Upload
transformations-at-the-edge
View
224
Download
0
Embed Size (px)
Citation preview
8/7/2019 PCAST Public Comments Summary Jjs
1/31
HIT Policy CommitteeHIT Policy Committee
PCAST WorkgroupSummary of Public CommentSummary of Public CommentResponses to ONC Request for Comment on PCAST ReportResponses to ONC Request for Comment on PCAST Report
Office of the National Coordinator
Jodi Daniel and Doug Fridsma
January 27, 2011
8/7/2019 PCAST Public Comments Summary Jjs
2/31
Disclaimer
The following presentation will show the initial analysis
and summary of public comments made in response to
ONCs Request for Comment on the PCAST report"Realizing the Full Potential of Health Information
Technology to Improve Healthcare for Americans: The
Path Forward. This summary does not reflect the
position of the Office of the National Coordinator.
2
8/7/2019 PCAST Public Comments Summary Jjs
3/31
ONC Request for Comment Overview
On Dec 8, 2010, the Presidents Council of Advisors on Science
and Technology released their Report entitled "Realizing the Full
Potential of Health Information Technology to Improve Healthcare
for Americans: The Path Forward."
On the same day, ONC published a Request for Comment asking
the public 9 questions regarding:
The impact of PCAST on ONC activities
Initial thoughts on PCAST recommendations
How they want ONC to act on the PCAST recommendations
Public comment was due on Jan 19th, by which we received 107
comments
3
8/7/2019 PCAST Public Comments Summary Jjs
4/31
Commenter Profile
We received comments from:
Associations, EHR and PHR vendors, HIT Software
Companies - around 35%
Infrastructure experts, HIEs and StandardDevelopment Organizations under 15%
Providers, Pharmacy or Pharmacy Organizations,
Hospitals and Health Plans 20%
Others including Patient Advocates, IndividualCitizens and State Health Employees remaining
30%
4
8/7/2019 PCAST Public Comments Summary Jjs
5/31
Common Themes of Comments
Timeline IssuesTimeline Issues
Effects on ONC ProgramsEffects on ONC Programs
Process of Implementing PCASTProcess of Implementing PCASTRecommendationsRecommendations
Privacy and Security IssuesPrivacy and Security Issues
StandardsStandards
5
8/7/2019 PCAST Public Comments Summary Jjs
6/31
Question #1a, 1b
What standards, implementation specifications,
certification criteria, and certification processes for
electronic health record (EHR) technology and other
HIT would be required to implement the followingspecific recommendations from the PCAST report:
a. That ONC establish minimal standards for the
metadata associated with tagged data elements;
b. That ONC facilitate the rapid mapping of existing
semantic taxonomies into tagged data elements;
6
8/7/2019 PCAST Public Comments Summary Jjs
7/31
Question #1a, 1b: Summary of Responses
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Use an open, consensus-driven process
Do not reinvent the wheel: leverage existing meta-data standards
and registries and leverage existing taxonomies and vocabularies
Keep meta-data requirements to a minimum
StandardsStandards
Harmonize existing taxonomies: the industry needs widely
available harmonized taxonomies; e.g., SNOMED CT to ICD-
9/ICD-10
Beware of losing clinical context: the true meaning of data can be
lost when tagging at the atomic level Choose the right granularity of data-tagging: dataset-level might
be the happy medium between document-level and atomic-level
Use a model-driven approach: tags, terminology and value sets
need to be defined in an information model
7
8/7/2019 PCAST Public Comments Summary Jjs
8/31
8
Question #1c
What standards, implementation specifications,
certification criteria, and certification processes for
electronic health record (EHR) technology and other
HIT would be required to implement the following
specific recommendations from the PCAST report:
c. That certification of EHR technology and other HIT
should focus on interoperability with reference
implementations developed by ONC.
