

We recognize this is no small task, but the alternative is to continue the unacceptable chaos that characterizes the status quo of interoperability. Paradoxically, while we must begin to comprehensively coordinate the mission-critical infrastructure of HIT, its coordination must be focused on those activities that people and organizations agree that they want to coordinate. In other words, this must be a self-organizing, collaborative process, reflecting the particular interests and focus of diverse communities of interest across the ecosystem. Its outcomes cannot be pre-ordained: the governance structures will emerge “in the rearview mirror,” based on the outcomes of subsets of collaborative activities.
It is critically important not to let construction of an ideal governance solution impede immediate progress. It will take a long time to fully instantiate a durable, persistent governance and coordination process. Even very recent history is littered with multiple, failed efforts to define “the right governance” and roadmap for HIT. These failures are the result of approaching the problem from too narrow a perspective. We should look to the wisdom of General and President Dwight D. Eisenhower, who said "Whenever I run into a problem I can't solve, I always make it bigger. I can never solve it by trying to make it smaller, but if I make it big enough, I can begin to see the outlines of a solution."

Please find Adventist Health System's comments in the attached file.

Please find my comments attached.

Please see attached.

Please see Carequality's comments in the attached file.

April 3, 2015

The Consortium for Citizens with Disabilities Technology and Telecommunications Task Force would like to submit the following comments regarding “Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0.” The Consortium for Citizens with Disabilities is a coalition of more than 100 national disability organizations working together to advocate for national public policy that ensures the self-determination, independence, empowerment, integration, and inclusion of children and adults with disabilities in all aspects of society. The Telecommunications and Technology Task Force focuses on ensuring national policy on matters of telecommunications and technology, including assistive technology, helps move society toward our ultimate goal of full inclusion of all people with a disability.

The Task Force commends the Office of the National Coordinator for Health Information Technology’s (HIT) work to develop this draft report. Specifically, however, the Task Force recommends the report include language that ensures HIT is fully accessible for people with disabilities. It is important that all different types of information and communications technologies (ICT) are fully accessible, including HIT, by conforming to a set of nationally accepted ICT access standards.

As you continue to finalize the Roadmap that outlines the interoperability across the HIT landscape, it is essential that the development of the health IT system be designed to ensure compatibility with an array of assistive technologies. The importance of ensuring an accessible infrastructure up front during the early development stages is easily overlooked, and therefore, we are asking for language ensuring ICT accessibility included in the final version of this report.

The CCD Technology and Telecommunications Task Force would like to meet in person to explain this issue in further detail. It is essential that accessibility issues be considered during the development of this Roadmap and incorporated during the development of a healthy HIT ecosystem.

Thank you for your consideration of these views. If you have any questions, please feel free to contact one of the CCD Technology and Telecommunications Task Force Co-Chairs: Eric Buehlmann, eric.buehlmann@ndrn.org; Mark Richert, 4justice@concentric.net; Audrey Busch, audrey.busch@ataporg.org; Sara Rosta,sara.rosta@ppsv.com; or Michael Brogioli, mbrogioli@resna.org.

Sincerely,

Mark Richert, American Foundation for the Blind
Audrey Busch, Association for Assistive Technology Act Programs
Sara Rosta, Perkins
Michael Brogioli, Rehabilitation Engineering and Assistive Technology Society of North America
Eric Buehlmann, National Disability Rights Network

We do not want to pass The Doc Fix. We need to vote NO on the HR2.

We already have a shortage of health care professionals, especially physicians. This shortage is only going to grow worse. So why would we want to do anything that is going to, first, discourage young people to seek the medical profession and second, why would we do this to only short change ourselves in the future of healthcare professionals. Vote No on HR2.

Keep our patient data private. Why would we want the patient data public property?
Vote NO on HR2.

General comment: excellent overarching vision, perfect timing, needed

Long range goal has to include unimpeded information exchange across all service sectors that might be engaged with individuals having complex medical, behavioral, functional and environmental needs. This requires standards for information exchange, syntax and meaning that are shared by medical service providers, behavioral health service providers, Long Term and Post Acute Care providers (LTPAC) and LTSS/HCBS providers and, finally, the individual and immediate caretakers. Currently, there is limited exchange between these sectors although exchange among medical providers has increased thanks to meaningful use incentives. Robust exchange among all of these sectors is a necessity for the individuals with the most complex needs.

There are two essential processes that should be called out specifically: transitions of care from one site or team to another, and longitudinal coordination of care across all sites and teams. These are the fundamental processes in health care and need to be explicitly supported. The capability to exchange a plan with other service providers should be a high priority goal. The data required as part of an exchangable plan includes most of the information needed to assure safe transitions. When this is done electronically, it opens up the possibility of using the act of transferring this information as a quality measure based on timeliness, completeness and format.

ONC Rocks.

Please!!!! Let's keep confidentiality in the freedom of speech! !!!