- The American Medical Informatics Association is advising the Centers for Disease Control and Prevention to limit the scope of health IT testing in the field to ensure the success of the proposed National Test Collaborative.
“Despite our support for such an endpoint, AMIA urges CDC to begin with a narrow scope that is initially developed for a single purpose,” wrote President & CEO Douglas Fridsma, MD, PhD.
“Starting with a limited pilot will enable the NTC to learn how to establish and coordinate relationships among various stakeholders, including health IT developers, clinician users, clinical informatics experts, healthcare organizational leaders, standards developers, measure stewards, and others,” he added. “A limited scope will also improve the sustainability of the NTC by increasing the likelihood of tangible outputs and outcomes from which to incorporate into future focus areas.”
The comments on scope stem from examples listed in the CDC RFI for evaluation: electronic clinical quality measures, clinical decision support (CDS), and other clinical testing.
Choosing one area for piloting in-situ health IT testing rather than many increases the likelihood that CDC and NTC meet with success in the long term, the AMIA letter states. To that end, the association makes a case for each of the three focal areas.
According to AMIA, eCQMs are an obvious starting point:
CDS is another viable use case given the appropriate amount of time:
A recent study published in JAMIA captured provider dissatisfaction with CDS alerts in the form of override comments. CDS is clearly one area ripe for empirical analysis.
The association notes that testing the interoperability of certified EHR technology would also go a long way toward improving “the usability and utility of clinical data” — although that focal area is mired by delays in implementing provisions of the 21st Century Cures Act at ONC.
“We are eagerly awaiting final rules implementing this provision of Cures and we envision that once an NTC is established, such testing could represent an important set of use cases,” said Fridsma.
In his closing remarks to CDC, the head of AMIA emphasized the challenges inherent to any voluntary program.
“Testing real-world, EHR-derived health IT scenarios — no matter what the use case — will involve organizational and legal structures that lab-based testing does not,” Fridsma cautioned. “These additional dimensions will likely mean that only the most motivated individuals and organizations will engage with the NTC on a voluntary basis, given the difficulty and uncertainty of in situ testing. We encourage CDC to think about various incentives that sister agencies within HHS can provide to testing participants, such as CMS payment policy and ONC Surveillance capacity.”
As noted in the association’s preamble to its comments, health IT testing in the field is a necessary complement to conformance testing. Last year highlighted the limitations of the latter when a popular CEHRT was found to be lacking functionality not observed in a lab environment.