- The American Medical Informatics Association (AMIA) recently submitted a letter to National Coordinator for Health Information Technology Donald Rucker, MD with recommendations to improve the ONC Interoperability Framework.
Representing 5,400 informatics professionals, the association expressed its support for the development of a measurement framework for interoperability standards and emphasized the importance of drafting a framework that benefits providers and reduces administrative burden.
In particular, AMIA recommended that measurement and measure reporting be automated wherever possible, high-value standards and use cases be targeted, and value be delivered to stakeholders being measured.
“We underscore the need to have the benefits of measurement outweigh the costs, and that there is sufficient effort to develop and implement automated measurement solutions,” wrote the association. “As the work moves forward, we urge ONC to be very mindful of the potential burdens associated with additional measurement and to carefully balance the burdens of measurement with expected benefits.”
A shift toward increasingly automated reporting will require ONC to offer guidance surrounding what is acceptable for voluntary and optional automated data collection before the transition from surveys to automated collection is complete, stated the association.
AMIA also advised ONC against requiring providers to submit superfluous data.
“It is essential that measurement not become an end in and of itself and that we recognize the costs to clinicians, developers and others in developing and implementing automated solutions,” wrote AMIA.
The association outlined its stance on each objective measurement area.
First, AMIA voiced its support of all Objective 1 proposed measures, stating providers would likely benefit from data obtained through this objective measurement area and measures would not be viewed as excessively burdensome.
However, the association stated Objective 2 requires some tweaking.
“Objective 2, which focuses on the ‘use of standards, including customization of the standards, by end users to meet specific interoperability needs,’ will require substantial examination, broad stakeholder input, and – potentially – much work to realize a positive benefit/burden ratio,” wrote AMIA.
“As a general observation, we anticipate Objective 2 Measurement Areas will rely more heavily on clinical end-user reporting then is envisioned by the proposed Framework to provide valuable, actionable data,” the association continued.
In response, AMIA recommended ONC develop quantitative and qualitative measures for Objective 2.
First, the association stated ONC will need to discern which standards are useful for facilitating interoperability for clinical use cases considered to have high-value for patients to limit measurement options and administrative burden.
Further, quantitative measures should be automated to evaluate the use of standard medical terminologies.
Automated measurement may require specific software and changes to certain standards to allow for a more accurate measurement of the ways different standards are being used.
AMIA suggested ONC work with standards development organizations to make necessary changes.
“Automated measurement and reporting is necessary because while clinician end-users and their health IT support are likely to be a better focus point of measurement, they are likely to have limits in what they can report, especially for Objective 2, given their variable and uneven knowledge of standards, versioning, etc.,” wrote the association.
Beyond automated measures, the association also recommended ONC gain insight into the level of provider levels of conformance or customization to certain standards.
“These reviews would enable ONC to contextualize transaction-level and other quantitative data to better understand if clinically relevant data were available to the clinician when and where they were needed, and which standards were used to facilitate specific instances of interoperability,” stated AMIA.
Developing measures that focus on understanding where interoperability is still needed is more valuable than measuring ways interoperability may already be occurring, said AMIA.
Measuring standards in this way would require increased reliance on claims data and statistical samples.
“This approach would help ONC assess the use of standards to facilitate the availability of data and the impact of interoperability where it is likely to influence the care of patients most – among the clinicians and organizations that treat them routinely,” the association stated.