HITPC Meaningful Use Stage 3 RFC Comments

1. HITPC Meaningful Use Stage 3 RFC Comments February 22, 2013 Information Exchange Workgroup Micky Tripathi

2. Agenda • Review IEWG101

3. Tentative IE Workgroup Timeline

4. IEWG 101 Query for Patient Record

5. HITSC Response to IEWG101 • The workflow required here is a labor-intensive, paper-based workflow that barely works in a paper-based environment. I don’t think it’s reasonable to attempt to replicate this workflow electronically. The EHR receiving the query should mediate the request and then tell the querying system what documents are available to them. The receiving system should then protect those documents i.a.w. its own policy and the patient's preferences. We need to think through how this should happen in an electronically connected world -- not how to replicate a paper workflow electronically. For increased convenience, reduced complexity, and easier comprehension, I suggest a measure that enables a provider to obtain a patient's privacy preferences from another provider or third party service. This would enable a patient to register her preferences once, and then simply provide a pointer to those preferences for subsequent encounters with other providers. A number of providers and HIEs already are implementing such a service, making the need to specify a standard service interface (e.g., RHex) and coding more urgent. • Unfortunately no universal patient health identifier exists, and the lack of a reliable means of identifying patients is broadly viewed as a significant challenge to care quality. The proposed model involving the use of demographics to identify patients is not sufficiently reliable to support query for individual patients’ information. Multiple efforts currently under way are addressing the challenges around “directed query” (i.e., query for a specific patient’s information) through the use of a voluntary identifier, and we think it is important that regulations allow progress to continue to be made in this area. Lacking standards to support either the positive and unequivocal identification of patients or query for a specific patient’s information, we urge the ONC not to include in regulation a detailed description of how directed query is performed. Policy and standards around trustworthy identity proofing and authentication are rapidly evolving, and should provide a strong foundation for trusted query. We encourage the ONC to continue to support the development of new models for using voluntary or other high-quality identifiers and authentication methods.

6. IEWG 101Query for Patient Record

7. IEWG 101Query for Patient Record

8. IEWG 101Query for Patient Record

9. IEWG 101Query for Patient Record Measure

10. IEWG 101Query for Patient Record Patient Matching

11. Discussion • What if any changes does the Workgroup want to make based on comments. Key areas raised in the comments to consider: • Level of specificity of the objective and complex workflow • Is clarity needed around what infrastructure is needed to achieve this objective? • Can HIOs or other third parties support the achievement of this objective? • Privacy and Security • Separate certification criterion for query and response • Measure • Others?

12. Next Steps • On the next call the WG will review IEWG 102, 103, MU05