Because the industry lacks a standardized UEL message wrapper, there’s little chance CMS/ONC can inject significant PCAST-report principles into Stage 2 of its Meaningful Use incentive program, according to Stan Huff and Dixie Baker, both members of the PCAST Workgroup, a subgroup of ONC’s HIT Policy Committee.
Workgroup Chair Paul Egerman, a retired software entrepreneur, set the tone for the meeting by noting that the group’s mandate was to discuss the PCAST report’s “implications and feasibility” on Meaningful Use not to “not to criticize the report, if it’s good or bad or right or wrong.”
Though continually pressed by Egerman — operating under the charge from both PCAST and National Coordinator David Blumenthal, M.D., that ONC move the nation toward the report’s recommendations “boldly and aggressively” — the duo adamantly resisted the injection of any measures into Stage 2 that would require use of a UEL wrapper.
“My concern is timeframe,” said Stanley Huff, M.D., professor of Biomedical Informatics at the University of Utah College of Medicine and CMIO at Intermountain Healthcare. “If we are talking about this push (of CCD elements) in a UEL wrapper, that implies that in the timeframe for Stage 2, there is a UEL that has been defined, approved and, hopefully, prototyped — one that we know is fit for the purpose, and I really question whether that can happen in the timeframe of Stage 2.”
Doug Fridsma, M.D., Ph.D., director of ONC’s Office of Standards and Interoperability, related that all Stage 2 measures had to be finalized for the Notice of Proposed Rulemaking (NPRM) by September of this year, which would mean everything had to be “completed, vetted and piloted by July.”
At that, Baker, Ph.D — SVP, CTO and Technical Fellow at Science Applications International Corporation’s health and life sciences business — promptly stated, “Then I would agree with Stan. Since we don’t have a common metadata UEL model in place, I think it’s true a UEL is not feasible by Stage 2.”
Baker went on to drive the point home by talking of her nascent work on the Privacy and Security Standards Workgroup. “We are just preparing at end of the month to present recommendations for digital certification standards that will be developed by the Standards and Interoperability Framework Team … I think a better target (for a UEL) is Stage 3.”
Huff continued: “The standards are not in place, and the there are no implementations in place. This thing has to be locked down so that you have a specification people can start programming against later this year. All of these things are doable, they are wonderful things, but the timeline is just not right for you to have enough public input, have people prototype it, and prove that it works.”
But Huff went on to say there was something which could be done to move Meaningful Use in the PCAST direction. “We could say — and it’s implied — that you have to be able to send a CCD using LOINC and SNOMED to a PHR, that is doable. What isn’t doable is when you say UEL wrapper, or moving to a PCAST approach with a UEL, that makes it not doable by July.”
At that, a workgroup member commented that if Huff’s assessment was accurate, the industry was in a “poor state of affairs.”
“It may be a poor state of affairs,” retorted Huff, “but I think that’s exactly where we are.”
jbormel says
Is human reproduction in a poor state of affairs because the process requires nine months?
I reach the opposite conclusion of the workgroup member who made that comment. If the quote included the word “industry”, so that it read “the industry was in a poor state of affairs”, then it’s simply incorrect. Industry in a good and healthy state knows that a proof-of-concept, while usually essential, does not reliably portend scaling issues. Only some of those are technological. The broad, international success of IHE exemplifies that industry can and has produced true interoperability and meaningful standardization.
Similarly, if the quote was actually saying that “the government regulatory and industry complex was in a poor state of affairs,” that would be incorrect as well. The ONC’s S&I framework has incorporated a staged-approach, concordant with respect for pregnancy-type processes that are irreducible. It has also been carefully kept open and inclusive, like the industry’s IHE process.
Anthony, your account sounded balanced (as usual). It would appear that what we’re seeing is responsible, adult supervision with respect to a regulatory process.
The slur on industry or regulatory process being “a poor state of affairs” is simply and profoundly ignorant. Was that taken out of context?
flpoggio says
Dr. Joe…
Great retort. I would take it a step further. Not only does nature take nine months, Mother Nature NEVER – not once – has delivered a complete set of specs, user manual, or trouble shooting guide with that wonderful product she has been delivering for the last million years. What’s wrong with that woman?? Why do we keep tolerating such failures? We should send the product back, or at least enact some tough legislation aimed at her. Sure would be much easier to automate medicine & healthcare if we only had the same level of documentation you get with your PC, or Windows7, or Ipad!
Frank Poggio
The Kelzon Group
Anthony Guerra says
Thanks for your comments gentlemen. Joe, I believe the comment was very much in context. In fact, I wrote the story almost in dialogue format to convey the discussion’s give and take. Anyone who wishes to hear the audio of that meeting can go so here. http://healthit.hhs.gov/media/policy_committee/2011-03-17_policy_pcast.mp3 Though the workgroup’s chair, Paul Egerman, continually reminds members to state their names before talking, many do not, or at least do not 100 percent of the time. That can make accurate attribution difficult, and that is why I had to report that comment without conveying who made it.
jbormel says
Anthony, as I know you agree, paradox characterizes healthy social affairs. This concept is well developed by my friend Richard Farson in his best seller, Management of the Absurd. I think that’s what’s going on here, and, it’s a good thing.
The Advisory Committees are necessarily comprised of both visionaries and realists. Their product ultimately needs to meet both ends. The need to connect assumptive goals (stretch) with a place that can be bridged from today.
I recognize the frustration of the “poor state” commenter, but respectfully point out that rushing into something unproven a la Dixie Baker/Staff Huff’s perspective, creates the possibility –and based on experience with massive implementation of federal mandates – some would assert even a probability of failure.
Who is at risk of that potential failure? The patient! It would be contrary to the Policy and Standards committee’s own principles to recommend something that carries a knowably serious possibility of putting patient safety at risk.
The key to paradox is recognizing it. Failure to do so predictably leads to abuse, whether it’s managing subordinates, children, or translating regulation into prudent policy.