Creating an interoperability roadmap

Dr.Aryan Chavan challenges to be addressed: (1) variation in how standards are tested and implemented; (2) variation in how health IT stakeholders interpret and implement policies and legal requirements; and (3) reluctance of health IT stakeholders to share and collaborate in ways that might foster consumer engagement.^[6]

The ONC is working to develop a policy advisory for health information exchange by 2017 that will define and outline basic expectations for trading partners around health information exchange, interoperability and the exchange of information.^[6] Current federal and state law only prohibits certain kinds of information blocking in limited and narrow circumstances, for example, under the Health Insurance Portability and Accountability Act (HIPAA) or the Anti-Kickback statute.^[6]

Protecting privacy and security

In addition to HIPAA, many states have their own privacy laws protecting an individual’s health information. State laws that are contrary to HIPAA are generally preempted by the federal requirements unless a specific exception applies. For example, if the state law relates to identifiable health information and provides greater privacy protections, then it is not preempted by HIPAA. Since privacy laws may vary from state-to-state, it may create confusion among health IT stakeholders and make it difficult to ensure privacy compliance.^[6]

Establishing common technical standards

Use of common technical standards is necessary to move electronic health information seamlessly and securely. While some clinical record content, such as laboratory results and clinical measurements are easily standardized other content, such as provider notes may be more difficult to standardize. Methods need to be identified that allow for the standardization of provider notes and other traditionally “free form text” data.

The ONC HIT Certification Program^[7] certifies that a system meets the technological capability, functionality and security requirements adopted by HHS. ONC will assess the program on an ongoing basis “to ensure it can address and reinforce health IT applications and requirements that support federal value-based and alternative payment models.”^[5]

Increasing confidence in safety and safe use of health IT

Health care consumers, providers and organizations need to feel confident that the health IT products, systems or services they are using are not only secure, safe and useful but that they can switch between products, systems or services without loss of valuable information or undue financial burden. Implementation of the Federal Health IT Strategic Plan 2015-2020, along with the 2013 HHS Health IT Patient Safety Action and Surveillance Plan and 2012 Food and Drug Administration Safety and Innovation Act will attempt to address these concerns.^[5]

Developing national communications structure

A national communications infrastructure is necessary to enable the sharing of electronic health information between stakeholders, including providers, individuals and national emergency first responders. It is also necessary for delivering telehealth services or using mobile health applications. “Expanded, secure, and affordable high-speed wireless and broadband services, choice, and spectrum availability will support electronic health information sharing and use, support the communication required for care delivery, and support the continuity of health care and public health services during disasters and public health emergencies.”^[5]

Stakeholder collaboration

The federal government in its role as contributor, beneficiary and collaborator “aims to encourage private-sector innovators and entrepreneurs, as well as researchers, to use government and government-funded data to create useful applications, products, services, and features that help improve health and health care.” HHS receives funds from the Patient-Centered Outcomes Research Trust Fund to build data capacity for patient-centered outcomes research. It is estimated HHS will receive over $140 million for the period between 2011 and 2019. These funds will be used “to enable a comprehensive, interoperable, and sustainable data network infrastructure to collect, link, and analyze data from multiple sources to facilitate patient-centered outcomes research.”^[5]

Limiting data collection

The needs of healthcare providers, government agencies, health plans, and researchers for quality data must be met to ensure adequate medical care and to make improvements to the healthcare system, while still ensuring the patients right to privacy. Data collection should be limited to necessity for medical care and by patient preference beyond that care. Such limits would protect patient privacy while minimizing infrastructure costs to house data. When possible, patients should be informed about what data is collected prior to engaging in medical services.^[13]

Limiting data use

Expanding availability of big data increases the risk of statistical errors,^[1] erroneous conclusions and predictions,^[10] and misuse of results.^[14] Evidence supports use of data for process improvements,^[15][16][17] cost reductions,^[18] personalized medicine,^[19] and public health.^[20] Innovative uses for individual health^[19][21] can harm underserved populations.^[22] Limiting use for denial and exclusion prevents use to determine eligibility for benefits or care and is harmonized with other U.S. anti-discrimination laws, such as Fair Credit Reporting Act, and is harmonized with anti-discrimination laws like the Civil Rights Act and the Genetic Information Nondiscrimination Act.

Providing incentives to encourage appropriate use

Increasing vertical integration in both public and private sector providers^[23] has created massive databases of electronic health records.^[24] The ACA has provided Medicare and Medicaid incentives to providers to adopt EHR's.^[13] Large healthcare institutions also have internal motivation to apply healthcare analytics, largely for reducing costs by providing preventative care.^[25] Policy could increase data use by incentivizing insurers and providers to increase population tracking, which improves outcomes.^[12]

To enforce compliance with regulations, the government can use incentives similar to those under the ACA for Medicare and Medicaid to use electronic health records.^[13]

Creating standards for the IT infrastructure

Inappropriate IT infrastructure likely limits healthcare analytics findings and their impact on clinical practice.^[11] Establishing standards ensures IT infrastructure capable of housing big data balanced with addressing accessibility, ownership, and privacy.^[25] New possibilities could be explored such as private clouds and “a virtual sandbox” consisting of filtered data authorized to the researchers accessing the sandbox.^[11][26] Standards promote easier coordination in information collaboration between different medical and research organizations^[11] resulting in significantly improving patient care by improving communication between providers and reducing duplicity and costs.

Minimum standards are necessary to balance privacy and accessibility.^[11] Standardization helps improve patient care by facilitating research collaboration and easier communication between medical providers.^[11] The research can yield preventive care concepts that can reduce patient caseload and avoid long-term medical costs.