1. Overview of Request for Comments ONC 2017 Interoperability Standards Advisory
ONC looking for comments on any last revisions, additions, or recommendations for the ISA’s 2017 online edition before they lock-in all of the ISA’s 2017 improvements to make the “2018 Reference Edition.”
The ISA is a dynamic, coordinated catalog of standards and implementation specifications that can be used to meet interoperability needs in healthcare.
The ISA will play a role in ONC’s efforts to implement the 21st Century Cures Act and serve as a way to harness industry input on interoperability standards best fit for a particular use in health IT.
Last year, ONC shifted from a static “document-based” ISA to a more interactive online platform, which allows for ongoing updates to occur throughout the year.

2. Overview of Request for Comments ONC 2017 Interoperability Standards Advisory
2018 “Reference Edition” ISA to be published later this year
ONC looking for input to ensure ISA reflects the latest/most accurate information about standards. ONC intends to add new components to the ISA, including:
Consumer-based interoperability needs as recommended by the former Health IT Standards Committee
New section on includes administrative standards and implementation specifications developed in coordination with CMS
Educational and informational resources to allow for better understanding of health IT interoperability concepts
New questions and answers submitted for stakeholder feedback
Comments accepted through November 20, 2017
HL7 Policy Advisory Committee requesting comments from WGs by October 15

3. Overall Instructions
Please review each section being requested from CQI, and define the following:
Whether the standards and implementation specifications named (name, version, etc) ARE STILL THE RIGHT ONES
Whether EACH of the SIX characteristics reported for EACH standard/implementation specification is still correct:
Standard Process Maturity (Final, Balloted Draft, In Development)
Implementation Maturity (Production or Pilot)
Adoption Level (0 to 5 Dots for Low, Low-Medium, Medium, Medium-High, High)
Federally Required (Yes/No)
Cost (Free or $)
Test Tool Availability (Yes, Yes($), Yes-Open, No, N/A)
Whether the emerging standards and emerging implementation specifications listed ARE STILL THE RIGHT ONES
Whether EACH of the SIX characteristics reported for EACH standard/implementation specification is still correct (same as above)
Whether there are any updates/corrections to be made on the “Limitations, Dependencies, Preconditions for Consideration” or “Applicable Security Patterns for Consideration” sections
Section I - D: Functional Status/Disability – CDS/CQI
Interoperability Need: Representing Patient Functional Status and/or Disability
HL7 Comment from 2016: We recommended considering PROMIS, acknowledging it is not an official standard and comes with the associated risk. Standards not maintained by an SDO or similar organization increases risks for implementers. While appropriate experts have developed many standards with the best of intentions, failure to move such standards into formal SDO organizations and processes leaves the standards without a clear plan for ongoing maintenance, update, and support. However, we still suggest including this standard where ONC can clearly identify that it is not under active maintenance by a formal SDO, and should clearly state the risks to implementers.
HL7 Comments for 2017:
Comment
Section I - M: Patient Clinical “Problems” (i.e., conditions) – PATIENT CARE / CQI
Interoperability Need: Representing Patient Clinical “Problems” (i.e., Conditions)
HL7 Comment from 2016: We submitted a comment that many systems capture/document conditions in other code sets – ICD-9/ICD-10. We suggested these other standards be recognized for current use (e.g., ICD-10) or as part of historical analysis/analytics/CDS (e.g., ICD-9). Similarly, for reporting HEDIS Quality Measures, SNOMED equivalents are not provided. Rather code sets such as ICD and CPT are used. We need better rationale/wording to have this addressed.
Section I - S – Social Determinants – PATIENT CARE/CQI ?
Interoperability Need: Representing Depression
HL7 Comment from 2016: We suggested to add – PHQ-4, which was not needed so need better rationale if still needed.
Section II - D – Clinical Quality Measurement - CQI
Interoperability Need: Sharing Quality Measure Artifacts for Quality Reporting Initiatives
HL7 Comment from 2016: We made the following suggestions that were not addressed:
Suggest to add a roadmap consideration under Limitations, Dependencies, and Preconditions: CQL-based HQMF major release 2 expected in 2017.
Suggest to add a roadmap consideration under Limitations, Dependencies, and Preconditions: The CQF on FHIR will be transitioned to FHIR Clinical Reasoning.
Suggest to add FluentPath as an emerging standards.
Please review and provide any updated suggestions that make a better case why it should be included.
Section II - E – Clinical Quality Reporting - CQI
It appears neither of our suggestions were addressed. Please review and provide any updated suggestions that make a better case why it should be included.
• Section III - B – Clinical Decision Support Services - CDS (CQI MIGHT BE INTERESTED…)
o Interoperability Need: Providing Patient-Specific Assessments and Recommendations Based on Patient Data for Clinical Decision support
 Typo: QICore/QuICK should be QICore/QUICK
o Interoperability Need: Retrieval of Contextually Relevant, Patient-Specific Knowledge Resources from Within Clinical Information Systems to Answer Clinical Questions Raised by Patients in the Course of Care
 The adoption level for “HL7 Version 3 Standard: Context Aware Knowledge Retrieval Application. (“Infobutton”), Knowledge Request, Release 2.” should be 4 bullets. [clarify rationale]
o Please review and provide any updated suggestions that make a better case why it should be included.
• Section VI – Questions
o ONC is asking for feedback on specific questions. The following questions jumped out for (specific) workgroups to review:
 In what ways has the ISA been useful for you/your organization as a resource? ONC seeks to better understand how the ISA is being used, by whom, and the type of support it may be providing for implementers and policy-makers.
• All WGs: Reflect on what HL7 member organizations have done that we want to contribute.
 An Appendix II has been added that includes educational and informational resources as recommended by the Health IT Standards Committee/2017 ISA Task Force. Are there other topics and/or existing resources which would be helpful to include in this area to increase stakeholder understanding of health IT interoperability issues?
• All WGs: Anything to add?
 Are there additional Interoperability Needs (with corresponding standards) that represent specific sociodemographic, psychological, behavioral or environmental domains that should be included in the ISA?
• CBCC, CIC, Behavioral Health, LongTerm Care, Learning Health System CQI MIGHT BE ALSO INTERESTED…
 Is the existing ISA format used for listing standards and implementation specifications applicable for listing Models and Profiles? Are there additional or different attributes that should be collected for them? Are there additional models and/or profiles that should be listed?
• ALL WGs – Any relevant EHR Profiles, DAMs and other models should be considered.
Section 218(b) of the PAMA directs CMS to establish a new program to promote the use of Appropriate Use Criteria for ordering and furnishing certain advanced imaging services
AUC: criteria that are evidence-based and are established to assist professionals who order and furnish certain advanced imaging services to make the most appropriate ordering and treatment decision for a specific clinical condition for an individual.
There are four major components of the AUC program:
Establishment of AUC (November 15, 2015)
Identification of mechanisms for consultation with AUC (April 1, 2016)
Commence AUC consultation by ordering professionals, and reporting on AUC consultation by furnishing professionals (January 1, 2017)
Identify outlier ordering professionals (annually after January 1, 2017)

