July 6, 2020

Response to Draft Voluntary User-Reported Criteria for the Electronic Health Record Reporting Program

Download The Sequoia Project’s complete response with appendix attached

The Sequoia Project is pleased to submit these comments on the Draft Voluntary User-Reported Criteria for the Electronic Health Record Reporting Program. We recognize the importance of these criteria and the proposed EHR Reporting Program to be administered by the Office of the National Coordinator for Health IT (ONC) and appreciate the provision of a 60-day public feedback period. Our comments focus on criteria related to interoperability and health information exchange.

The Sequoia Project is a non-profit, 501(c)(3) public-private collaborative that advances the interoperability of electronic health information for the public good. The Sequoia Project previously served as a corporate home for several independently governed health IT interoperability initiatives, including the eHealth Exchange health information network and the Carequality interoperability framework. The eHealth Exchange and Carequality now operate under their own non-profit organizations. The Sequoia Project currently supports the RSNA Image Share Validation Program, the Patient Unified Lookup System for Emergencies (PULSE), and the Interoperability Matters cooperative. Lastly, we are honored to have been selected by ONC to be the Recognized Coordinating Entity (RCE) for the Trusted Exchange Framework and Common Agreement (TEFCA).

These comments reflect our experience supporting large-scale, nationwide health information sharing, including active work with several federal government agencies. Through these efforts, we serve as an experienced, transparent, and neutral convener of public and private sector stakeholders to address and resolve practical challenges to interoperability. Our deep experience implementing nationwide health IT interoperability, including our track record of supporting and operationalizing federal government and private sector interoperability initiatives, provide a unique perspective on these draft criteria as they relate to interoperability and health information exchange.

Overall Perspectives
Our detailed comments are in the attached appendix. We also offer the following overall perspectives.
First, we agree strongly with the comments in the April 2020 report (Report) to the ONC by the Urban Institute “What Comparative Information Is Needed for the EHR Reporting Program?” (Report) that the EHR Reporting Program should prioritize criteria that measure the ability to exchange data with other entities and the ability to use exchanged data as key criteria for the Reporting Program. We further agree with the specific comments that reporting criteria should include documentation of a product’s capability to exchange with state-wide, regional, and national networks.

We also agree with comments summarized in the Report on the importance of reporting on security features and standards used and the recognition of the importance and value of the Carequality Technical Trust Policy, Version 2.0.
Finally, we urge Urban Institute and its partners to place a high priority on ensuring that comparisons across products and developers of certified health IT are valid and reliable. In this regard, we point you to the discussion that accompanied your recent presentation to the HITAC on June 17, 2020. We believe that as much attention needs to be paid to the methodology for data collection and fielding of surveys as on development of the criteria and survey instruments.

We appreciate the opportunity to provide you our comments on the Draft Voluntary User-Reported Criteria for the Electronic Health Record Reporting Program. The Sequoia Project stands ready to assist you in any way that we can.

Most respectfully,
Mariann Yeager
CEO, The Sequoia Project

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