Last month (before they lost their budget), the Office of the National Coordinator for Health Information Technology (ONCHIT) released a Request for Information (RFI) seeking public comment regarding how widespread interoperability of health information technologies and health information exchange can be achieved through a National Health Information Network (NHIN). You can find the official documents here.
We listened in on their conference call December 6th, during which they answered questions regarding the RFI. (Answering questions about the questions, if you will.) Over 550 people participated in the call. ONCHIT will post a transcript of the call on this website on or before December 16th. Responses must be received on or before January 18, 2005 at 5:00 P.M. EST.
We didn't learn a whole lot from the conference call, but expect that we would learn a lot from people's responses. Indeed, just thinking about the questions is a useful exercise. Even if you don't intend to respond, if you care about these issues, it's worthwhile looking at them. Many of the questions would also be applicable for consideration at the regional level as well.
Below for convenience, we've paraphrased and shortened the questions a bit. If you're thinking about responding read the official ones.
1. How would we define a National Health Information Network (NHIN), particularly as it pertains to the information contained in or used by electronic health records. What are the key barriers and key enablers to interoperability?
2. What type model a NHIN would allow widely available access to information as it is produced and used across the health care continuum; enable interoperability and clinical health information exchange broadly across most/all HIT solutions; protect patients’ individually-identifiable health information; and allow vendors and other technology partners to be able to use the NHIN in the pursuit of their business objectives? What roles of should various private- and public- sector entities play?
3. What aspects of a NHIN could be national in scope (i.e., centralized commonality or controlled at the national level), versus those that are local or regional in scope? The Feds take care to note that “national” and “regional” are not meant to necessarily imply federal or local governments.
Organizational and Business Framework
4. What type of framework could be needed to develop, set policies and standards for, operate, and adopt a NHIN? What kinds of entities and stakeholders could compose the framework? How would you approach the following questions?
- How could a NHIN be developed? What could be key considerations in constructing a NHIN? What could be a feasible model for accomplishing its construction?
- How could policies and standards be set for the development, use and operation of a NHIN?
- How could the adoption and use of the NHIN be accelerated for the mainstream delivery of care?
- How could the NHIN be operated? What are key considerations in operating a NHIN?
5. What kind of financial model could be required to build a NHIN? What are potential sources of initial funding, relative levels of contribution among sources and the implications of various funding models.
6. What kind of financial model could be required to operate and sustain a functioning NHIN and what are the implications of various financing models?
7. What privacy and security considerations, including compliance with relevant HIPAA rules, are implicated by the NHIN, and how could they be addressed?
8. How could the framework for a NHIN address public policy objectives for broad participation, responsiveness, open and non-proprietary interoperable infrastructure?
Management and Operational Considerations
9. How could private sector competition be appropriately addressed and/or encouraged in the construction and implementation of a NHIN?
10. How could the NHIN be established to maintain a health information infrastructure that:
- evolves appropriately from private investment;
- is non-proprietary and available in the public domain;
- achieves country-wide interoperability; and
- fosters market innovation.
11. How could a NHIN be established so that it will be utilized in the delivery of care by healthcare providers, regardless of their size and location, and also achieve enough national coverage to ensure that lower income rural and urban areas could be sufficiently served?
12. How could community and regional health information exchange projects be affected by the development and implementation of a NHIN? What issues might arise and how could they be addressed?
13. What effect could the implementation and broad adoption of a NHIN have on the health information technology market at large? Could the ensuing market opportunities be significant enough to merit the investment in a NHIN by the industry? To what entities could the benefits of these market opportunities accrue, and what implication (if any) does that have for the level of investment and/or role required from those beneficiaries in the establishment and perpetuation of a NHIN?
Standards and Policies to Achieve Interoperability
14. What kinds of entity or entities could be needed to develop and diffuse interoperability standards and policies? What could be the characteristics of these entities? Do they exist today?
15. How should the development and diffusion of technically sound, fully informed interoperability standards and policies be established and managed for a NHIN, initially and on an ongoing basis, that effectively address privacy and security issues and fully comply with HIPAA? How can these standards be protected from proprietary bias so that no vendors or organizations have undue influence or advantage?
16. How could the efforts to develop and diffuse interoperability standards and policy relate to existing Standards Development Organizations (SDOs) to ensure maximum coordination and participation?
17. What type of management and business rules could be required to promote and produce widespread adoption of interoperability standards and the diffusion of such standards into practice?
18. What roles and relationships should the federal government take in relation to how interoperability standards and policies are developed, and what roles and relationships should it refrain from taking?
Financial and/or Regulatory Incentives and Legal Considerations
19. Are financial incentives required to drive the development of a marketplace for interoperable health information, so that relevant private industry companies will participate in the development of a broadly available, open and interoperable NHIN? If so, what types of incentives could gain the maximum benefit for the least investment? What restrictions or limitation should these incentives carry to ensure that the public interest is advanced?
20. What kind of incentives should be available to regional stakeholders (e.g., health care providers, physicians, employers that purchase health insurance, payers) to use a health information exchange architecture based on a NHIN?
21. Are there statutory or regulatory requirements or prohibitions that might be perceived as barriers to the formation and operation of a NHIN, or to support it with critical functions?
22. How could proposed organizational mechanisms or approaches address statutory and regulatory requirements (e.g., data privacy and security, antitrust constraints and tax issues)?
23. What are the major design principles/elements of a potential technical architecture for a NHIN? (They don't want an overly technical response to this one.)
24. How could success be measured in achieving an interoperable health information infrastructure for the public sector, private sector and health care community or region?
There are some good questions here. Have a ball with them.