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HIT Policy Committee

HIT Policy Committee. Nationwide Health Information Network Governance Workgroup Recommendations Accepted by the HITPC on 12/13/10 Nationwide Health Information Network Governance John Lumpkin, MD, MPH, Workgroup Chair Robert Wood Johnson Foundation. Pre-Decisional Draft. Workgroup Members.

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HIT Policy Committee

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  1. HIT Policy Committee Nationwide Health Information Network Governance Workgroup Recommendations Accepted by the HITPC on 12/13/10 Nationwide Health Information Network Governance John Lumpkin, MD, MPH, Workgroup Chair Robert Wood Johnson Foundation Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 Pre-Decisional Draft

  2. Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 Workgroup Members Chair:John Lumpkin, Robert Wood Johnson Foundation Members: • Laura Adams Rhode Island Quality Institute • Christine Bechtel National Partnership for Women & Families • Carol Diamond Markle Foundation • Linda Fischetti Department of Veterans Affairs • John Glaser Siemens • Leslie Harris Center for Democracy & Technology • John Houston University of Pittsburgh; NCVHS • Michael Matthews MedVA • John Mattison Kaiser Permanente • Girish Kumar Navani eClinicalWorks • Tim O’Reilly O’Reilly Media • Wes Rishel Gartner

  3. Discussion Topics Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • Workgroup Status • Recommendations Appendix (separate deck) • Governance principles and functions • NW-HIN as preferred approach • Federal, ONC and shared responsibilities • Conditions of Trust and Interoperability • Validation • Public comments

  4. Workgroup Status * The nationwide health information network is in the process of being renamed. The acronym “NW-HIN” is used solely for convenience. Pre-decisional DRAFT.  For HITPCConsideration – 12/13/10 • October 2010: Phase 1 recommendations • NW-HIN* governance principles. • NW-HIN governance objectives and functions. • November 2010: Preliminary findings and recommendations • NW-HIN governance functions and objectives. • Governance roles and responsibilities. • December 2010: Final recommendations • Principles • NW-HIN as preferred approach • Federal leadership and shared responsibilities • NW-HIN Conditions of Trust and Interoperability (NW-HIN COTIs) • NW-HIN Validation • Oversight

  5. Recommendations to HITPC 5 Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10

  6. Recommendation 1: Nine Sound Principles for NW-HIN Governance Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • Transparency and openness • Inclusive participation and adequate representation • Effectiveness and efficiency • Accountability • Federated governance and devolution • Clarity of mission and consistency of actions • Fairness and due process • Promote and support innovation • Evaluation, learning and continuous improvement See Appendix slides 4 – 8 for more details

  7. Recommendation 2: NW-HIN as Preferred Approach See Appendix, slides 15 – 17 for more details 7 Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • The NW-HIN should be an environment of trust and interoperability for exchange based on NW-HIN Conditions of Trust and Interoperability (COTIs): • Should be the preferred approach for exchange of health information nationwide. • Should be supported by the federal government with strong incentives to vigorously promote adoption.

  8. Recommendation 3: Federal Leadership and Shared Responsibilities 8 • Federal leadership • The federal government should : • Establish fundamental conditions for trust and interoperability and utilize its full range of authorities to assure compliance. • Recognize existing state authorities across all relevant domains and facilitate coordination and harmonization with states and other entities as needed. • Federal agencies should participate fully and directly in NW-HIN and its governance. • Federal information exchange should be conditioned upon compliance with NW-HIN requirements. • Shared responsibilities: • Reflecting “governance of governances,” other entities should have specific appropriate roles within the framework. See Appendix slides 19 – 22 for more details Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10

  9. Recommendation 4: NW-HIN Conditions of Trust and Interoperability (NW-HIN COTIs) 9 Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • ONC should establish conditions to assure trust and interoperability, optimizing broad stakeholder input, including consumers. • NW-HIN COTIs should provide a baseline and address need for variability. • Some are required and apply across all NW-HIN scenarios. • Others may be required in particular circumstances. • The Governance rule should: • Establish an initial set of NW-HIN COTIs. • Establish a process for adding and modifying NW-HIN COTIs • Should provide maximum flexibility for innovation and adaptation. See Appendix slides 24 – 27 for more details.

  10. Potential COTIs: Example Topics 10 Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • Privacy • Fair information practices • Consent • Purposes for exchanging through NW-HIN, secondary use, re-identification • Security • Encryption • Identity proofing • Authentication • Auditing • Participant access policies • Interoperability • Level of conformance • Other Policies • To promote information sharing • Factors that should preclude an entity from NW-HIN • Technical requirements • Secure transport • Data lookup and retrieval, • Notification of availability of new / updated data • Subject-data matching capabilities • Data content

  11. Recommendation 5: NW-HIN Validation* * Validation generally refers to the process of verifying compliance and may include a broad array of possible methods (e.g. self attestation, testing, certification of systems, accreditation of entities, etc. 11 Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • ONC should establish a mechanism to verify that NW-HIN COTIs are satisfied. • Balance assurance with cost and burden of validation • Leverage existing validation methods, processes and entities where appropriate, including currently existing EHR certification. • EHR Certification should include applicable NW-HIN COTIs and should be a pathway to NW-HIN validation for those NW-HIN COTIs. • Any NW-HIN validation testing method should incorporate EHR validation testing where applicable • NW-HIN validation should be required when exchanging in NW-HIN environment and asserting NW-HIN compliance. • There should be various methods of NW-HIN validation: • Appropriate to specific NW-HIN COTIs and the level of assurance needed. • . See Appendix slides 29 – 33 for more details.

  12. Recommendation 6: NW-HIN Oversight 12 Pre-decisional DRAFT.  For HITPC Consideration – 12/13/10 • ONC should oversee NW-HIN governance and assure accountability • Coordinate between Federal Agencies, state entities and validation entities.  • Monitor and highlight innovation • Address governance barriers • Provide ongoing evaluation and continuous improvement

  13. Discussion 13

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