9 concerns about EHR information blocking from a HIMSS letter to ONC

While HIMSS' EHR Association appreciates the care with which ONC discussed the challenges to interoperability in its recent Report on Health Information Blocking, it was not without its fair share of concerns and critiques of the report's language and conclusions. The EHRA addressed these in a recent letter to ONC.

"The EHRA is dedicated to establishing an environment where the right data can flow to the right party at the right time, using a set of agreed-upon standards," the letter reads. "We look forward to addressing challenges to interoperability and advancing use of exchange. To that end, the EHRA will further review its EHR Developer Code of Conduct to determine how to strengthen it in support of this shared objective."

Here are nine concerns the EHRA raises about ONC's information blocking report.

• The ONC included the recommendation to strengthen in-the-field surveillance of ONC-certified health IT in its report. However, HIMSS said it is unclear how that type of surveillance would help to address any information blocking taking place.
• Although standards variability can impact the ability of systems to interoperate in some instances, constraining those standards — proposed by the ONC — can have the unintended effect of not satisfying the reality of variation in software.
• Effective governance must be established across public and private stakeholders that increases trust and enables data to move.
• There is a fine line between promoting transparency to have an improved understanding of the necessary components to realize interoperability and the type of transparency that would limit a provider's ability to be flexible in developing new market solutions.
• Increased efforts to improve stakeholder understanding of HIPAA standards that affect information sharing will help remove hesitation to share certain types of data.
• The ONC recommended illegal business practices be referred to appropriate law enforcement agencies, but HIMSS said it is unclear how this action should be applied further.
• HIMSS suggests maturing interoperability is the more critical action at this point.
• Real cases of information blocking will become more evident if and when they occur if CMS works alongside stakeholders to coordinate payment incentives for interoperability.
• Changing payment and delivery mechanisms, as well as associated innovation and competition aligned with them, are most critical to achieving interoperability.

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