1. HL7 CQI WG – Comment Opportunities
Two comment opportunities
ONC 2018 Interoperability Standards Advisory (comments due Sept 14 to HL7 Policy Advisory Committee)
ONC RFI on EHR Reporting Program (comments due Sept 20 to HL7 Policy Advisory Committee)

2. HL7 CQI WG ONC 2018 Interoperability Standards Advisory - Overview of Request for Comments
ISA represents ONC’s approach to coordinate the identification, assessment, and public awareness of interoperability standards and implementation specs
Scope: focus on electronic health information created in the context of treatment and subsequently used to accomplish an interoperability purpose (such as treatment, public health, administration, research); it is not exhaustive but expected to progressively and periodically expand
Main purposes still remains:
1) provide industry with single, public list of standards and implementation specs for use in clinical information interoperability; 2) reflect results of ongoing industry development and consensus when more than one standard exists; 3) document status of standards development, use, limitations, preconditions, dependencies, and security; 4) provide clarity, consistency and predictability to the public regarding standards and implementation specs; and 5) encourage industry to use standards in government programs, procurement, testing and certification
Key Links:
PDF Version:

3. HL7 CQI WG ONC 2018 Interoperability Standards Advisory - Overview of Request for Comments
Structure continues to include the following major sections:
Section I - Vocabulary/Code Sets/Terminology Standards and Implementation Specifications (i.e., “semantics”)
Section II – Content/Structure Standards and Implementation Specifications (i.e., “syntax”)
Section III – Standards and Implementation Specifications for Services (i.e., the infrastructure components deployed and used to address specific interoperability needs)
Section IV – Models and Profiles
Section V – Administrative Standards and Implementation Specifications (i.e., payment, operations and other "non-clinical" interoperability needs)
Section VI – Questions and Requests for Stakeholder Feedback
Appendices 

4. HL7 CQI WG ONC 2018 Interoperability Standards Advisory - Overview of Request for Comments
Online edition being updated periodically; major review done fall of each year; major updates to online edition done post review period (end of year)
Current version includes multiple updates done since last major review November, 2017:
March, 2018 – change menus and TOC to reflect ‘lettered’ sub-section format
December, 2017 – numerous changes in response to public comments received to prepare 2018 Ref Edition, including: 1) revisions to introduction language; 2) change in title of Social Determinants to Social, Psychological and Behavioral Data; 3) added two new interoperability needs under Care Plan (documenting/sharing medication-related care plans by pharmacists, sharing patient care teams for care plan); 4) consolidation of previous two Quality-related sections into a combined Section II-D: Clinical Quality Measurement and Reporting; 5) adding three interoperability needs to Electronic Prescribing (Prescriber response to Prior Auth, Prior Auth cancel request, ability to obtain patient’s medication history from PDMP); 6) adding interoperability need to Images section (format of radiation exposure dose reports); 7) change title of Patient Identification Management to Patient Demographic Record Matching; and others

5. HL7 CQI WG ONC 2018 Interoperability Standards Advisory - Overview of Request for Comments
Our comments from 2017
Section I - D: Functional Status/Disability – CDS/CQI
Repeat 2016 comment: We recommended considering PROMIS, acknowledging it is not an official standard and comes with the associated risk.
Section II - D – Clinical Quality Measurement - CQI
Interoperability Need: Sharing Quality Measure Artifacts for Quality Reporting Initiatives
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
Section II - E – Clinical Quality Reporting - CQI
Suggest a roadmap consideration under Limitations, Dependencies, and Preconditions for FHIR Clinical Reasoning for Clinical Quality Reporting
Update to QRDA Category I STU 4 for implementation of eCQMs in 2018 and QRDA Category I STU 5 for implemention of eCQMs in 2019.
Update to QRDA Category III STU 2.1 for aggregate reporting in 2018 and 2019

