The letter offers four high-level recommendations, as follows:
- Focusing on business cases and return on investment (ROI) objectives first;
- Requiring pilot and demonstration projects before national mandates of standards and implementation guidance;
- Ensuring national health information technology standards development organizations (SDOs) are engaged in the development of health IT standards guidance, along with other stakeholders from patient, provider and industry groups; and
- Establishing a minimum floor for standards and implementation guidance.
In our consulting engagements, we are often asked to help our clients navigate the standards development process. It usually starts with an incredulous question: how do we possibly get from the high-level statements above to a much longer and more difficult set of implementable criteria in a FHIR resource or an IHE profile where the correct SNOMED CT terms appear in the correct value sets with the correct cardinalities attached to the correct set of documentation choices? It seems like such a big gap to bridge, and we have products to build now.
There's no single answer, but we advise our clients to base their standards implementation efforts on a set of criteria pretty similar to what HL7 is recommending to the Senate. Go slow, choose carefully, but make a choice and go. The combination of government actions to set a policy direction, standards development to create the necessary artifacts, and market forces for reimbursement and quality, all work together to create better and better resources for high-quality documentation based on standards.
Standards implementation success isn't necessarily linear, nor always quick. Without good guidance and a clear strategy, it's still possible for a vendor to bet on the wrong standards, or implement a standard only to discover that they've negatively affected user satisfaction. Nonetheless, the long-term trend is for electronic health data to be more shareable, more standards-based. The train is still moving relatively slowly, but as it speeds up it will be much harder for data-silo'ed vendors to jump on.