- Pew Charitable Trusts recently requested ONC support the expansion of health data exchange via application programming interfaces (APIs) beyond common clinical data sets (CCDS) to include a wider variety of important EHR data.
In a letter to National Coordinator Don Rucker, MD, Pew addressed the current state of health data standardization and recommended ONC expand API functionality as part of its efforts to implement provisions of the 21st Century Cures Act.
Under current regulation, health IT developers are required to enable patient access to CCDS through open healthcare APIs. While CCDS contain health data including medication and allergy information, they often omit other relevant EHR data — such as family health histories and diagnostic imaging reports — that could further improve clinical decision-making.
Provisions of the 21st Century Cures Act mandate that ONC require health IT developers to develop innovative APIs that support the access, exchange, and use of all data elements in a patient’s EHR within the bounds of privacy laws. Cures also mandates that patients and providers are able to utilize this data without special effort.
“This expansion of API functionality could not only allow patients easier access to more information from their health record, but also facilitate many other uses, including fostering interoperability among facilities and development of new clinical decision tools for care providers,” wrote Pew Charitable Trusts Health IT Manager Ben Moscovitch.
Pew recommended ONC clearly specify that “all data elements” entails both data in the CCDS and other medically relevant information.
“ONC has recognized the limitations of the CCDS in its recently released draft Trusted Exchange Framework and Common Agreement, which defines a set of information for exchange termed the U.S. Core Data for Interoperability (USCDI),” the letter stated. “As envisioned by ONC, the USCDI goes beyond the CCDS and will grow over time to incorporate more data elements that should be exchanged electronically.”
The draft Trusted Exchange Framework and Common Agreement (TEFCA) published earlier this month is currently open for public comment. The framework is designed to improve interoperability by implementing provisions of 21st Century Cures Act through a nationwide approach to health data exchange.
In addition to clarifying the definition of “all data elements,” Pew also recommended ONC promote the exchange of unstructured EHR data.
“While some data elements contained in EHRs may not be structured in a standard way, the agency should not limit access to that information solely due to the lack of standardization,” wrote Moscovitch. “For example, some free text notes may be essential to transmit, or some critical data elements may be coded in standards that are not widely adopted.”
According to Pew, EHR data that has not been standardized can still be useful to patients and clinicians in a text or PDF form. This kind of information should be made available through APIs.
Ultimately, Pew recommended that ONC require health IT developers to enable API access to radiology medical imaging, allergies, family health history, social determinants, medical device data, patient generated data, and genomic data.
While widely-adopted standards are in place for data elements such as radiology medical imaging and allergies, standards for medical device and patient generated data are not yet fully developed.
Pew also recommended ONC consider leveraging Fast Healthcare Interoperability Resources (FHIR) as a way to improve API functionality.
“ONC should consider whether to identify or facilitate the use of this standard in the regulations to provide health IT developers a clear direction when developing APIs,” suggested Pew.
However, Pew noted that in some cases FHIR standards may not be appropriate. Specifically, it may be easier to exchange free text and unstructured data via electronic clinical documents. Pew also recommended ONC refrain from reformatting EHR data.
“As ONC develops regulations to implement this provision, the agency should consider incorporating additional data elements beyond just the CCDS — for example the USDCI, even when information is not structured or standardized — for inclusion as part of APIs to foster better sharing and use of data that can improve the quality, safety, and coordination of care,” the organization concluded.
This letter follows another from Pew last month advocating for the implementation of provisions from the Cures Act.
Pew and the American Medical Informatics Association (AMIA) urged that congressional appropriators ensure ONC is allotted adequate funding to implement the EHR reporting program. The EHR reporting program mandates that EHR developers submit data on the functions of their health IT products.
The program could also help to establish new requirements related to EHR certification according to the two organizations.
Pushing for the swift and thorough implementation of provisions from the 21st Century Cures Act further supports the healthcare industry’s goal of enabling true interoperability and effective EHR use.