Proposed Interoperability Standards Measurement Framework Public Comments

Please find attached comments from the American Academy of Pediatrics.

Please see the attached file. Thank you for to opportunity to share our comments and recommendations.

Thank you for providing us an opportunity to comment on this document. We are submitting these comments on behalf of Veteran's Health Administration, Defense Health Agency, Program Executive Office Defense Healthcare Management Systems and DoD / VA Interagency Program Office. Let me know if there are any questions. Chris Hills (843) 218.6627

Allscripts, with a platform of clinical and business solutions for ambulatory, acute and post-acute care settings, is relied upon by the largest network of providers. It is through our three decades of experience partnering with and deploying software to this vast network of providers that we can submit informed comments today on the Office of the National CoordinatorÕs Proposed Interoperability Standards Measurement Framework. We appreciate an opportunity to contribute to this important discussion of how to best measure interoperability standards adoption and use, and we welcome any questions or discussion that would be helpful. Please see attached...

In the simplest case, collection of the Direct Address and other activated FHIR or XD endpoints for an organization would be helpful in determining that such capabilities have been enabled for an organization and through which trust community. This could be a path toward building a nationwide directory of all electronic addresses and for evaluating the capabilities of those endpoints by performing automated tests (or at least pinging them). A breakdown of how IRA requests are managed would also be helpful--expecting this to be heavily fax-dependent today and moving toward more automation. Give an opportunity to list a provider organization or EMR vendor with which there are interoperability issues that should be explored, so that solutions can be sought. Next in priority would be assessing the % of pulled or received documents that were successfully incorporated into new or existing medical records, with a categorization of the remaining % that couldn't be incorporated (patient not accepted, CCDA incompatibilities, or for which effort was not made to do so). Of the % unsuccessfully digested documents, list 3 different product/vendor senders or sources whose documents you were unable to digest and what transport method was used. Nice to have: it would be useful to explore failures/missed connections--perhaps a narrative set of questions to ask providers regarding why sent messages seem to fail (percentage breakdown of trust issues, attachment related issues, or that messages were not sent in the first place due to not knowing the recipient's address). Also, what data would help their work but is not available to them presently? Your question of how to collect metrics on increased efficiently and improved care might be similarly addressed by allowing providers to respond in the form of a narrative that allows them to describe successes relevant to their specialty. It would be helpful to note which b.1 certified EMRs do not work with which h.2 certified HISPs, to evaluate "interoperability at the edge". Metrics to consider: 1) Number of query or Direct messaging resources available to a practice (count of distinct provider organizations participating in network and for which the destination endpoint or address is known or discoverable); 2) Percent of patient documents received from a foreign system which can be referenced within the EMR as if they were locally generated (denominator is total # of Direct messages received or queries performed).

Please accept the attached Feedback about the Standards Measurement Framework.