At the January 20, 2010 meeting of the HIT Standards Committee, we had an important discussion of the Interim Final Rule and Notice of Proposed Rulemaking.
Doug Fridsma presented this powerpoint about the Interim Final Rule. Slide 3 illustrates the linkage between Meaningful Use objectives, Certification criteria and standards. It's a 1:1 mapping - every objective has certification criteria. Every certification criteria has standard(s) requirements. Slides 5-8 document the differences between the HIT Standards Committee recommendations and the IFR. You'll see that most of the base standards recommendations from the HIT Standards Committee (based on a foundation of HITSP work) were included in the IFR.
We discussed several key questions.
Why does the IFR lack detailed implementation guidance?
The IFR is a regulation, which means that the details provided in it are hard to change. By providing base standards but enabling implementation guidance to be published separately from the regulation itself, ONC allowed evolution and refinement of more specific guidance.
Why does the IFR identify architectural approaches to transmission, REST and SOAP but not transaction orchestration?
ONC is spending $60 million on reference implementations of transmission/transport software for the NHIN, some of which will be very simple (RESTful)
Will there be APIs developed by vendors, especially for routing patient summaries per the patient preference?
ONC is trying to balance regulation and market forces, believing that PHR vendors will come together and create a common API for patient data transmission if it is required by meaningful use.
Karen Trudel from CMS presented this powerpoint about Notice of Proposed Rulemaking.
It contains many questions and requests for comment. The comment period closes March 15 and we'll see revisions of the NPRM that are directly related to comments. Likely most revisions will be deletions and changes, but if additions can be justified based on the comments, they are possible.
Each Workgroup chair presented their workplaces for the next 6 weeks and the next 6 months. The workgroups will all make comments about the IFR to the entire HIT Standards Committee for its review at the February 24 meeting. The Committee will forward its consolidated comments to ONC by March 1.
You'll see substantial work on vocabularies and implementation guidance including security/privacy over the next 6 months.
The sense of the HIT Standards Committee is that ONC did a great job on a tight timeframe. The comment period will add the final polish.
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