8
8/7/2019 PCAST Public Comments Summary Jjs
9/31
Question #1c: Summary of Responses
Timeline IssuesTimeline Issues
Incremental process using pilot demonstration will reduce the
risk
Effects on ONC ProgramsEffects on ONC Programs
Certification based as much as possible on ONC-developed
reference implementations is essential to realization of
opportunities identified by PCAST
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Build reference implementations: these create real-world
validation of the PCAST concepts and give a solid basis for
certification
Validate data at rest (i.e., within EHRs) and during interchange
9
8/7/2019 PCAST Public Comments Summary Jjs
10/31
10
Question #2
What processes and approaches would facilitate the
rapid development and use of these standards,
implementation specifications, certification criteria and
certification processes?
10
8/7/2019 PCAST Public Comments Summary Jjs
11/31
Question #2: Summary of Responses
Effects on ONC ProgramsEffects on ONC Programs
Incentivize development and adoption through federally-
sponsored programs, e.g., CMS, DoD, ONC
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations Achieve broad industry participation built on openness andtransparency
Build on processes that work, e.g., IHE, MITA, Direct Project,
etc.
StandardsStandards Incentivize development and adoption through federally-
sponsored programs, e.g., CMS, DoD, ONC, etc.
Provide common tools that enable development, collaboration,
pilots, and testing for efforts such as mapping terminologies
and taxonomies 11
8/7/2019 PCAST Public Comments Summary Jjs
12/31
12
Question #3a, 3b
Given currently implemented information technology
(IT) architectures and enterprises, what challenges will
the industry face with respect to transitioning to the
approach discussed in the PCAST report?
a. Given currently implemented provider workflows,
what are some challenges to populating the
metadata that may be necessary to implement the
approach discussed in the PCAST report?
b.Alternatively, what are proposed solutions, or best
practices from other industries, that could be
leveraged to expedite these transitions?
12
8/7/2019 PCAST Public Comments Summary Jjs
13/31
Question #3a, 3b: Summary of Responses
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Providers must have general availability of sufficient
broadband and computing resources before implementing
PCAST recommendations
Privacy and Security IssuesPrivacy and Security Issues atomic-level data tagging may further effect patient identity and
matching issues as well as issues of data ownership
StandardsStandards
Must have consensus on the correct level of data granularity
New PCAST standards should harmonize with existingsystems, standards to maintain workflow dynamics and avoid
potential patient safety issues
Build on existing document-level tagging approach instead of
atomic-level tagging, or at least enable interoperability among
the two 13
8/7/2019 PCAST Public Comments Summary Jjs
14/31
14
Question #4
What technological developments and policy actions
would be required to assure the privacy and security of
health data in a national infrastructure for HIT that
embodies the PCAST vision and recommendations?
14
8/7/2019 PCAST Public Comments Summary Jjs
15/31
Question #4: Summary of Responses
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Implementation of granular consent and data segmentation must allow for
dynamic privacy metadata that allows patients to update their privacy
preferences.
Design of granular patient privacy control features should be patient-centric not
data-centric Privacy and Security IssuesPrivacy and Security Issues
DEAS-based infrastructure must ensure public trust by:
Performing risk analysis
Upgrading outdate privacy policy that do not take into account the health
network
Having infrastructures that are certified Having reliable patient identification
Having built-in technology solutions for patient identification without
acceptable false positives rates
Data sharing infrastructure must have an acceptable accountability/oversight
framework and should avoid an over-reliance on consent
15
8/7/2019 PCAST Public Comments Summary Jjs
16/31
16
Question #5
How might a system of Data Element Access Services
(DEAS), as described in the report, be established, and
what role should the Federal government assume in
the oversight and/or governance of such a system?
16
8/7/2019 PCAST Public Comments Summary Jjs
17/31
Question #5: Summary of Responses
Outside of privacy and security concerns,Outside of privacy and security concerns, commenterscommenters had the followinghad the following
input in regards to the DEAS framework proposed by PCAST:input in regards to the DEAS framework proposed by PCAST:
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Commenters that suggested financial incentives may be necessary to
spur development of DEAS. Commenters acknowledged that multiple models exist on which
DEAS could be structured and governed. Suggestions included using
an SOA or having DEAS reside in an HIE. However, there was no
predominant opinion among comments received for this RFC.
