After describing the context for the task force’s work – essentially the existing programs around certified health information technology and recent public health emergencies and pandemic (e.g., Zika outbreak, COVID-19) – the task force makes a strong recommendation for ONC to “establish certification criteria for technologies used by public health, focused on the certification of interoperability functions….” This would be a dramatic step for the Federal government which up until now has shied away from formal certification of public health data systems. Given differences in law and policy at the state, tribal, local and territorial levels, it is not clear that formal certification would be fair or effective given the potential cost to develop and implement it. Programs within public health agencies might run the risk of losing CDC funding if non-compliant, when difficulties in compliance could be outside of the agency’s direct control. Note that there was very little discussion of CDC’s Data Modernization Initiative (DMI) in this context, and that there were no specific recommendations (see below) about how to implement such an initiative.
The detailed recommendations of this task force, if accepted, will continue to strengthen the CMS Promoting Interoperability program to the point that public health agencies should benefit from more standardized, compliant data streams from clinical care without the need for themselves to undergo certification. In some domains, like immunization, the American Immunization Registry Association (AIRA) with CDC support has already established a formal “measurement and improvement” initiative (M&I) which provides guidance and formal testing for compliance with national standards. Other public health domains are less far along but this model could easily be replicated.
The report then goes on to provide seventeen general recommendations, ten recommendations (plus one general “suggestion”) related to standards and standards adoption, followed by twenty-six recommendations about specific public health interoperability requirements. The first general recommendation relates to establishment of certification criteria and potentially certification for the public health side of interoperability transactions which is already discussed above. The fourth recommendation tries to make a distinction between certification for public health functions rather than systems though the distinction does not seem practical. Additional general recommendations target use of standardized terminology and value sets (including USCDI and the outcome of Project US@), and embracing of real-world testing of interoperability transactions. The standards-related recommendations focus on improvement of data quality through more consistent use of standards, support of public health needs by TEFCA, including leveraging TEFCA consent practices (and a suggestion for ONC to coordinate best practices) to improve the consistency of law and policy across jurisdictions.
Here are some domain-specific comments:
- With respect to Immunization Information Systems, the Task Force recommended bringing the certification criteria more in line with practices in the field like use of web services for transport, more reliance on the HIMSS-AIRA-IIP program for testing, improvement of immunization information in USCDI, and modular certification for the IZ Gateway (though it is not clear how this would be possible given that the IZ Gateway does not currently examine messages that it transports let alone ensure their conformance to standards).
- With respect to syndromic surveillance, the Task Force recommends that a broader set of care settings be included, as well as reference to more up-to-date technical standards than are currently codified in the regulations.
- With respect to electronic laboratory results (ELR) transmission, the Task Force focused mostly on ensuring that ONC ensure use of more up-to-date technical standards than are currently codified in the regulations. In addition, the Task Force was concerned that ONC continue to delineate the difference between ELR and electronic case reporting (eCR), and that participants realize that successful ELR requires focus not only on the lab to public health interface for sending results but on all the upstream processes and systems that lead up to results transmission.
- With respect to eCR, the Task Force recommended reference to more up-to-date technical standards than are currently codified in the regulations, better testing tools, establishment of a national healthcare organization directory (see related CMS RFI), and addition of certification requirements for receiving eCR Reportability Responses (RR) from the Reportable Conditions Knowledge Management System (RCKMS).
- There were no substantive recommendations related to reporting to cancer registries, antimicrobial use and resistance reporting, and health care surveys.
Overall, the Task Force’s recommendations seemed rather mild. But then again, they were constrained to focus on the interoperability regulations as they exist. These recommendations, if accepted, should marginally help in moving the country toward more uniformity and effectiveness in its public health reporting. Given the number of end points and data trading partners between clinical care and public health, and the distributed nature of healthcare and healthcare regulation in the US, there is still much work to be done.
This post was authored by Noam H. Arzt, and first published in the HLN Blog. It is reprinted by Open Health News with permission. The original post can be found here.