4. Sample

5. Sections for CQI Review/Comment
Section I - D: Functional Status/Disability – CDS/CQI
Interoperability Need: Representing Patient Functional Status and/or Disability
HL7 Comment from 2016: We recommended considering PROMIS, acknowledging it is not an official standard and comes with the associated risk. Standards not maintained by an SDO or similar organization increases risks for implementers. While appropriate experts have developed many standards with the best of intentions, failure to move such standards into formal SDO organizations and processes leaves the standards without a clear plan for ongoing maintenance, update, and support. However, we still suggest including this standard where ONC can clearly identify that it is not under active maintenance by a formal SDO, and should clearly state the risks to implementers.
HL7 Comments for 2017:
We recommended considering PROMIS, acknowledging it is not an official standard and comes with the associated risk. Standards not maintained by an SDO or similar organization increases risks for implementers. While appropriate experts have developed many standards with the best of intentions, failure to move such standards into formal SDO organizations and processes leaves the standards without a clear plan for ongoing maintenance, update, and support. However, we still suggest including this standard where ONC can clearly identify that it is not under active maintenance by a formal SDO, and should clearly state the risks to implementers.
Comment

6. Sections for CQI Review/Comment
Section I - D: Functional Status/Disability – CDS/CQI

7. Sections for CQI Review/Comment
Section I - M: Patient Clinical “Problems” (i.e., conditions) – PATIENT CARE / CQI
Interoperability Need: Representing Patient Clinical “Problems” (i.e., Conditions)
HL7 Comment from 2016: We submitted a comment that many systems capture/document conditions in other code sets – ICD-9/ICD-10. We suggested these other standards be recognized for current use (e.g., ICD-10) or as part of historical analysis/analytics/CDS (e.g., ICD-9). Similarly, for reporting HEDIS Quality Measures, SNOMED equivalents are not provided. Rather code sets such as ICD and CPT are used. We need better rationale/wording to have this addressed.
HL7 Comments for 2017:
Comment

8. Sections for CQI Review/Comment
Section I - M: Patient Clinical “Problems” (i.e., conditions) – PATIENT CARE / CQI

9. Sections for CQI Review/Comment
Section I - S – Social Determinants – PATIENT CARE/CQI ?
Interoperability Need: Representing Depression
HL7 Comment from 2016: We suggested to add – PHQ-4, which was not needed so need better rationale if still needed.
HL7 Comments for 2017:
Comment

10. Sections for CQI Review/Comment

11. Sections for CQI Review/Comment

12. Sections for CQI Review/Comment

13. Sections for CQI Review/Comment
Section II - C – Clinical Decision Support CDS/CQI
Interoperability Need: Shareable Clinical Decision Support
HL7 Comments for 2017:
Agree with CDS WG statements
Comment
Interoperability Need: Provide Access to Appropriate Use Criteria
Interoperability Need: Communicate Appropriate Use Criteria