6. PROPOSED 2018 COMMENTS FROM CQI

7. PROPOSED 2018 COMMENTS FROM CQI

8. PROPOSED 2018 COMMENTS FROM CQI

9. PROPOSED 2018 COMMENTS FROM CQI

10. PROPOSED 2018 COMMENTS FROM CQI – OTHER SECTIONS
Section I – Vocabulary/Terminology/Code Sets
Social Determinants of Health – there are many coding systems. However, there does not seem to be much alignment across them.
Consider adding measures for Housing, Food, Water Quality and Environmental Factors
Look at NCVHS Environmental Scan of SDH measures at Scan_ FINAL.pdf
NCVHS Framework: community-health-and-well-being-v4/
Section II – Content/Structure Standards
We support CDS WG comments on the CDS sections and standards
Section IV – Models and Profiles
QI Core is out Reference Model for Quality Measure and Reporting; we recommend including it in this section of Models and Profiles

11. HL7 CQI WG ONC RFI on EHR Reporting Program
Under 21st Century Cures Act, HHS (ONC) is to create an EHR Reporting Program and establish a series of reporting criteria to be required as a condition of certification and maintenance of certification of EHR/Health IT
Cures Act require the EHR Reporting Program reporting criteria to address the following five categories: Security; interoperability; usability and user-centered design; conformance to certification testing; and other categories, as appropriate to measure the performance of certified EHR technology.
The Cures Act also suggests several other categories for consideration, including, but not limited to: Enabling users to order and view results of laboratory tests, imaging tests, and other diagnostic tests; exchanging data with clinical registries; accessing and exchanging data from medical devices, health information exchanges, and other health care providers; accessing and exchanging data held by federal, state, and local agencies.
RFI focused on the five mandatory categories, and questions are divided into two main sections: 1) Cross- cutting: Requests input on priorities on the intersection of health IT product-related reporting criteria and healthcare provider reporting criteria; and 2) Categories: Requests input on specific focus areas, including the reporting criteria categories required by the Cures Act.

12. HL7 CQI WG ONC RFI on EHR Reporting Program
Cross-Cutting Questions:
Please identify any sources of health IT comparison information that were not in the EHR Compare Report that would be helpful as potential reporting criteria are considered. In addition, please comment on whether any of the sources of health IT comparison information that were available at the time of the EHR Compare Report have changed notably or are no longer available.
Which, if any, of these sources are particularly relevant or should be considered as they relate to certified health IT for ambulatory and small practice settings?
What types of reporting criteria should developers of certified health IT report about their certified health IT products: That would be important to use in identifying trends, assessing interoperability and successful exchange of health care information, and supporting assessment of user experiences?
What recommendations do stakeholders have to improve the timeliness of the data so there are not significant lags between its collection and publication?
How could HHS encourage clinicians, patients, and other users to share their experiences with certified health IT?
Which particular reporting mechanisms, if any, should be avoided?
Would a common set of criteria reported on by all developers of certified health IT, or a mixed approach blending common and optional sets of criteria, be more effective as we implement the EHR Reporting Program?
In what ways can different health IT deployment architectures be accommodated? For instance, are there certain types of criteria that cloud-based certified health IT developers would be better able to report on versus those who are not cloud-based? How might this affect generating and reporting information on criteria?

13. HL7 CQI WG ONC RFI on EHR Reporting Program
Questions on “Categories”
What categories of reporting criteria are end users most interested in (e.g.,security, usability and user-centered design, interoperability, conformance to certification testing)? Please list by priority.
Describe other useful security and privacy features or functions that a certified health IT product may offer beyond those required by HIPAA and the ONC Health IT Certification Program, such as functions related to requirements under 42 CFR part 2.
Please comment on the usefulness of product integration as a primary means of assessing interoperability (as proposed in the EHR Compare Report).
What other domains of interoperability (beyond those already identified and referenced above) would be useful for comparative purposes?
Of the data sources described in this RFI, which data sources would be useful for measuring the interoperability performance of certified health IT products?
How helpful would CMS program data (e.g., Quality Payment Program MIPS Promoting Interoperability Category, Inpatient Hospital Promoting Interoperability Program, Medicaid Promoting Interoperability Programs) related to exchange and interoperability be for comparative purposes? What measures should be selected for this purpose? Given that some of these data may be reported across providers rather than at the individual clinical level, how would this affect reporting of performance by health IT product?
What other data sources and measures could be used to compare performance on interoperability across certified health IT products?
How should the above categories be prioritized for inclusion/exclusion in the EHR Reporting Program, and why? What other criteria would be helpful for comparative purposes to best support end users' needs (e.g., to inform health IT acquisition, upgrade, and implementation decisions)?