Feedback on EHR Metadata: Go SlowAssociations Object to Requiring Tags for EHR Incentive Program
The Office of the National Coordinator for Health IT had issued an advance notice of proposed rulemaking soliciting comments on the notion of requiring the use of metadata tags for data elements within summary care records downloadable by patients (see: ONC Releases Metadata Standards Notice). Such tags could be used to describe the data elements, such as to indicate the source of the data or patient privacy preferences for sharing the data with providers.
The College of Healthcare Information Management Executives argues that it's inappropriate to include a metadata requirement in the "meaningful use" criteria for stage two of the EHR incentive program, which begins next year. "We do not believe that the meaningful use regulatory schema is the appropriate venue to mandate unproven standards or incomplete protocols," says CHIME, which represents healthcare CIOs.
CHIME notes that ONC is working on a number of projects to develop and test metadata standards, including the new Query Health and Data Segmentation initiatives. "We do not believe enough progress has been made, or evidence gathered, to support the technologies and strategies needed to include the metadata standards as part of meaningful use stage two," CHIME states in its comment letter.
Lack of EvidenceThe American Hospital Association takes a very similar position. "The AHA believes that inclusion of these standards in stage two meaningful use regulations would be premature in the absence of systematic evidence that they offer demonstrated benefits that outweigh the costs of implementation and are feasible for use in all care settings."
And the American College of Physicians, which represents 132,000 internal medicine physicians, objects to what it calls "the prospect of standards development via regulation." Instead, it advocates working through existing standards-setting bodies. "The outcome of any comment solicitation must be to submit a set of recommendations to an appropriate standards development organization for proper implementation," it states.
Comments on the proposal can be viewed at a government website. The deadline for submitting comments is Sept. 23.
Easing Health Information ExchangeONC issued the solicitation for comments in light of a report from the President's Council of Advisors on Science and Technology, which called for extensive use of metadata tagging of electronic health records to help ease health information exchange. PCAST urged requiring metadata tags in future stages of the EHR incentive program.
Earlier, an ONC workgroup that reviewed the PCAST report advocated a go-slow approach to testing the council's recommendations (see: Tests of new HIE Architecture Slated).
Farzad Mostashari, who heads ONC, said earlier that his office would review the comments received to help determine the feasibility of including any implementation of metadata tags in stage two EHR incentive program requirements.
Stage one EHR meaningful use requirements are now in place, and federal authorities are continuing development of stage two requirements. A draft of stage two criteria could come late this year or early next year for implementation later in 2012.