14. Sections for CQI Review/Comment

15. Sections for CQI Review/Comment

16. Sections for CQI Review/Comment
Section II - D – Clinical Quality Measurement - CQI
Interoperability Need: Sharing Quality Measure Artifacts for Quality Reporting Initiatives
HL7 Comment from 2016: We made the following suggestions that were not addressed:
Suggest to add a roadmap consideration under Limitations, Dependencies, and Preconditions: CQL-based HQMF major release 2 expected in 2017.
Suggest to add a roadmap consideration under Limitations, Dependencies, and Preconditions: The CQF on FHIR will be transitioned to FHIR Clinical Reasoning.
Suggest to add FluentPath as an emerging standards.
Please review and provide any updated suggestions that make a better case why it should be included.
HL7 Comments for 2017:
Recommend CQL-based HQMF STU 2.1 to address the QDM content expressly created for use with CQL. The STU has been tested in pilots addressing drafts for all eCQMs currently in the CMS programs.
Suggest FHIRPath as an emerging standard (previously called FluentPath and now renamed).
Suggest a roadmap consideration under Limitations, Dependencies, and Preconditions for FHIR Clinical Reasoning
List HQMF Normative (R1) instead of HQMF STU 2.1

17. Sections for CQI Review/Comment
Section II - D – Clinical Quality Measurement - CQI

18. Sections for CQI Review/Comment
Section II - E – Clinical Quality Reporting - CQI
It appears neither of our suggestions were addressed. Please review and provide any updated suggestions that make a better case why it should be included.
HL7 Comments for 2017:
Suggest a roadmap consideration under Limitations, Dependencies, and Preconditions for FHIR Clinical Reasoning for Clinical Quality Reporting
QRDA Category I STU 4 for implementation of eCQMs in 2018 and QRDA Category I STU 5 for implemention of eCQMs in 2019.
QRDA Category III STU 2.1 for aggregate reporting in 2018 and 2019

19. Sections for CQI Review/Comment
Section II - E – Clinical Quality Reporting - CQI

20. Sections for CQI Review/Comment
Section III - B – Clinical Decision Support Services - CDS (CQI MIGHT BE INTERESTED…)
Interoperability Need: Providing Patient-Specific Assessments and Recommendations Based on Patient Data for Clinical Decision support
HL7 Comment from 2016: Typo: QICore/QuICK should be QICore/QUICK
HL7 Comments for 2017:
Comment
Interoperability Need: Retrieval of Contextually Relevant, Patient-Specific Knowledge Resources from Within Clinical Information Systems to Answer Clinical Questions Raised by Patients in the Course of Care
HL7 Comment from 2016: The adoption level for “HL7 Version 3 Standard: Context Aware Knowledge Retrieval Application. (“Infobutton”), Knowledge Request, Release 2.” should be 4 bullets. [clarify rationale]. Please review and provide any updated suggestions that make a better case why it should be included.

21. Sections for CQI Review/Comment
Section III - B – Clinical Decision Support Services - CDS (CQI MIGHT BE INTERESTED…)

22. Sections for CQI Review/Comment
Section VI – Questions
ONC is asking for feedback on specific questions. The following questions jumped out for (specific) workgroups to review:
17-1. In what ways has the ISA been useful for you/your organization as a resource? ONC seeks to better understand how the ISA is being used, by whom, and the type of support it may be providing for implementers and policy-makers.
All WGs: Reflect on what HL7 member organizations have done that we want to contribute.
HL7 Comments for 2017:
Comment

23. Sections for CQI Review/Comment
Section VI – Questions (cont.)
17-3. An Appendix II has been added that includes educational and informational resources as recommended by the Health IT Standards Committee/2017 ISA Task Force. Are there other topics and/or existing resources which would be helpful to include in this area to increase stakeholder understanding of health IT interoperability issues?
All WGs: Anything to add?
HL7 Comments for 2017:
Comment

24. Sections for CQI Review/Comment
Section VI – Questions (cont.)
17-4. Are there additional Interoperability Needs (with corresponding standards) that represent specific sociodemographic, psychological, behavioral or environmental domains that should be included in the ISA?
CBCC, CIC, Behavioral Health, LongTerm Care, Learning Health System CQI MIGHT BE ALSO INTERESTED…
HL7 Comments for 2017:
Comment

25. Sections for CQI Review/Comment
Section VI – Questions (cont.)
17-7. Is the existing ISA format used for listing standards and implementation specifications applicable for listing Models and Profiles? Are there additional or different attributes that should be collected for them? Are there additional models and/or profiles that should be listed?
ALL WGs – Any relevant EHR Profiles, DAMs and other models should be considered.
HL7 Comments for 2017:
Comment