Monday, March 15, 2010

In ONC I Trust

It's my nature to question authority.

Whether it's religion, politics, or even my local administrative leadership, authority figures must earn my trust.

Earning that trust is not easy. As folks who work closest with me know, I believe that much of Dilbert is based on true case studies.

Over the past year, I've worked very closely with many people at ONC - David Blumenthal, John Glaser, Judy Sparrow, Farzad Mostashari, Chuck Friedman, Carol Bean, Doug Fridsma, Chris Brancato, Jonathan Ishee, Arien Malec (on loan to ONC for 8 months), and Jodi Daniel. I've worked with HHS CTO Todd Park. I've worked with US CTO Aneesh Chopra.

They've earned my trust.

The ONC folks work long hours, nights, and weekends. They do not have a dogmatic philosophical, industry, or architectural bias. They are simply trying to move the ball forward to improve healthcare quality and efficiency using IT tools.

Meaningful Use is a brilliant construct. If it were not for meaningful use, the stimulus would simply be a hardware and software purchasing program. Clinicians would waste government dollars buying technology and never use it (or use it in limited ways such as revenue cycle automation). I've seen numerous technology programs fail because clinicians just give the technology to their kids or sell it on eBay. Meaningful use requires metrics of adoption of the measure of success. Clinicians only receive stimulus dollars AFTER they have fully adopted the technology.

NHIN Direct is a powerful idea. My blog is filled with entries suggesting that we need a reference implementation for simple transport of data packages (X12, NCPDP, HL7 v2, CDA, CCR) among payers, providers and patients. NHIN Direct will assemble energetic, well intentioned people to create open source software that solves real world transport problems. I'm serving on the NHIN Direct Implementation Group. We'll have running code, implementation guidance, and data use agreements by October.

I've enjoyed my 5 years harmonizing standards as part of HITSP. The tireless volunteers really made a difference. But there were issues. The AHIC Use Cases were overly complex. The Interoperability Specifications, which were designed to support the AHIC Use Cases, tightly coupled transport and content standards. It was challenging to use a portion of a use case to solve a limited real world problem. In HITSP's final contract year, the Tiger Teams did remarkable work creating highly reusable content, vocabulary, transport and security modules called capabilities and service collaborations that were much more aligned with ARRA and easier for implementers to understand.

The new Standards Harmonization framework being proposed by ONC using the National Information Exchange Model (NIEM) is something to be embraced, not feared. I've been misquoted saying something like "we'll extend the Department of Justine infrastructure to include healthcare." That's not at all what I said. My actual comments reflected on the wisdom of the NIEM methodology which follows the HITSP Tiger Team approach - define the business needs and find the parsimonious data content, vocabulary and transport standards to meet that need. NIEM methodology is consistent with CDA, CCR, and simple transport. It does not replace the decades of work that have already been done. Instead it provides a methodology for defining needs, selecting and developing standards, and implementing those standards in a testable, sustainable way. Over the next few weeks, I'll write about the several recent RFPs that embrace NIEM methodologies issued including

*Office of the National Coordinator (ONC) CIO-SP2i Solicitation Number 10-233-SOL-00070 entitled "Standards and Interoperability Framework – Use Case Development and Functional Requirements for Interoperability

*Office of the National Coordinator (ONC) CIO-SP2i Solicitation Number 10-233-SOL-00072 entitled "Harmonization of Standards and Interoperability Specifications."

*Office of the National Coordinator (ONC) CIO-SP2i Solicitation Number 10-233-SOL-00080 entitled "Standards and Interoperability Framework Standards Development."

I've written letters of support for responses to all these RFPs.

I was recently asked about the Certification NPRM and if the temporary process and permanent process might create market confusion by changing certification criteria after 2 years and requiring that clinicians replace the systems acquired under the temporary process. My answer was simple - ONC leaders would not let that happen. The people there understand that this is a journey and will ensure that change is managed as evolutionary phases, not revolutionary quantum leaps.

Finally, I trust the HIT Policy Committee and HIT Standards Committees. These folks are good people, with diverse backgrounds, and different points of view. You will not see hegemony of any single person or organization. All their calls and work are done in open public forums. They have included the best people with the greatest good of patients as their driving motivation.

We live in remarkable times, which I've called the "Greatest Healthcare IT generation" and the "Healthcare IT Good Old Days"

My advice - trust the ONC folks and Federal Advisory Committees. Join the process. Be open about your opinions. Feel free to disagree with any idea or policy. Democracy is messy, but the folks at ONC today have the right people and processes in place to harness our energy and turn it into guidance we can all embrace.

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