Doug Fridsma presented a straw man for the evolution of the HIT Standards Committee Workgroups to better align with our domain expertise, especially as term limits require the rotation of members. The committee agreed that it made great sense to organize ourselves into content, vocabulary, transport/security, architecture/api/services, implementation/certification/testing groups. An overall steering committee will triage questions to the right groups and collate the responses from groups.
We then began a day long look at the 2015 Notice of Proposed Rulemaking.
Liz Johnson and Cris Ross presented comments from the Implementation Workgroup. Their key summary is reconsider the cost/benefits of frequent rule changes because there is
*No guarantee that the items contained in 2015 Edition will be part of 2017 Edition/MU Stage 3
*Unclear benefits to provider community related to implementing an incremental update while continuing to gather data for attestation period in any fiscal year on 2014 Edition
*Preference for vendors to focus on optimizing current code releases and begin preparation for MU Stage 3
*Cost burden to both vendors and providers
Next, – Majorie Rallins and Danny Rosenthal presented the Clinical Quality Workgroup NPRM evaluation. Their key takeaways are that many of the quality standards required for the 2015 NPRM are not mature/fit for purpose and that energy should be spent improving QRDA 1 (patient level), not QRDA 2 (summary), or QRDA 3 (numerator/denominator calculations)
Next, Dixie Baker and Lisa Gallagher presented the Privacy and Security Workgroup Comments.
Their key point was the need to to ensure there is some kind of non-prescriptive functional demonstration of modular EHR components working together to ensure data integrity and privacy.
Finally Dixie Baker and Walter Suarez presented the NSTIC Hearing Update. Their key takeaway is that NSTIC is not making standards, it is suggesting frameworks for use of existing standards. In particular OAuth and OpenID are likely to be increasingly important.
A great meeting. I am hopeful ONC will incorporate the balanced comments for the workgroups into their regulation writing.
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