StandardsStandards
Commentors suggested that ONC could make software or animplementation specification available for DEAS framework.
Some suggested that ONC examine XDS, and the experience of
intermediaries (e.g. Surescripts) and patient record locator services
when developing this DEAS implementation specification
17
8/7/2019 PCAST Public Comments Summary Jjs
18/31
18
Question #6
How might ONC best integrate the changes envisioned
by the PCAST report into its work in preparation for
Stage 2 of Meaningful Use?
18
8/7/2019 PCAST Public Comments Summary Jjs
19/31
Question #6: Summary of Responses
Timeline IssuesTimeline Issues
There was broad consensus among the variety of commenter groups
that full implementation of atomic data tagging and DEAS deployment
cannot be realized in the timeframe of MU stage 2 and 3. Many felt
that existing systems could not be upgraded in time and the cost of
new systems would be unrealistic.
In addition, commenters stated that delays in the PCAST timeframe
may occur while new metadata standards are developed
However, many felt that it would be timely to have DEAS and other
PCAST technology pilots during Stage 2
Effects on ONC ProgramsEffects on ONC Programs
Many comments asked ONC to focus MU Stage 2 on: Improved interoperability and connectivity to state systems
Value-based MU criteria rather than technology adoption goals
Outcome research, assessments, new quality measures
Decision Support
Biosurveillance and Biometrics 19
8/7/2019 PCAST Public Comments Summary Jjs
20/31
20
Question #7
What are the implications of the PCAST report on HIT
programs and activities, specifically, health information
exchange and Federal agency activities, and how could
ONC address those implications?
20
8/7/2019 PCAST Public Comments Summary Jjs
21/31
Question #7: Summary of Responses
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Many commenters wanted to see the government:
Hosting, as part of the S&I Interoperability Framework, an HIE
Interface Initiative for an implementation specification of the EHR
to HIE interface consistent with the NW-HIN Exchange (HIE-to-HIE interface).
Engaging the various state HIEs (to which edge EHR are to be
connected), HIE vendors, EHR vendors and other stakeholders in
this definition so that consistency be ensured across all
state/regional/community HIEs.
Including this implementation specification for Stage 2 or 3, EHRcertification.
Establishing a voluntary HIE testing program, based on this
implementation specification.
21
8/7/2019 PCAST Public Comments Summary Jjs
22/31
22
Question #8
Are there lessons learned regarding metadata tagging
in other industries that ONC should be aware of?
22
8/7/2019 PCAST Public Comments Summary Jjs
23/31
Question #8: Summary of Responses
Timeline IssuesTimeline Issues
Once again, many pointed out that no precedents exist in otherOnce again, many pointed out that no precedents exist in other
industries that portray the massive scale of metaindustries that portray the massive scale of meta--data tagging,data tagging,
fragmentation and voracious capacity requirements forfragmentation and voracious capacity requirements for
complexity of health information.complexity of health information.
Process of Implementing PCAST RecommendationsProcess of Implementing PCAST Recommendations
Implementation using complex metadata may be
difficult to implement
StandardsStandardsAvoid reinventing standards and learn from
successes and problems experienced with epSOS,
HL7 V3 RIM, ASCX12, GIS and others
23
8/7/2019 PCAST Public Comments Summary Jjs
24/31
24
Question #9
Are there lessons learned from initiatives to establish
information sharing languages (universal languages)
in other sectors?
24
8/7/2019 PCAST Public Comments Summary Jjs
25/31
Question #9: Summary of Responses
StandardsStandardsExamples from other industries include:
Banking and the Internet
Data Fusion Centers -Department of Homeland Security (DHS) and
Department of Justice (DOJ)
Examples of previous standards work to review include:
DICOM, ICAM, LCs MARC (MODS, MADS), ADLs SCORM,
W3Cs RDF, OWL, Dublin Cores DCMI Abstract Model, Global
JXDM, and OAI-PMH.
