tag:blogger.com,1999:blog-4384692836709903146.post5765449626321965109..comments2024-03-27T09:55:23.143-07:00Comments on Dispatch from the Digital Health Frontier: In ONC I TrustJohn Halamkahttp://www.blogger.com/profile/04550236129132159307noreply@blogger.comBlogger4125tag:blogger.com,1999:blog-4384692836709903146.post-48442603525553961452010-03-17T10:48:20.669-07:002010-03-17T10:48:20.669-07:00Dear John,
We commend your clarifying the good in...Dear John,<br /><br />We commend your clarifying the good intentions and strong work ethic of ONC, and applaud ONC’s efforts to increase the transparency of decision making. TRUST is an essential and positive word! The qualifications of the members of the HIT Policy Committee and HIT Standards Committee, likewise, are impressive and contribute toward trust. We strongly agree with you that trust must be earned and also verified through consistent demonstration of transparency and positive outcomes. While we acknowledge that these efforts are under the tight Federal rulemaking constraints and deadlines, it’s our experience that more improvements are needed to advance confidence in the direction that ONC is heading. We have three recommendations:<br /><br />1. USE AND ENDORSE OPEN CONSENSUS-BASED PROCESSES<br />We believe that a consensus process, open to all stakeholders not just for input but for engagement in decision making, is the best way to reach the goal, although consensus is slower and more difficult to achieve than unilateral decisions. The representatives on the HIT Policy and Standards committees were hand-picked, well-intentioned individuals with informed opinions. As far as we know, there is no structure to ensure that they represent all required constituencies even informally. We recommend a more formal process to ensure that the committees represent all stakeholders including small, medium, and large organizations. We appreciate that inviting the public to listen to workgroup meetings and respond to blogs are steps in the right direction. But unlike true consensus-based processes (HITSP for example), where all can participate, the public’s role in workgroup meetings is limited to a few minutes at the end after decisions have already been made, so it’s unclear whether comments make any difference. Even the best group of 20+ individuals can’t possess the subject matter expertise on all the standards and MU which they recommend. Thus reliance on standards derived from open consensus-based processes remains essential.<br /><br />2. BUILD TRUST THROUGH CONTINUITY OF DIRECTION<br />Standards-based interoperability is a key goal that requires that people not only buy in to the goal but have confidence that others will too and that the standards will “stick.” They’re more confident when they trust that “following direction” will yield positive results. But there are instances where it appears that a few voices have overridden industry consensus processes built over the past five years, which has led to some “zigzagging” of direction. The US government first endorsed AHIC/HITSP/CCHIT processes and outputs, but now seems to backtrack on much of what has been done. For example, why is it necessary to reinvent user stories for transitions of care under NHIN Direct? Or to revisit HHS-recognized standards for patient summaries or point-to-point document sharing? Why not improve, extend, streamline, and clarify what was already written (e.g., previous AHIC/ONC use cases, HITSP interoperability specs, etc.)? <br /><br />Zigzags discourage trust: if the many developers who followed (trusted) the previously government-endorsed direction see that the rules change significantly, what’s to say that those rules won’t have major changes again after the 2010 and 2012 elections? Continuity of direction engenders trust: discontinuity engenders uncertainty and doubt and may cause some to think “Why bother? It’s going to change again anyway…” <br /><br />3. COMMUNICATE CONSISTENTLY AND TRANPARENTLY IN ALL HITECH INITIATIVES<br />Certain processes, e.g., commenting on the January IFR and NPRM, were well-communicated and open to all. However, the recent FBO.gov standards harmonization successor RFP process appeared to be much less open, almost invisible, and inaccessible to most. Clear, widespread communications for all HITECH initiatives is very important. <br /><br />In conclusion, we applaud the goal of Trust, and hope that our recommendations promote increased progress toward this goal.<br /><br />Respectfully submitted,<br />David Tao, Hans Buitendijk, and Lawrence McKnight MD<br />Siemens HealthcareDavidhttps://www.blogger.com/profile/13251393010554964308noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-37203632095960154722010-03-16T08:47:56.374-07:002010-03-16T08:47:56.374-07:00I agree. Having attended many of the HIT Standards...I agree. Having attended many of the HIT Standards and Policy Committee meetings, both as a member of the public and as someone who is trying to figure out how to best leverage my skills to help the considerable effort in achieving meaningful use, I share your impression of the quality of work being done. In breadth of experience from both the committee members and in those giving testimonials, in the measured - and sometimes lively - debate, and in the consideration being given to a broad range of stakeholders, including the willingness to learn lessons from other industries, the careful pragmatism of setting baseline standards while minimizing negative impact on innovation. I have been impressed and comforted by the quality of people and thought involved in the process.<br /><br />SarahUnknownhttps://www.blogger.com/profile/15322389134316881808noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-16328282513705963812010-03-15T22:43:59.268-07:002010-03-15T22:43:59.268-07:00Thanks for providing some good data and sharing y...Thanks for providing some good data and sharing your unique perspective with us.<br /><br />If you want to see some success on transparency see:<br /><br /><a href="http://radar.oreilly.com/2010/03/evolution-of-transparency.html" rel="nofollow">http://radar.oreilly.com/2010/03/evolution-of-transparency.html</a><br /><br />For a great analogy on NHIN Direct see:<br /><br /><a href="http://blog.nhindirect.org/2010/03/cakes-bakeries-and-recipes.html" rel="nofollow">http://blog.nhindirect.org/2010/03/cakes-bakeries-and-recipes.html</a>Ahierhttps://www.blogger.com/profile/13398190978662246852noreply@blogger.comtag:blogger.com,1999:blog-4384692836709903146.post-32608767127577640602010-03-15T09:03:02.776-07:002010-03-15T09:03:02.776-07:00From my perspective as an active participant on NH...From my perspective as an active participant on NHINdirect.org, I agree fully. I've broadened my outlook through participation (and hopefully added a bit to the discussion). However, I would like to see a broader set of opinions and thoughts to help ensure a useful outcome. Your appeal for participation across the board is on the mark, and NHINdirect.org is, I would argue, an excellent place for folks to add their perspective today. (And I mean "today" quite literally. There is no time like the present!)<br /><br />BrettUnknownhttps://www.blogger.com/profile/06888858343833487183noreply@blogger.com