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Wednesday, March 10, 2010

On Governance for Developing a Policy Framework and Other Updates

One of the things I love about HIMSS is the social interaction that I get with people that I don't get from many other venues.  I had an interesting discussion with someone about how his organization put together a policy framework for health information exchange in a few short months.

The information exchange included a number of governmental agencies and participating healthcare organizations in a large city.  I believe the total number of agencies and organizations exceeded two dozen.  There were a few unique attributes to the governance model used to put together this framework that he expressed to me.
  1. They put together more than 100 use cases for information exchange that were based on real business cases.  In and of itself, this was probably a monumental task, however, because they had these business cases, they were able to explain the reasons that they needed particular abilities in the exchange.  This came into play frequently later.
  2. The legal end included lawyers who were tasked with figuring out how to set up the appropriate policy to accomplish the goals of the exchange.  Most of the time it seems that lawyers are tasked with protecting an organization from liability, rather than figuring out how to accomplish a task.  Yes, protecting the organization (and the patients) was one of their responsibilities, but they were also tasked with getting the work done.
  3. The various workgroups met on a frequent (but not extreme) basis to discuss the policy framework.  Silence implied consent to the framework that was proposed, so you had to show up to voice your concerns.
  4. Blocking problems were addressed by returning to the business case and explaining the need.  "Do you really want to prevent us from X?" was the question that was raised, where X was the goal of the business case.  That was often enough to restir interest in figuring out how to solve the problem. But just in case...
  5. There was also very strong top down support from the local leadership that was able to provide a forcing function.  When problems came up that seemed unresolvable, the leader was able to provide pressure to break the log-jam.
  6. The organization was very strong technically.  The person I spoke with had a very sound understanding of how to implement access control mechanisms to support the policy framework using standards-based technology.  I've run into only a few people outside of the security specialty in healthcare standards who understand this well.  This guy could probably have written the IHE Whitepaper on access controls in his sleep.
  7. They had enough resources to accomplish the task, not only from the policy development side, but also from the technical end.
I wish I could remember where this was done.  I seem to recall that it was a large northeastern city. 

This was another one of those meetings where both the party I was talking to and I had run out of business cards.  I never did get over to the CONNECT booth where he was at, because I had other duties that day at the Interoperability Showcase that day.

P.S.  Oh, and on that other "secret" issue I reported on earlier this week:  The standard that the Federal Government wishes to harmonize into the healthcare space is NIEM or the National Information Exchange Model.  The feedback I've gotten from at least two sources indicates that I was "right on" in what I reported two days ago here.  HL7 has started investigating NIEM.  The initial feedback from their investigation didn't set off any major firestorms so there may be some promise here.  I've been looking at it, skimming mostly, but expect to pay more attention as soon.  This site looked interesting.

I imagine we'll hear something about the new harmonization effort in the next week or so, although who knows whether this will be a big splash or a stealth program.  I suspect the former even though it started as the latter. 

I also expect that this harmonization activity will tie in somehow with the NHIN Direct activities. At the moment, that web site seems to be just a sequence of blogs from one person.  If NHIN DIRECT really wants to accomplish a draft by very early May, real discussions and work needs to get started alot quicker.  The time frames they suggest are rather agressive for drafting specifications from a volunteer base.  I'm wondering how they plan to crack that nut, and how much time they expect members to put into this effort.  I've been through crazy deadlines before on ONC projects (remember the HITSP 90 day diversion?), and I'm not sure I want to do it again.  But I am interested... and waiting to hear more.


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