Examples of countries looking at health data exchange:
England: Abandoned data level architecture for CDA model Finland: Using CDA model of exchange
European NW-HIN called epSOS: Using CDA model of exchange
.
25
8/7/2019 PCAST Public Comments Summary Jjs
26/31
Timeline Comment Summary
Timeline:Timeline:
ManyMany commenterscommenters were glad to see PCAST recommendationswere glad to see PCAST recommendations
push toward an increased focus on information exchangepush toward an increased focus on information exchange
before the release of Stage 2 MU criteria and certificationbefore the release of Stage 2 MU criteria and certification
criteria.criteria. However, majority ofHowever, majority of commenterscommenters were concerned about thewere concerned about the
timeline effects of implementing full PCAST recommendationstimeline effects of implementing full PCAST recommendations
in the midst of rolling out MU stage 2 and 3 along with otherin the midst of rolling out MU stage 2 and 3 along with other
changing standards such as IC9 to IC10. They werechanging standards such as IC9 to IC10. They were
concerned that there would be negative effects on patientconcerned that there would be negative effects on patientsafety.safety.
Many reviewers specifically recommended that PCASTMany reviewers specifically recommended that PCAST
recommendations be a long term strategy rather than anrecommendations be a long term strategy rather than an
immediate deviation from the current groundwork that hasimmediate deviation from the current groundwork that has
already been laid.already been laid.26
8/7/2019 PCAST Public Comments Summary Jjs
27/31
Effects on ONC ProgramsEffects on ONC Programs Comment Summary
Effects on ONC ProgramsEffects on ONC Programs
Most commenters urged ONC to leverage success of
current ONC and private HIT programs without
reinventing the wheel in the midst in the HITECH
incentive period.
Many stated that full implementation of PCAST
recommendation would require redesign of much of the
ongoing federal HIT grants and contract; which would
incur substantial cost and may discourage participation
of current players
Many commentors did suggest the ONC begin smaller
pilots to develop and test PCAST technology solutions. If
successful, these solutions can later be more widely
implemented. 27
8/7/2019 PCAST Public Comments Summary Jjs
28/31
8/7/2019 PCAST Public Comments Summary Jjs
29/31
Privacy and Security Comment Summary
Privacy and Security
Many commenters were very supportive of the concept of
giving patients granular consent as envisioned in the
PCAST report.
However, many were worried that tagging patient privacypreferences to the data would lead to a static, rather than a
dynamic, data control environment that prevented patients
from updating their privacy preference once the data was
released.
Commenters from the research community were supportiveof PCAST concept of creating a subset of de-identified data
for the purpose research
However, others were not supportive of this PCAST
recommendation because they were skeptical that data can
truly be de-identified 29
8/7/2019 PCAST Public Comments Summary Jjs
30/31
Standards Comment Summary
A few commenters wanted ONC to avoided competition
between existing standards and instead move to a
completely new approach as outlined in PCAST
because:
They felt that current standards are strict and do not allow forinnovation and flexibility or allow scalability.
They also felt that the CDA is not a suitable framework for the
exchange of metadata tagged elements, as it is document-centric and
exists primarily as a wrapper for many different kinds of documents
However, most commenters stated that PCAST goalsof interoperability and data liquidity can be met with
existing and emerging standards, particularly those
developed by ANSI accredited SDOs such as ICD-10,
SNOMED, and LOINC.30
8/7/2019 PCAST Public Comments Summary Jjs
31/31
Next Steps
Next Steps:
ONC is currently working to:
Further analyze the comments received Create a summary report of the comments that will
be available to the WG
We request workgroup members to inform us ofspecific types of analysis they would like us to perform
of the comments during this time.
31