Healtheway Comments to HIT Standards Committee Regarding NwHIN Power Team Recommendations (9/10/14)

Healtheway provided the following comment to the HIT Standards Committee following the NwHIN Power Team’s recommendations regarding query-based exchange.

“We agree with the recommendation to focus on enabling query-based exchange, by defining the functions and enabling multiple approaches, without prescribing how query-based exchange is conducted.

We do, however, believe the recommendations need to be tempered in the practical realities inherent in widespread adoption of query-based exchange.

First:  There was a disappointing lack of recognition in the NwHIN Power Team’s recommendations regarding the significant adoption of query-based exchange in production today using existing, mature national and international standards, such as SOAP, IHE XCA, XDS, XCPD, PIX, PDQ.  We recognize that all vendors may not wish to support these standards; however, there should be stronger recognition regarding the widespread adoption of mature, existing standards.

The eHealth Exchange alone, has nearly 80 participants, with an additional 20 nearing production, representing more than 30% of all US hospitals and 10,000 medical groups who treat 100 million patients.  There are millions of query-based transactions exchanged each year, within and between networks using these standards. Industry has already embraced query based exchange; and, it is important to not disrupt this.

We believe there should be more recognition regarding the level of production use of existing query capabilities and assure more balanced support of both existing and emerging approaches in 2017.  We have seen the issues caused by radical course changes and need to learn from those experiences.

Second, we acknowledge that there is growing interest in using FHIR as it progresses toward pilot implementation. It will take years to fully develop, as well as long-term planning. We caution having national policy primarily focus on an unproven, although potentially promising approach.  Anointing an unproven technology before it’s ready for widespread implementation, and in the absence of having supporting markets would increase costs, introduce burden and would unnecessarily disrupt current production efforts.  We believe that emerging approaches such as RESTful and FHIR should be properly vetted through real-world implementations, with measurable evidence that they will work as “predicted”, and that there is some level of demonstrated maturity and stability.

In addition, there should be a carefully coordinated and communicated industry-wide implementation planning that allows sufficient time to migrate without disrupting current production efforts, with input from public-private collaborative efforts such as Carequality.

Finally, technology should be a tool for enabling interoperability policy, but should not serve as the policy in and of itself, as the recommendations suggest.”

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