HIMSS questions Obama's plan for universal healthcare language
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| Image source: www.whitehouse.gov |
These are among the comments HIMSS submitted in response to a Request for Comments from the Office of the National Coordinator for Health IT (ONC) on the PCAST report, “Realizing the Full Potential of Health IT to Improve Healthcare for Americans: The Path Forward.”
The Universal Healthcare Data Exchange Language proposed in the PCAST document can be of significant benefit to the practice of healthcare, but only if it is coordinated with a variety of other standards and capabilities to form a well-integrated and standardized total system, HIMSS stated. “We urge the Health and Human Services (HHS) to incorporate this work as an integral component of a larger integrated plan for services and capabilities that extends across the entire spectrum of healthcare functions and activities.
The Chicago-based organization has “serious reservations” about PCAST’s assertion that the central element of universal exchange language for healthcare information must be meta-tagged individual data elements. “We believe it much more appropriate to focus on a ‘document’ or record-centric approach to healthcare information, as used in the HL7 CDA [Clinical Document Archive] documents, recognizing that HL7 also supports data organization and exchange of non-document data as needed. Continuity of Care Document and other CDA documents use highly extensible meta-tagged XML.”
The individual data element approach divorces data elements from key contextual information, such as associated structured data and non-structured data such as clinical impressions. “It creates a very material risk that virtual records created by the use of a browser will not provide a sufficiently complete or accurate basis for safe and effective clinical care,” HIMSS stated.
Contrary to the conclusions of PCAST, patient identification and matching across healthcare data is made substantially less precise when the unit of analysis is the individual data element rather than a more complete clinical document, such as an encounter summary. The potential workflow disruptions associated with supporting a highly granular meta-tagging approach could disrupt the patient care process, according to HIMSS.
“The specific approach called for by PCAST poses substantial and entirely unwarranted patient safety risks,” HIMSS commented. “The PCAST approach could lead to substantial and negative disruptions that will impose clinical and financial costs that are not offset by reasonably foreseeable benefits. Clearly, healthcare technologists and standards experts draw on work from broader informatics domains, but the risks associated with inaccurate or misleading healthcare data simply dwarf those that would be felt in almost any other sector."
The PCAST report also is “entirely too optimistic” about the ability of middleware to accurately generate the meta-tagged data called for. “The approach outlined would simply impose unwarranted additional strain on a healthcare system already facing the challenges of meaningful use, ICD-10 and SNOMED-CT implementation, value-based payment, quality reporting and accountable care organizations, to just name a few.
“The EHR of today is very different than that of five or ten years and ago and roadmaps for the near-term future portend even more innovative, patient-centric change. The PCAST report’s critique of EHRs as being primarily billing-focused is hopelessly out-of-date; it does not reflect newer technologies and standards that are already widely deployed across healthcare."
In summary, “the access and sharing of metadata-tagged data element can be best performed and implemented by sharing metadata-tagged data packaged in documents, but with access to individual data elements, performing filtering and aggregation at the requesting IT system,” HIMSS stated.
Click here for HIMSS complete commentary.