Hospitals and physicians have a little more than 13 months to buy, implement and demonstrate that they can “meaningfully use” an electronic health-record system to be ready for the first “payment year” under the American Recovery and Reinvestment Act of 2009 health information technology subsidy program.
One member of a federal advisory panel offering suggestions to HHS on the definition of meaningful use also has some innovative ideas on how to jump start health information exchange. Moving electronic health information between providers and to and from patients likely will be among the meaningful-use criteria to be formally adopted by HHS early next year.
Latanya Sweeney is a computer scientist and one of two privacy experts appointed to the HIT Policy Committee created under the ARRA passed in February.
Last month, in an 18-page white paper,
The Medical Billing Framework as the Backbone of the National Health Information Infrastructure, Sweeney talked about modifying existing claims data streams and X-12 message profiles to accommodate the movement of patient demographic information and “lightweight clinical information” such as diagnoses, allergies and prescription histories, to a new, special-purpose data storage and retrieval entity called a “consortium.” From the consortium, this basic but potentially life-saving information could be distributed to clinicians as well as patients' personal health-record systems. Sweeney's plan is posted on the
AdvanceHIT Project Web site.
Sweeney is an associate professor of computer science, technology and policy in the School of Computer Science at Carnegie Mellon University, Pittsburgh, and is director of its laboratory for international data privacy. She holds a doctorate in computer science from the Massachusetts Institute of Technology and an undergraduate degree in computer science from Harvard University.
Her ideas are meant to be only a part of a broader discussion among academics on the form and function of the proposed national health information network, according to a mission statement on the AdvanceHIT Project Web site. A key target audience for the group is the Office of the National Coordinator for Health Information Technology at HHS. Under the ARRA, the HIT Policy and Standards committees make their recommendations to the Office of the National Coordinator, or ONC, which is responsible for advising the HHS secretary on meaningful use, testing criteria for EHRs, data standards, privacy and security policy and fostering IT system interoperability.
“A key problem,” the project's mission statement says, “is the timetable on which ONC has to operate under ARRA and the lack of available well-formed possible designs. We want ONC to be able to contemplate competing designs for various interoperable parts of the infrastructure, to compare and contrast critical stakeholder issues in each proposed design, and then to construct a final design based on rigorous analyses and consideration.
“Identifying well-formed possible designs is not as simple as calling on industry to propose designs,” the statement said. “Industry will respond, but will do so, without needed knowledge of stakeholder concerns and without leveraging newer technologies from other areas. … We can help industry develop the best solutions by first providing them with well-formed problem statements that identify needed functions and stakeholder interests to consider.
“Many of us in academia are willing to help. Our idea is to join with industry and other stakeholders for intense, in-depth analyses sufficient to generate well-informed designs. Our mission is not to directly construct technical solutions or to insert ourselves into solutions. We will produce publicly available white papers that provide detailed analysis. Our approach offers a kind of “pre-certification” by promising viable technology designs that have a better likelihood of user acceptance, societal adoption and organizational uptake before they are built,” the statement said.
In September, Sweeney testified before her own HIT Policy Committee as it held a daylong session focusing on privacy and security issues. Sweeney called for baking privacy and security requirements into the architecture of the proposed NHIN as it is being designed. That call mirrors the concepts of “privacy by design” advocated by Ontario's information and privacy commissioner Ann Cavoukian, most recently for use in the development of the so-called “smart” electricity grid. As proposed, the new smart grid will include sophisticated home monitoring and data collection components, such as whether and when a friend's electric vehicle was recharged at your house.
Returning to Sweeney's white paper, she proposes tweaking and expanding the X12-837 claims submission, X12-835 claims decision, X12-270 eligibility inquiry and X12-271 eligibility response transaction formats to accommodate not only the movement of data they typically carry, such as diagnosis and procedure codes, but also allergies and prescription drug information.
Sweeney's model would transport data to the consortium by leveraging the quality data codes, or QDCs, appended to the claim stream and used by the CMS since 2007 in its Physician Quality Reporting Initiative.
Most of the quality measures in the list of meaningful uses recommended by the HIT Policy Committee earlier this year “already have QDCs,” Sweeney said
Sweeney makes extensive use of data flow diagrams in her white paper and detailed explanations of how a claims-based NHIN might work.
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